Justia Idaho Supreme Court Opinion Summaries

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

Several descendants and heirs of Edith Little each own separate parcels of real property in Teton County, Idaho, which were divided and conveyed to Edith’s three children after dissolution of a family partnership in 1993. The deeds for these parcels included restrictive language limiting the owners’ ability to sell, trade, convey, or encumber the properties during their lifetimes or the lifetimes of their living heirs, except that conveyances were allowed only to their siblings, nephews, and nieces—not to their own spouses, children, or grandchildren. Despite the restrictions, over the years, owners conveyed their parcels to spouses and lineal descendants.Plaintiffs, who are current owners of two of the parcels, brought suit in the Seventh Judicial District Court of Teton County seeking to quiet title and obtain a declaratory judgment that the deed restrictions were unreasonable restraints on alienation and void as against public policy. The defendants, also family members, argued the restrictions were enforceable. The district court granted summary judgment for the defendants, concluding the Idaho statutes had abrogated the common law rule against unreasonable restraints on alienation and upholding the restrictions.On appeal, the Supreme Court of the State of Idaho reviewed the district court’s decision de novo. The Idaho Supreme Court held that the common law rule against unreasonable restraints on alienation remains in effect in Idaho and was not abrogated by Idaho Code sections 55-111 or 55-111A. The Court further determined that the restrictions in these deeds are unreasonable because they do not effectively preserve the properties within the immediate family and unduly hinder the owners’ ability to use or benefit from their land. The Supreme Court vacated the district court’s judgment, reversed its summary judgment order, and remanded the case for further proceedings. Costs were awarded to the plaintiffs as the prevailing party. View "Smallwood v. Little" on Justia Law

Taylor L. Wood, her husband, and her son received medical care from physicians employed by Intermountain Emergency Physicians, PLLC (IEP). The resulting medical debt was assigned to Medical Recovery Services, LLC (MRS) for collection. After Wood’s attorneys alleged violations of state law, the Woods and IEP entered into a settlement that discharged the debt and provided payment to the Woods. Nevertheless, MRS later sued Wood to collect the same debt. Wood responded by counterclaiming and bringing IEP into the case as a third-party defendant, relying on the settlement agreement. MRS dismissed its complaint upon learning of the prior settlement, and all claims were eventually dismissed by the court.After judgment was entered, both sides sought a determination of the prevailing party and an award of attorney fees. The District Court of the Seventh Judicial District, Bingham County, found that Wood was the prevailing party over MRS and ordered MRS to pay Wood’s costs and attorney fees, concluding that MRS’s complaint was frivolous due to lack of proper investigation and communication regarding the settlement. MRS and IEP filed a first motion for reconsideration of the fees order, which was denied. They then filed a second motion for reconsideration, also denied, and subsequently appealed.The Supreme Court of the State of Idaho reviewed the case. It held that it lacked jurisdiction to review the district court’s order awarding costs and attorney fees to Wood because MRS and IEP’s notice of appeal from that order was untimely under Idaho Appellate Rule 14(a). The court did have jurisdiction to review the denial of the second motion for reconsideration, but because MRS and IEP failed to provide argument or authority on that issue, they waived it. The Supreme Court affirmed the district court’s denial of the second motion for reconsideration. View "Medical Recovery Services, LLC v. Wood" on Justia Law

The case centers on a dispute between a former employee and his employer regarding an alleged agreement to transfer company stock. The plaintiff, who had worked for the employer for many years and was promoted several times, claimed that he was promised a portion of stock if he remained employed through a specific date. This promise was allegedly memorialized in a 2018 letter from one of the company’s owners. After the plaintiff fulfilled his employment commitment but did not receive the stock, he sued the company and several individuals for promissory estoppel, fraud, and breach of contract.Previously, the District Court of the Fourth Judicial District, Ada County, reviewed the case. The court granted summary judgment to two individual defendants, dismissing them from the suit. The plaintiff’s claims against the remaining defendants proceeded to a bench trial. After trial, the district court found in favor of the company and its owner on all counts, concluding there was no enforceable contract due to the absence of an essential term—price—and insufficient evidence of fraud. The court also awarded attorney fees to both the company and the owner.The Supreme Court of the State of Idaho affirmed the district court’s dismissal of the breach of contract and fraud claims, agreeing that the 2018 letter did not create an enforceable contract and that there was no clear and convincing evidence of fraud. The Supreme Court also affirmed the award of attorney fees to the owner but vacated the fee award to the company, finding the company’s initial fee request procedurally deficient. The case was remanded for entry of an amended judgment consistent with these findings. Attorney fees and costs on appeal were awarded to the owner, but not to the company. View "York v. Kemper Northwest, Inc." on Justia Law

The case concerns a challenge to the rezoning of 145 acres of farmland in Canyon County, Idaho for light industrial use. The property owners, the Judith A. Gross Trust and Douglas Gross, sought the rezoning to facilitate future industrial development. The Canyon County Development Services Department and Planning and Zoning Commission recommended approval, and the Canyon County Board of County Commissioners ultimately approved the rezoning with conditions, including restrictions on certain uses. Three local businessmen and their agricultural business objected, arguing the rezoning would harm their agribusiness interests by reducing available farmland and impacting crop isolation.After the Board declined to reconsider its approval, the petitioners filed for judicial review in the District Court of the Third Judicial District of Idaho, Canyon County. They claimed standing as “affected persons” under the Local Land Use Planning Act (LLUPA), asserting concrete adverse impacts on their businesses. The district court dismissed the petition, holding that the petitioners failed to establish “constitutional” standing under the traditional three-part test—injury in fact, causation, and redressability—and declined to consider whether the petitioners met LLUPA’s “affected person” standard.The Supreme Court of the State of Idaho reviewed the district court’s decision. It held that the applicable standing inquiry for judicial review under LLUPA is the “affected person” standard set forth in Idaho Code section 67-6521, rather than the traditional federal three-part test. The Court clarified that Idaho’s standing doctrine is a “self-imposed constraint” and subject to legislative definition. The Supreme Court reversed the district court’s denial of the petition for review and remanded for consideration of standing under the LLUPA standard. Attorney fees were denied, but costs were awarded to the petitioners. View "Crookham v. County of Canyon" on Justia Law

Elizabeth Corey Raber and Michael Robert Raber married in Texas and later moved to Idaho, where their only child was born. After marital difficulties, Mother filed for divorce in Idaho in 2022. Initially, Child lived with Mother in Coeur d’Alene, while Father had weekend visitation. Mother resumed part-time legal work and began traveling with Child to Texas. A temporary custody schedule was modified in June 2023 to a week-on/week-off rotation, resulting in Child regularly traveling between Idaho and Texas. Following an evaluation by a psychologist recommending Mother be allowed to relocate to Texas with primary custody, the magistrate court proposed two alternative custody schedules depending on Mother’s residence, ultimately finalizing custody without articulating a best-interests-of-the-child analysis.On appeal, the Supreme Court of Idaho previously vacated the magistrate court’s judgment and remanded the case for further proceedings, instructing the magistrate court to exercise discretion regarding the scope of proceedings. On remand, Judge Anna Eckhart declined to consider new evidence or hold a new trial, instead relying on previous records and issuing findings that prioritized Child’s remaining in Idaho and continuing a week-on/week-off schedule if Mother returned to Idaho. If Mother remained in Texas, the court applied the psychologist’s recommended visitation schedule for Father, granting Mother one long weekend per month. Judge Katherine Murdock later entered judgment memorializing this custody and child support order after Judge Eckhart’s retirement. Mother appealed, challenging the custody determination and child support calculation.Reviewing the case, the Supreme Court of Idaho found the magistrate court abused its discretion by relying on a clearly erroneous factual finding regarding Child’s residence and by conducting an incomplete best-interests-of-the-child analysis. The court also found error in the child support calculation and its lack of supporting analysis. Thus, the Supreme Court of Idaho vacated the judgment and remanded for a new trial before a different magistrate judge, instructing the court to consider all relevant evidence and properly analyze the child’s best interests. View "Raber v. Raber" on Justia Law