Justia Idaho Supreme Court Opinion Summaries

Lewis Patrick and Michele Sivertson owned and managed Laughing Dog Brewing, Inc. (LDB), which faced financial difficulties in 2017. To address these issues, they, along with affiliated entities AHR, LLC and Fetchingly Good, LLC, engaged attorney Ford Elsaesser to restructure their debt. Elsaesser drafted a promissory note and facilitated the transfer of LDB’s assets to AHR and Fetchingly Good, allegedly without disclosing conflicts of interest or legal risks. After the asset transfer, Fetchingly Good assumed LDB’s operations, and LDB filed for bankruptcy. Acorn Investments, LLC, a creditor with a judgment against LDB, sued the Original Plaintiffs under various theories, including the Idaho Uniform Voidable Transactions Act and racketeering statutes.The litigation between Acorn and the Original Plaintiffs was resolved through a settlement agreement. The Original Plaintiffs stipulated to a judgment in favor of Acorn, but Acorn agreed not to execute on the judgment. Instead, Acorn received an assignment of the Original Plaintiffs’ claims against Elsaesser, including legal malpractice, breach of contract, and breach of fiduciary duty. Acorn substituted as plaintiff in the malpractice case. Elsaesser moved for summary judgment, arguing that the malpractice claim was not assignable. The District Court of the First Judicial District, Bonner County, agreed and dismissed the case without prejudice, finding the assignment did not meet the exception for assignability established in St. Luke’s Magic Valley Regional Medical Center v. Luciani.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court’s judgment. The Court held that the assignment of the legal malpractice claim to Acorn did not fall within the Luciani exception, which allows assignment only when such claims are transferred as part of a larger commercial transaction involving other business assets and liabilities. Here, only the claims were assigned, not any business assets or obligations. The Court also declined to award attorney fees to either party, but awarded costs to Elsaesser. View "Acorn Investments, LLC v. Elsaesser" on Justia Law

After a 22-year-old man was killed in a car accident caused by a drunk driver, his parents, who were no longer together, each filed separate wrongful death lawsuits. The mother and father’s cases were consolidated and settled before trial, but they could not agree on how to divide the settlement proceeds. The law firm holding the funds initiated an interpleader action to have the court determine the appropriate division. The parents had a complicated history, including periods of estrangement, custody disputes, and issues related to drug use and financial support.The District Court of the Fourth Judicial District, Ada County, held an evidentiary hearing and ultimately awarded 75% of the net settlement proceeds to the mother and 25% to the father. The court based its decision on findings that the father had failed to fulfill his parental and legal obligations, including not paying child support, misusing disability payments intended for the child, and engaging in illegal drug use with his son. The court found that the mother had provided more consistent emotional and financial support. The father appealed, arguing that he was entitled to half of the proceeds and that the court erred by considering his past conduct rather than the proper legal standard for wrongful death damages.The Supreme Court of the State of Idaho reviewed the case and held that the district court erred by not applying the correct legal standard. The Supreme Court clarified that wrongful death damages are forward-looking and intended to compensate for the loss of future support, companionship, and other benefits the decedent would have provided. The court found that the district court improperly based its apportionment on the parents’ past conduct rather than their respective losses. The Supreme Court reversed the district court’s decision, vacated the judgment, and remanded the case for further proceedings consistent with its opinion. View "Rossman Law Group, PLLC v. Holcomb and Carraway" on Justia Law

PacifiCorp, a utility company operating a natural gas power plant in Chehalis, Washington, supplies electricity to customers in Idaho. Washington enacted the Climate Commitment Act (CCA), requiring greenhouse gas emitters to purchase emissions allowances. PacifiCorp sought to recover $2.3 million from Idaho customers, representing their share of the costs for these allowances needed to operate the Chehalis plant. The CCA provides “no-cost” allowances exclusively to Washington customers, shielding them from these costs, while PacifiCorp’s Idaho customers would bear the expense for electricity exported from Washington.The Idaho Public Utilities Commission reviewed PacifiCorp’s application under the Energy Cost Adjustment Mechanism (ECAM). The Commission approved recovery of over $60 million in other costs but denied the $2.3 million in CCA allowance costs. It reasoned that, under the 2020 PacifiCorp Inter-Jurisdictional Allocation Protocol, state-specific energy and climate policy costs should be borne by the state enacting them. The Commission also found that passing CCA costs to Idaho customers would violate Idaho Code section 61-502, which requires rates to be just, reasonable, and sufficient, and would create discriminatory customer classes. PacifiCorp’s petition for reconsideration was denied, with the Commission reaffirming its decision on both Protocol and statutory grounds.On appeal, the Supreme Court of the State of Idaho considered whether the Commission’s orders violated PacifiCorp’s constitutional rights, were unsupported by evidence, or were outside the regular pursuit of its authority. The Court held that the Commission acted within its statutory powers and that its decision to disallow recovery of CCA allowance costs from Idaho customers was supported by the record and consistent with its mandate under Idaho Code section 61-502. The Court affirmed the Commission’s orders. View "Pacificorp v. IPUC" on Justia Law

William Weeks was employed as an equipment operator for Oneida County’s Road and Bridge Department in Idaho. In September 2021, during a period of high COVID-19 transmission, Mr. Weeks continued working as required for critical infrastructure employees. He attended daily morning meetings with coworkers in a break room and often visited local stores. After a coworker became ill and missed work, Mr. Weeks developed COVID-19 symptoms, tested positive, and later died from complications. His wife, JaLyn Weeks, filed a worker’s compensation claim, alleging he contracted COVID-19 at work.The employer denied the claim, and Mrs. Weeks brought her case before the Idaho Industrial Commission. At the hearing, both parties presented expert testimony regarding the likely source and timing of Mr. Weeks’ infection. The Commission found the employer’s expert more persuasive, concluding that it was not possible to determine, by a preponderance of the evidence, that Mr. Weeks contracted COVID-19 at work rather than from other possible sources, such as visits to stores or contact with individuals outside of work. The Commission denied the claim for medical and death benefits.On appeal, the Supreme Court of the State of Idaho reviewed whether the Commission applied the correct legal standard and whether its findings were supported by substantial and competent evidence. The Court held that the Commission properly applied the preponderance of the evidence standard and did not err by refusing to resolve doubts in favor of compensability in occupational disease cases. The Court affirmed the Commission’s decision, holding that Mrs. Weeks failed to prove that Mr. Weeks actually incurred COVID-19 from his employment. The Court did not reach the issue of whether COVID-19 is a compensable occupational disease under Idaho law. View "Weeks v. Oneida County" on Justia Law

A police officer employed by the City of Boise suffered injuries during a traffic stop in 2019, including a right hip injury, which the employer accepted and compensated. Later, the officer developed left hip pain, and her physician initially stated it was unrelated to the work accident, but later opined it was likely related. Disputes arose over medical records and scheduling independent medical examinations (IMEs). The employer, relying on prior Idaho Supreme Court precedent, sent a letter purporting to suspend compensation when the officer did not attend an IME, though the Idaho Industrial Commission later found that no actual suspension occurred. The officer continued to receive salary and some benefits, while her left hip surgery was covered by private insurance.After the Idaho Supreme Court’s decision in Arreola v. Scentsy, Inc., which held only the Commission could order suspension of benefits for failure to attend an IME, the officer sought a declaratory ruling from the Commission regarding retroactive application of Arreola. While that petition was pending, the employer filed a complaint with the Commission to adjudicate issues about the officer’s entitlement to benefits and IME compliance. The officer then filed a second petition, arguing that only employees, not employers, could file such complaints under Idaho’s worker’s compensation law.The Idaho Industrial Commission denied both petitions. It found the first petition was moot because the officer’s benefits were never actually suspended and Arreola applied only prospectively. The Commission denied the second petition on the merits, holding it had jurisdiction to accept complaints from employers under Idaho Code section 72-707 and its own rules.On appeal, the Supreme Court of the State of Idaho affirmed the Commission’s denial of the first petition, finding no justiciable controversy. However, it set aside the denial of the second petition, holding that only employees may file complaints to request hearings on claims for compensation or income benefits under Idaho Code section 72-706, and the Commission exceeded its powers by allowing employer-initiated complaints in such matters. View "Coronado v. City of Boise" on Justia Law

After the death of Rolland Lane, the Lane Family Trust was divided into two sub-trusts, Trust A and Trust B, with Karla Lane serving as the sole trustee of Trust A and John Edwards, Scott Edwards, and Keith “KC” Lane as co-trustees of Trust B. The main asset of the trusts was a house and acreage in Caldwell, Idaho, owned equally by both trusts. Disputes arose over the sale of this property, with Karla seeking to sell it for no less than one million dollars, while the co-trustees of Trust B objected and pursued a different sale arrangement. After a cash offer of $1,350,000 was made, the district court ordered all trustees to accept the offer and close the sale by a specified date. Karla refused to comply, leading to further litigation.The District Court of the Third Judicial District of Idaho, Canyon County, ultimately removed Karla as trustee of Trust A, finding her refusal to follow the court’s order to sell the property constituted grounds for removal under Idaho law. The court appointed KC as the new trustee of Trust A. Karla appealed, arguing that her actions were within her discretionary authority as trustee and that she was acting in the best interests of the beneficiaries by seeking a higher sale price.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court’s order. The Supreme Court held that Karla had waived all arguments on appeal due to significant deficiencies in her briefing, including raising new arguments for the first time on appeal, failing to provide an adequate record, and not articulating how the district court abused its discretion. The Supreme Court also awarded attorney fees and costs to the respondents, finding the appeal to be frivolous. View "Edwards v. Lane" on Justia Law

Noah Gilbert purchased a motor vehicle insurance policy from Progressive Northwestern Insurance Company, initially declining underinsured motorist (UIM) coverage but later adding a UIM endorsement with $25,000 per person and $50,000 per accident limits. The policy included an offset provision, reducing any UIM payout by amounts received from another party’s insurance. Gilbert paid premiums for this coverage but never filed a UIM claim or experienced an accident triggering such coverage. He later filed a putative class action, alleging that Progressive’s UIM coverage was illusory under Idaho law and asserting claims for breach of contract, breach of the implied covenant of good faith and fair dealing, unjust enrichment, fraud, and constructive fraud.The District Court of the Fourth Judicial District, Ada County, reviewed cross-motions for summary judgment. The court raised the issue of standing and ultimately held that Gilbert lacked standing because he had not filed a claim or been denied coverage, and thus had not suffered an injury-in-fact. Alternatively, the court found that Gilbert’s claims failed on the merits: there was no breach of contract or bad faith without a denied claim, no damages to support fraud or constructive fraud, and unjust enrichment was unavailable due to the existence of a valid contract. The court granted summary judgment for Progressive and denied Gilbert’s motion for class certification as moot.On appeal, the Supreme Court of the State of Idaho held that Gilbert did have standing, as payment of premiums for allegedly illusory coverage constituted a concrete injury. However, the Court affirmed the district court’s judgment, finding that Gilbert’s claims failed on the merits because he never filed a claim, was never denied coverage, and did not incur damages. The Court also affirmed the dismissal of the unjust enrichment claim, as an enforceable contract provided an adequate legal remedy. The judgment in favor of Progressive was affirmed. View "Gilbert v. Progressive Northwestern Insurance Co." on Justia Law

The dispute arose over whether certain parcels of land owned by Vintage II, LLC and Christine Holding in Teton County, Idaho, were subject to covenants, conditions, and restrictions (CC&Rs) or other limitations associated with the adjacent Teton Saddleback Vistas Subdivision. The plaintiffs sought to quiet title, arguing their properties were not encumbered by three recorded CC&R instruments. The defendant homeowners association claimed the properties were subject to restrictions, including those set forth in a recorded Master Plan referenced in the plaintiffs’ deeds.The District Court of the Seventh Judicial District reviewed the case after a bench trial. It found that the CC&Rs did not encumber the subject properties due to deficiencies in their recording and description. However, the court concluded that the Master Plan, referenced in the plaintiffs’ deeds, did impose restrictions such as lot numbers, sizes, and open area requirements, and thus encumbered the properties. The court denied the plaintiffs’ request to quiet title, holding that the Master Plan created enforceable restrictions and a common law dedication of open space.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision to admit the Master Plan into evidence, finding it relevant because it was referenced in the deeds and material to the quiet title action. However, the Supreme Court reversed the district court’s conclusions that the Master Plan created restrictive covenants or a common law dedication. The Court held that the Master Plan did not clearly express any binding restrictions or dedication, and thus could not encumber the properties. The amended judgment was vacated, and the case was remanded for entry of judgment in favor of the appellant, Vintage II, LLC. The Court awarded costs to Vintage as the prevailing party. View "Vintage II, LLC v. Teton Saddleback" on Justia Law

A property owner along the shore of Priest Lake in Idaho sought a permit from the Idaho Department of Lands (IDL) for a submerged log structure, which he claimed had existed since the early 1960s. The structure, known as a log crib, was intended to prevent erosion and create a sandy beach. After initially applying for a permit to cover modifications made to the structure, including the addition of cobblestones and sandbags, the owner was denied due to lack of public benefit and evidence of modification. He then submitted a second application under Idaho Code section 58-1312, which allows permits for pre-1975 encroachments if the applicant provides documentation of the structure’s age and proof that it has not been modified since 1974.IDL denied the second application, finding insufficient evidence that the structure had not been modified since 1974, particularly since the owner admitted to adding and later removing materials. The owner appealed, and after a public hearing, the IDL Director issued a Final Order denying the permit, agreeing that while the structure predated 1974, it had been modified. The owner then sought judicial review in the District Court of the First Judicial District, Bonner County, arguing that IDL’s procedures violated his due process rights and that the agency erred in its interpretation of the law. The district court affirmed IDL’s decision, finding substantial evidence supported the denial and that due process was not violated.On further appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Court held that IDL properly denied the permit because the applicant failed to show the structure had not been modified since 1974, and that the agency was not required to follow procedures for new encroachments. The Court also found no due process violation and awarded attorney fees and costs to IDL. View "Wilson v. Idaho State Board of Land Commissioners" on Justia Law

A couple purchased a home from another couple, relying on representations made in a property condition disclosure form as required by Idaho law. After moving in, the buyers discovered significant defects in the home, including unpermitted additions and structural problems that were not disclosed. The buyers hired experts who confirmed that the attic and kitchen additions were structurally unsound and that required permits had not been obtained. The buyers filed suit three years after the sale, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, violation of the Idaho Property Condition Disclosure Act, and fraud.The case proceeded in the District Court of the Third Judicial District, Canyon County. A jury found in favor of the buyers on all claims except the implied covenant of good faith and fair dealing, awarding $63,024 in damages. After trial, the district court granted a directed verdict for the sellers on the Disclosure Act claim, finding it barred by a three-year statute of limitations, but denied the sellers’ motions on the fraud and contract claims. The court also denied the buyers’ request for attorney fees, reasoning they were not the prevailing party.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s denial of the sellers’ motions for directed verdict and judgment notwithstanding the verdict on the fraud claim, holding that the buyers’ fraud claim was not time-barred because they did not discover the fraud until after closing, and that substantial evidence supported the jury’s verdict. The Supreme Court reversed the district court’s dismissal of the Disclosure Act claim, holding that the claim accrued at closing, not upon delivery of the disclosure form, and thus was timely. The Court also held that the buyers were entitled to attorney fees under the purchase agreement and remanded for a determination of the amount. The buyers were awarded attorney fees and costs on appeal. View "VanRenselaar v. Batres" on Justia Law