Justia Idaho Supreme Court Opinion Summaries

A property owner in Idaho allowed her adult grandson, who suffered from severe mental illness and a history of violent behavior, to reside on her rural property. She periodically employed a caretaker to perform maintenance, but did not supervise his work or control his schedule. In September 2021, the grandson killed and mutilated the caretaker, perceiving him as a trespasser. The grandson pleaded guilty to second-degree murder and was sentenced to life in prison. The caretaker’s family sued the property owner and her limited liability company, seeking to hold them liable for wrongful death, intentional infliction of emotional distress (IIED), and negligent infliction of emotional distress (NIED).The District Court of the First Judicial District, Bonner County, granted summary judgment in favor of the property owner and the LLC. The court found no duty to protect the caretaker under either a special relationship or an assumed duty theory, and rejected the emotional distress claims, holding the alleged conduct was not extreme or outrageous and that no duty was owed to the heirs. The claims against other defendants were dismissed for lack of personal jurisdiction, and the plaintiffs did not appeal the dismissal of the premises liability claim or claims against one family member.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Supreme Court held that the property owner’s employment relationship with the caretaker did not create a special relationship imposing a duty to protect him from the grandson, nor did her limited attempts to mediate disputes constitute a voluntarily assumed duty. The Court also concluded that the IIED and NIED claims failed as a matter of law because the owner’s conduct was neither extreme nor outrageous, and she owed no legal duty to the heirs. The Supreme Court awarded partial attorney fees to the owner, finding the IIED and NIED appeals were frivolously pursued. View "Spears v. Antelope Mountain Resort, LLC" on Justia Law

A group of cities in Idaho, each holding junior ground water rights within the Eastern Snake Plain Aquifer, became subject to curtailment proceedings initiated by senior surface water users represented by the Surface Water Coalition. The Coalition argued that pumping by junior ground water rights holders diminished water available to senior rights holders drawing from the Snake River. In response, the Director of the Idaho Department of Water Resources has periodically updated the methodology used to determine whether material injury to the senior rights has occurred, issuing a series of orders—the most recent being a Sixth Methodology Order.Following the issuance of a Fifth Methodology Order and an associated Post-Hearing Order, the cities challenged those orders in the Snake River Basin Adjudication district court, raising several concerns about the Director’s factual determinations and legal standards. During the administrative process, the Director simultaneously issued a Sixth Methodology Order that expressly superseded all prior methodology orders. The cities, however, did not include a direct challenge to the Sixth Methodology Order in their petition for judicial review. The district court affirmed the Director’s Post-Hearing Order, supporting the agency’s methodology and factual findings.The Supreme Court of the State of Idaho held that it lacked jurisdiction to consider the appeal because the cities failed to petition for review of the operative Sixth Methodology Order in the district court, as required under Idaho administrative law. As a result, the Supreme Court dismissed the appeal for lack of jurisdiction and declined to address the substantive claims raised by the cities. The court also denied requests for attorney fees under Idaho Code section 12-117(1), finding the statute inapplicable, but awarded costs to the prevailing parties. View "City of Idaho Falls v. Idaho Department of Water Resources" on Justia Law

Three sisters, along with their father, were involved in a family farming and ranching business organized as a limited partnership. Over several years, the father gradually transferred assets and control to one sister and her husband, the Oxarangos, making them general partners and granting them increased ownership through discounted purchases and option agreements. The Oxarangos subsequently acquired various properties and shares from the father, including grazing land and a parcel known as the Roseberry Property. Two of the sisters, Hyde and Reaney, who remained limited partners, sued the Oxarangos alleging breach of fiduciary duty, wrongful acquisition of partnership opportunities, and sought their expulsion as general partners.The Third Judicial District Court, Gem County, reviewed the claims. It dismissed allegations related to earlier asset transfers, finding them barred by the statute of limitations. Regarding the Roseberry Property acquisition, the court determined Hyde and Reaney failed to show injury sufficient for standing in either a direct or derivative capacity. The court concluded the transactions involved personal property transfers among general partners and were not outside the partnership’s business purpose. Additionally, the court found the complaint did not adequately plead demand futility or particularized facts required for a derivative action under Idaho law. The expulsion claim was also dismissed for lack of sufficient factual allegations.The Supreme Court of the State of Idaho affirmed the district court’s dismissal. It held that Hyde and Reaney lacked standing to bring both direct and derivative claims because they did not plead an injury independent of harm suffered by the partnership and failed to meet statutory requirements for derivative suits, including particularized allegations of demand futility. The court also affirmed dismissal of the expulsion claim, finding Hyde and Reaney did not allege a distinct injury or wrongful conduct sufficient for judicial expulsion under the relevant statute. Costs and attorney fees were awarded to the Oxarangos. View "Hyde v. Oxarango" on Justia Law

Two individuals, who were in a long-term romantic relationship but never married, jointly purchased a piece of real property in Idaho. Both names were listed on the purchase and sale agreement and the warranty deed, but there was no specification of their respective ownership interests. After their relationship ended, one party attempted to transfer her interest in the property to a nonprofit and then reacquired it. The other party, who had paid all taxes, utilities, and expenses for the property, sought to quiet title in his name or, alternatively, to partition the property in kind, awarding him the entirety. The parties disputed whether ownership was equal or if one party had sole ownership.The District Court of the Seventh Judicial District, Bonneville County, initially denied both parties’ cross-motions for summary judgment, finding genuine disputes of material fact regarding ownership interests. After the Idaho Supreme Court issued Demoney-Hendrickson v. Larsen, which established a rebuttable presumption of equal ownership when a deed lists two names without specifying interests, the district court granted summary judgment to the defendant, concluding she had a 50% interest and ordering partition by sale. The court also determined the plaintiff had waived any claim for contribution because he had not pleaded it and awarded attorney fees to the defendant under Idaho Code section 12-121.The Supreme Court of the State of Idaho reviewed the case. It held that the district court erred in granting summary judgment to the defendant on the partition claim. The Supreme Court clarified that the plaintiff had provided sufficient evidence to establish a genuine dispute of material fact regarding the parties’ intent about their ownership shares, which should have precluded summary judgment. The court also clarified that a co-tenant listed on a deed can possess a 0% ownership interest, contrary to the district court’s conclusion. However, the Supreme Court affirmed the district court’s determination that the plaintiff had waived any claim for contribution. The Supreme Court reversed the grant of summary judgment on ownership, the denial of reconsideration, and the award of attorney fees, remanding for further proceedings. View "Bedell v. Parsons" on Justia Law

A group of residents and an association challenged actions taken by the Harris Ranch Community Infrastructure District No. 1 (CID) in Boise, Idaho. The dispute arose after the CID’s board adopted resolutions in 2021 authorizing payments to a developer for infrastructure projects—such as roadways, sidewalks, and stormwater facilities—and issued a general obligation bond to finance those payments. The residents objected to the projects, arguing they primarily benefited the developer, imposed higher property taxes on homeowners, and allegedly violated the Idaho Community Infrastructure District Act (CID Act) as well as state and federal constitutional provisions. Previously, the District Court of the Fourth Judicial District reviewed the matter after the residents filed a petition challenging the board’s decisions. The district court ruled in favor of the CID and the developer, concluding most of the residents’ claims were either time-barred under the CID Act’s statute of limitations or had been waived because they were not preserved before the CID board. The court also found that the remaining claims failed on their merits, holding that the challenged projects qualified as “community infrastructure,” the stormwater facilities satisfied ownership requirements, and the CID was not the alter ego of the City of Boise. On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Supreme Court clarified that, given the lack of formal administrative proceedings under the CID Act, the preservation doctrine did not apply to bar the residents’ arguments. Nonetheless, the Supreme Court held that any challenge to the CID’s original formation and the 2010 bond election was time-barred. The court further held that the roadways and stormwater facilities qualified as community infrastructure, the CID’s actions did not violate constitutional requirements regarding taxation or lending of credit, and the CID was not the alter ego of the city. The Supreme Court awarded costs on appeal to the CID and the developer but denied attorney fees to all parties. View "Doyle v. The Harris Ranch Community Infrastructure District No. 1" on Justia Law

A healthcare provider and several of its employees became involved in a dispute after the Idaho Department of Health and Welfare took protective custody of a child suffering from severe malnutrition. Following the hospital’s treatment of the child, a relative of the child, using media platforms and political organizations, publicly accused the hospital and its staff of participating in a conspiracy to kidnap, traffic, and harm children. These accusations led to public protests, threats, and disruptions at the hospital. The healthcare provider and its employees then sued the relative, his associates, and affiliated entities, alleging defamation, invasion of privacy, intentional infliction of emotional distress, trespass, and civil conspiracy, among other claims. They sought compensatory and punitive damages, injunctive relief, and removal of false statements.During proceedings in the District Court of the Fourth Judicial District, the defendant repeatedly failed to comply with discovery orders, missed depositions, and did not attend court hearings, despite multiple warnings and opportunities to comply. The court imposed escalating sanctions, culminating in striking the defendant’s pleadings and entering default as to liability. The court held a jury trial solely on damages, at which the defendant did not appear in person despite being given the opportunity. The jury awarded $52.5 million in compensatory and punitive damages, and the court issued a permanent injunction preventing further defamatory statements or harassment.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in imposing sanctions, entering default, and excluding evidence not properly disclosed. The court found that the defendant’s due process rights were not violated given repeated, willful noncompliance with court orders. The Supreme Court affirmed the district court’s judgment, including the damages award and the injunction, and awarded attorney fees and costs on appeal to the respondents. View "St. Luke's Health System, LTD v. Rodriguez" on Justia Law

Morgan Lohman purchased a 25.8-acre property, knowing that a homeowners’ association, Cave Bay Community Services, Inc., held a permanent easement on 7.31 acres and had an option agreement with the sellers, the Drehers, to purchase the easement land for one dollar once the Drehers’ loans were paid off. Despite concerns about the effect of this option on the value and use of his property, Lohman proceeded with the purchase. After the sale, the Drehers paid off their loans, and Cave Bay exercised its option to buy the easement property for one dollar, which Lohman refused to honor.Cave Bay filed suit against Lohman in the District Court of the First Judicial District of Idaho, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and seeking specific performance of the option agreement. Cave Bay moved for summary judgment only as to the specific performance “claim.” The district court granted summary judgment to Cave Bay on that basis, struck much of Lohman’s opposing declaration, and awarded Cave Bay attorney fees and costs. The court did not address the merits of the underlying breach of contract claim. After the parties dismissed the remaining claims, Lohman appealed.The Supreme Court of the State of Idaho reviewed the case and held that specific performance is a remedy, not a stand-alone cause of action. The court concluded that the district court erred by granting summary judgment on specific performance without first determining liability on the underlying breach of contract claim. The Supreme Court vacated the district court’s amended judgment, reversed the summary judgment ruling, and remanded the case for further proceedings. The court also vacated the award of attorney fees and costs, but awarded appellate costs to Lohman. No attorney fees were awarded on appeal as there was no prevailing party at this stage. View "Cave Bay Community Services v. Lohman" on Justia Law

The dispute centers on two neighboring property owners at Priest Lake, Idaho, whose properties are subject to several easements, and who have a history of disagreements concerning the use of a shared beach, lake access, and parking. The parties previously reached a court-mediated settlement agreement addressing these issues, which included a provision for future mediation and arbitration of disputes. Disagreements soon arose, particularly over the construction of a patio by one owner, leading the parties to arbitration as provided by their agreement. The arbitrator, after considering substantial evidence and briefing, ruled in favor of one party on all contested issues, including the patio’s location and construction, the use of easements, and parking arrangements.Prior to this appeal, the District Court of the First Judicial District, Bonner County, reviewed a motion to vacate the arbitration award. The moving party argued that the arbitrator exceeded his authority and was biased, primarily because the award was unfavorable and allegedly altered the terms of the court-approved settlement agreement. After considering the arguments, the district court denied the motion, finding that the arbitrator had acted within the scope of his authority and that no evidence of bias was presented.Upon review, the Supreme Court of the State of Idaho affirmed the district court’s decision. The court held that under Idaho’s Uniform Arbitration Act, judicial review of arbitration awards is extremely limited and does not allow for overturning an award simply due to alleged errors in law or fact, or because the outcome was unfavorable. The court found no evidence that the arbitrator exceeded his authority or acted with bias. Additionally, the court awarded attorney fees on appeal to the prevailing party under Idaho Code section 12-121, concluding the appeal was frivolous and without foundation. The district court’s denial of the motion to vacate was affirmed. View "Khalsa v. Ridnour" on Justia Law

A nonprofit organization, operating a camp for children with cancer, owned several buildings situated on land owned by a married couple. The couple, both involved in the nonprofit’s leadership, decided to sell the ranch property that included the camp’s buildings. During negotiations, the couple represented to the nonprofit’s board that appraisals did not specify values for the nonprofit's buildings and that the nonprofit’s share of sale proceeds should be calculated by square footage. Relying on these representations, the nonprofit accepted a portion of the sale proceeds. Subsequently, the nonprofit discovered that the appraisals had, in fact, assigned higher specific values to its buildings, resulting in a claim for damages against the couple for misrepresentation, breach of fiduciary duty, and unjust enrichment.The District Court of the Seventh Judicial District granted partial summary judgment to the couple on certain claims, but, after a bench trial, found in favor of the nonprofit on claims for constructive fraud, breach of fiduciary duty, and unjust enrichment. The court calculated the nonprofit’s damages but reduced the award by 50%, applying comparative negligence and the doctrine of avoidable consequences. The court denied attorney fees and prejudgment interest to both parties. Both sides appealed.The Supreme Court of the State of Idaho held that the doctrine of election of remedies did not bar the nonprofit’s appeal, as seeking satisfaction of a judgment is not inconsistent with seeking a greater award on appeal. The Court ruled that it was reversible error for the district court to reduce damages based on comparative negligence or a duty to mitigate, as those doctrines did not apply to the equitable and fiduciary claims at issue. The Court affirmed the district court’s rejection of the couple’s affirmative defenses of superseding intervening cause and unclean hands, as well as the finding that the wife breached her fiduciary duty. The denial of prejudgment interest and attorney fees was affirmed, but the nonprofit was awarded costs on appeal. The case was remanded for entry of judgment in the nonprofit’s favor for the full damages amount and reconsideration of prevailing party status. View "Camp Magical Moments, Cancer Camp for Kids, Inc. v. Walsh" on Justia Law

Several organizations and individuals petitioned to prevent the Idaho State Tax Commission from implementing a newly enacted parental choice tax credit. This tax credit, established in 2025, provides refundable credits to parents, guardians, and foster parents for certain private educational expenses, including private school tuition and related services, for dependent students not enrolled in public schools. The law caps total annual credits and includes prioritization based on income and previous participation. The petitioners, including advocacy groups, a school district, and parents, argued that the statute creates a separate, non-public education system funded by public resources, allegedly violating the Idaho Constitution’s mandate for a single, general, uniform, and thorough system of public schools. They also claimed the statute failed the “public purpose doctrine,” asserting it primarily benefits private rather than public interests.Before the Idaho Supreme Court, the petitioners sought a writ of prohibition, which would prevent the Tax Commission from carrying out the law. The respondents, including the State and the Idaho Legislature, contested the petitioners’ standing and the merits of the constitutional claims. The Supreme Court determined that the petitioners lacked traditional standing but, given the urgency and importance of the constitutional question and the absence of another suitable challenger, relaxed standing requirements to address the merits.The Supreme Court of Idaho denied the petition. It held that Article IX, section 1 of the Idaho Constitution does not restrict the legislature from enacting educational measures beyond the required public school system, so long as the public system remains intact and constitutionally sufficient. The Court also found that the tax credit serves a legitimate public purpose—supporting parental choice in education—even if private entities benefit. The petition was dismissed, and the Tax Commission was awarded attorney fees and costs. View "Committee to Protect and Preserve v. State" on Justia Law