Justia Idaho Supreme Court Opinion Summaries

Samuel and Peggy Edwards, residents of Rexburg, Idaho, refused to allow PacifiCorp, doing business as Rocky Mountain Power Company, to install a smart electrical meter on their property due to health concerns. Rocky Mountain considered this refusal a violation of its terms of service, which required access to electrical meter bases. After negotiations failed, Rocky Mountain informed the Edwards that their electrical service would be terminated unless they allowed the installation. The Edwards filed a formal complaint with the Idaho Public Utilities Commission (PUC), arguing they had not denied access and should be allowed to opt-out of the smart meter installation.The PUC consolidated the Edwards' complaint with similar complaints from other customers and granted Rocky Mountain's motion to dismiss, concluding that the Edwards had not provided evidence that smart meters presented a legitimate safety concern and that Rocky Mountain had the authority to access and replace meters. The Edwards' motion for reconsideration was also dismissed by the PUC, leading them to appeal to the Idaho Supreme Court.The Idaho Supreme Court reviewed whether the PUC properly determined that Rocky Mountain had the authority to access the Edwards' property to replace the existing meter with a smart meter. The Court affirmed the PUC's decision, concluding that the tariff provisions allowed Rocky Mountain to access and replace meters. The Court also found that the Edwards' constitutional arguments were waived due to insufficient support and authority. The PUC's orders dismissing the Edwards' complaint and denying reconsideration were affirmed. View "Edwards v. IPUC" on Justia Law

James and David Hart were involved in a real estate transaction with Millennial Development Partners, LLC, from 2016 to 2022. The Harts filed a complaint in September 2021 seeking a declaratory judgment that future purchases would be unenforceable. The district court set a trial date for July 12, 2022, with a backup date of October 11, 2022, and required discovery to be completed sixty days before trial. Millennial answered the complaint on June 7, 2022, asserting eleven affirmative defenses and counterclaimed for declaratory relief. The Harts' counsel requested a trial continuance due to an undisclosed conflict of interest with previous counsel. The district court continued the trial to October and ordered the Harts to file a motion and brief establishing good cause to amend the scheduling order. The Harts failed to comply with this order.The district court of the Sixth Judicial District of Idaho struck the Harts' pleadings and dismissed the case without prejudice as a sanction for failing to follow the court’s scheduling order. Millennial moved for attorney fees, which the district court awarded on two grounds: as a sanction for disobeying the scheduling order and under Idaho Code section 12-121, finding the Harts pursued the case unreasonably. The district court calculated the award considering Idaho Rule of Civil Procedure 54(e)(3) factors and awarded Millennial $9,592.46 in attorney fees and costs. The Harts moved to reconsider, arguing the district court incorrectly applied Idaho Rule of Civil Procedure 37(d)(3) and prematurely applied Idaho Code section 12-121. The district court clarified its sanction under Rule 16(e) and upheld the award.The Supreme Court of Idaho affirmed the district court’s decision, holding that the district court did not abuse its discretion in sanctioning the Harts under Idaho Rule of Civil Procedure 16(e) and awarding attorney fees under Idaho Code section 12-121. The court also affirmed the calculation of attorney fees and awarded Millennial attorney fees on appeal under Idaho Code section 12-120(3). View "Petersen v. Millennial Development Partners, LLC" on Justia Law

Sunnyside Park Utilities, Inc. (SPU) provides water and sewer services to commercial properties in Bonneville County, Idaho. Donald Sorrells, the owner of a lot in the Sunnyside Industrial & Professional Park, received a "Will Serve" letter from SPU in 2018, agreeing to provide water and sewer services based on his representation that he would install only two restrooms. However, Sorrells installed additional unauthorized water and sewer connections, leading to repeated excessive discharges into SPU's septic system. Despite multiple notices and requests for remediation from SPU, Sorrells failed to address the issues adequately, resulting in SPU seeking a declaratory judgment against him.The District Court of the Seventh Judicial District of Idaho found that Sorrells was a persistent violator of SPU's Sewer Rules and Regulations but determined that the Idaho Public Utilities Commission (IPUC) retained original jurisdiction over SPU's water system. The court denied SPU's requests for costs and attorney fees, leading to appeals from both parties.The Supreme Court of Idaho reviewed the case and affirmed the district court's judgment. The court held that the district court did not err in granting a declaratory judgment to SPU regarding Sorrells' violations of the sewer rules. However, it also upheld the district court's determination that the IPUC initially had jurisdiction over SPU's water system, as SPU had not established its nonprofit status at the time of filing. The court further affirmed the denial of attorney fees and costs to SPU, concluding that the Rules and Regulations did not expressly provide for such fees.On appeal, the Supreme Court declined to consider the merits of Sorrells' arguments due to his failure to comply with the Idaho Appellate Rules. The court also denied SPU's request for attorney fees and costs on appeal, as SPU did not prevail on its cross-appeal. View "Sunnyside Park Utilities, LLC v. Sorrells" on Justia Law

An attorney discipline case arose from allegations that Justin Oleson violated several Idaho Rules of Professional Conduct while representing Jeff Katseanes in post-divorce proceedings. Jeff's ex-wife, Judy, filed a civil complaint against him for unpaid spousal support, leading to a judgment and a motion for a Qualified Domestic Relations Order (QDRO) to access Jeff's retirement funds. Despite the district court granting the QDRO, Oleson advised Jeff to withdraw the funds, leading to further legal complications, including Jeff's contempt of court for failing to file an accounting of the funds.The Professional Conduct Board Hearing Committee found that Oleson violated Rules 1.7(a)(2), 3.4(c), and 8.4(d), recommending a public reprimand. However, they did not find clear and convincing evidence for violations of Rules 1.2(a), 1.3, 1.4, 4.1, and 8.4(c). Both the Idaho State Bar (ISB) and Oleson appealed the Committee's decision.The Idaho Supreme Court reviewed the case, affirming the Committee's findings of violations of Rules 1.7(a)(2), 3.4(c), and 8.4(d), but reversing the findings regarding Rules 1.2(a), 1.4, 4.1, and 8.4(c), determining that Oleson did violate these rules. The Court found that Oleson failed to consult with Jeff about the consequences of not filing the accounting, made misleading statements to a third party, and had a conflict of interest. The Court also concluded that Oleson’s actions were prejudicial to the administration of justice.Given the severity of the violations, Oleson's history of misconduct, and the absence of mitigating factors, the Idaho Supreme Court vacated the public reprimand and disbarred Oleson from practicing law in Idaho, effective immediately. Oleson is barred from applying for readmission for five years. His request for attorney fees was denied. View "ISB v. Oleson" on Justia Law

The plaintiffs, Kandi Terry-Smith and Roy A. Smith, Jr., filed a complaint against Mountain View Hospital (MVH) and Idaho Falls Community Hospital (IFCH) alleging medical malpractice after Kandi suffered an injury while a patient at MVH. The complaint was filed on March 11, 2022, and a second, identical complaint was filed on September 8, 2022. The first case was dismissed for inactivity, but the district court granted an extension for service of process. The process server, Tony Mares, filed an affidavit claiming he served MVH, but deficiencies were later found.In the district court, MVH moved to dismiss the second case as time-barred and the first case for insufficient service of process. The district court denied the Smiths' motion to consolidate the cases and dismissed the second case. The district court granted MVH’s motion to dismiss the first case for insufficient service of process, finding that the Smiths failed to properly serve MVH. The Smiths' subsequent motions for reconsideration, to amend the complaint, and for additional extensions were denied. The district court also denied the Smiths' I.R.C.P. 60(b) motion for relief from the order denying reconsideration and judgment.The Idaho Court of Appeals reviewed the case and affirmed the district court’s judgment. The court held that the Smiths failed to show good cause for the failure to timely serve MVH and did not exercise due diligence. The court also found no excusable neglect and determined that the Smiths' attorney's reliance on the process server’s affidavit was unreasonable. The court denied MVH’s request for attorney fees in the district court due to the lack of a cross-appeal but granted attorney fees and costs on appeal, finding the Smiths' appeal frivolous and without foundation. View "Smith v. Mountain View Hospital, LLC" on Justia Law

Crystal Lorene Limary and Shaun Patrick McLean were married in 2015 and had one child together. They moved into a house purchased by Shaun's parents in 2016, making monthly payments to them until 2019 when Shaun took out a mortgage to buy the house, using a $70,000 gift of equity from his parents as a down payment. Crystal filed for divorce, and the couple disagreed on the classification of the house, the $70,000 gift, a camper trailer, and the parenting schedule for their daughter.The magistrate court held a four-day trial, during which it extensively questioned the parties and witnesses. The court determined that the house and camper trailer were community property and that the $70,000 was a gift to both Crystal and Shaun. Shaun appealed, arguing that the magistrate court's conduct at trial was inappropriate and biased. The district court agreed, finding that the magistrate court's active participation obscured the reliability of its decision. The district court vacated the judgment and remanded the case with instructions to reassign it to a different judge.The Supreme Court of Idaho reviewed the district court's decision and affirmed it. The court held that the magistrate court abused its discretion by extensively questioning the parties and witnesses, which affected Shaun's right to a fair trial. The court concluded that the district court did not err in vacating the judgment and remanding the case for a new trial with a different magistrate judge. Neither party was awarded attorney fees on appeal, but costs were awarded to Shaun as the prevailing party. View "Limary v. McLean" on Justia Law

This case involves the termination of parental rights and an adoption proceeding. Jane Doe 1 ("Mother") and John Doe ("Father") had a child out of wedlock. Approximately eight months after the child's birth, Mother and her fiancé filed a petition to terminate Father's parental rights and allow the fiancé to adopt the child. Mother did not serve the petition on Father, and he did not participate in the proceedings. The magistrate court terminated Father's parental rights and granted the adoption. Father later filed two motions to set aside the judgment, arguing that his due process rights were violated due to lack of notice. This appeal concerns Father's second motion.The magistrate court denied Father's second motion, finding it barred by res judicata. The district court disagreed, reversed the magistrate court's order, and remanded the matter for the magistrate court to consider the motion on its merits. Mother appealed, arguing that Father's motion was barred by procedural doctrines, including res judicata and waiver.The Supreme Court of Idaho held that Father's Rule 60(b)(4) motion alleged a fundamental error that deprived him of his right to procedural due process, which in turn violated his fundamental constitutional right to raise his child. The Court concluded that the fundamental error doctrine applies to create an exception to the doctrines of res judicata and waiver. The Court affirmed the district court's decision and remanded the matter to the magistrate court to hold an evidentiary hearing to determine whether Father's Rule 60(b)(4) motion was timely and, if so, whether the termination and adoption judgment is void. The Court also awarded partial attorney fees to Father for defending against certain arguments raised by Mother on appeal. View "Doe v. Doe" on Justia Law

Jon and Shawna Hill, along with their children, filed a medical malpractice lawsuit against Dr. Stuart Clive and his employer, Emergency Medicine of Idaho, P.A. (EMI), alleging that Clive misdiagnosed Jon Hill with vertigo when he was actually suffering from a stroke. This misdiagnosis led to severe physical and cognitive impairments for Jon Hill. The Hills claimed negligence, gross negligence, reckless misconduct, and respondeat superior liability. The district court dismissed the children's claims, ruling that Idaho does not recognize a claim for loss of parental consortium. The jury found in favor of EMI and Clive, and the district court denied the Hills' motion for a new trial based on alleged juror misconduct.The Hills appealed the district court's dismissal of their children's claims, two evidentiary rulings, and the denial of their motion for a new trial. The Idaho Supreme Court affirmed the dismissal of the children's claims, agreeing that Idaho law does not recognize a claim for loss of parental consortium for non-fatal injuries. The court noted that creating such a cause of action involves significant policy considerations best left to the legislature.The Idaho Supreme Court reversed the district court's decision to allow expert testimony on "hindsight bias" by EMI's expert, Dr. Opeolu M. Adeoye, finding it irrelevant and prejudicial. The court held that this error affected the Hills' substantial rights, as the testimony improperly endorsed EMI's theme of hindsight bias, potentially influencing the jury's decision. Consequently, the judgment in favor of EMI and Clive was vacated, and the case was remanded for a new trial. The court did not address the Hills' other issues on appeal due to the remand. EMI's request for attorney fees on appeal was denied, as they were not the prevailing party. View "Hill v. Emergency Medicine of Idaho, P.A." on Justia Law

Sherry Cole filed a formal complaint against Rocky Mountain Power (RMP) alleging she had been overbilled due to her power meter being cross-connected with her neighbor’s. Initially, an RMP employee confirmed the cross-connection and credited her account with $1,256.45. However, subsequent tests revealed no cross-connection, leading RMP to remove the credit and instead apply a $450 credit for the inconvenience. Cole then filed a formal complaint with the Idaho Public Utilities Commission, which dismissed her complaint due to lack of evidence of overcharging. Cole's motion for reconsideration was also denied.The Idaho Public Utilities Commission reviewed Cole’s complaint and RMP’s response, which included calculations of her energy usage and an affidavit from an investigator who found no cross-connection. The Commission dismissed Cole’s complaint, finding no evidence of overcharging, and denied her petition for reconsideration, stating she failed to demonstrate the dismissal was unreasonable or unlawful. Cole appealed to the Supreme Court of Idaho, asserting multiple errors.The Supreme Court of Idaho affirmed the Commission’s decisions. The Court found that the Commission’s findings were supported by substantial and competent evidence, including the investigator’s analysis and the results of two breaker tests. The Court also held that Cole’s constitutional arguments were waived as they were raised for the first time on appeal and were not supported by sufficient legal authority. Additionally, the Court ruled that pro se litigants are not entitled to attorney fees, and since Cole appeared pro se and did not prevail, she was not awarded attorney fees. View "Cole v. Idaho Public Utilities Commission" on Justia Law

Elizabeth Corey Raber (Mother) and Michael Robert Raber (Father) married in 2019 in Texas and had one child. They moved to Coeur d’Alene, Idaho, in June 2020. Their relationship involved significant conflict, including a domestic dispute in June 2020 and a felony domestic battery charge against Father in December 2021, which was later dismissed. They separated, and Mother filed for divorce in January 2022, requesting joint legal and physical custody but primary physical custody and permission to relocate to Texas with the child. Father initially sought sole custody but later requested joint custody with equal time.The magistrate court ordered a Parenting Time Evaluation (PTE), which recommended joint legal custody with Mother having sole decision-making authority over schooling and routine medical care. The PTE also recommended that Mother have primary physical custody and be allowed to relocate to Houston. The magistrate court proposed two custody options: one where the child would stay in Idaho with a week-on/week-off schedule, and another where the child would fly between Idaho and Texas every two weeks. The court entered a judgment based on the second option after Mother relocated to Texas.The Supreme Court of Idaho reviewed the case and found that the magistrate court failed to consider all relevant factors, including the impact of the child traveling 2,000 miles every two weeks and the effect on the child’s education and stability. The court held that the magistrate court abused its discretion by not making a specific determination regarding the best interests of the child. The judgment was vacated, and the case was remanded for further proceedings to properly analyze the best interests of the child and consider all relevant factors. The court declined to award costs on appeal, as there was no prevailing party. View "Raber v. Raber" on Justia Law