Justia Idaho Supreme Court Opinion Summaries

A group of cities holding junior ground water rights in the Eastern Snake Plain Aquifer sought judicial review of a final order issued by the Director of the Idaho Department of Water Resources. This order updated the methodology used to assess whether pumping by junior ground water users caused material injury to senior surface water rights holders who divert water from the Snake River. The Director’s Fifth Amended Final Order revised technical aspects of the model and data, and after a hearing on objections by the cities, the Director affirmed the methodology with modifications and issued a Sixth Methodology Order, which expressly superseded all prior methodology orders.The cities filed a petition for judicial review in the Snake River Basin Adjudication district court, challenging the Director’s Post-Hearing Order regarding the Fifth Methodology Order. The district court affirmed the Director’s findings and conclusions, upholding the methodology and the application of the clear and convincing evidence standard, and found that the Director did not prejudice the cities’ substantial rights. The district court’s judgment specifically affirmed the Post-Hearing Order but did not address the operative Sixth Methodology Order.On appeal, the Supreme Court of the State of Idaho reviewed whether the cities had properly invoked its jurisdiction. The Court held that the cities failed to challenge the currently operative Sixth Methodology Order in district court, and therefore, under Idaho law, the Court lacked jurisdiction to consider the appeal or award the requested relief. As a result, the appeal was dismissed for lack of jurisdiction. The Court awarded attorney fees and costs to the Idaho Department of Water Resources but denied attorney fees to the intervening Surface Water Coalition, granting them costs only. View "City of Idaho Falls v. IDWR" on Justia Law

The claimant suffered a workplace injury while lifting a box, resulting in immediate neck and shoulder pain. She promptly sought medical treatment and was diagnosed with a shoulder strain, receiving temporary disability benefits and performing light duty work. Over time, her symptoms persisted and evolved, leading to various medical evaluations, including imaging studies and independent medical exams. Disagreement arose between medical providers regarding the nature and cause of her cervical spine abnormalities, with one provider opining that a herniated disc at C6-7 was caused by the accident and recommending surgery, while others attributed her symptoms to mild degenerative changes not caused by the workplace incident.After exhausting benefits and undergoing surgical procedures outside of the worker’s compensation system, the claimant filed a complaint with the Idaho Industrial Commission seeking additional medical and disability benefits, asserting that her cervical condition was work-related. Following a hearing, the Commission weighed conflicting medical expert testimony and found some inconsistencies and possible exaggeration in the claimant’s symptom reporting. Ultimately, the Commission determined that the claimant had proven a shoulder injury from the accident but failed to establish, to a reasonable degree of medical probability, that her herniated disc or cervical spine condition was caused by the workplace event.The Supreme Court of the State of Idaho reviewed the Commission’s decision. Applying the standard that factual findings by the Commission will not be disturbed unless clearly erroneous, and that legal conclusions are subject to free review, the Court found substantial and competent evidence supporting the Commission’s denial of additional benefits for the cervical spine condition. The Court affirmed the Commission’s decision and held that neither party was entitled to attorney fees on appeal. View "Proulx v. Saveway Market, Inc." on Justia Law

Joel Ward performed construction work for Bishop Construction, LLC and its sole member, Ren Bishop, in Idaho, Montana, and Wyoming, with an agreed hourly wage and travel compensation. Despite keeping detailed records of his hours, Ward was not paid for work completed between 2017 and 2019, leading him to pursue payment through legal action. The dispute centered on whether Ward should be classified as an employee or an independent contractor and whether he was required to register as a contractor under Idaho law.The case was first heard in the District Court of the Seventh Judicial District of Idaho, Bonneville County. After a bench trial, and based on the parties’ stipulation that Ward was an independent contractor, the court dismissed his wage claims, leaving only breach of contract and unjust enrichment claims. The district court initially awarded Ward full damages for breach of contract. However, after Bishop raised the issue of contractor registration under the Idaho Contractor Registration Act (ICRA) in post-trial motions, the court amended its findings, limited contract damages to out-of-state work, awarded unjust enrichment damages for Idaho work, and granted costs and attorney fees.On appeal, the Supreme Court of the State of Idaho reviewed whether Ward was required to register as a contractor under ICRA and whether the contract was illegal. The Court held that Bishop failed to meet his burden to prove Ward was required to register under ICRA, as the record did not establish Ward’s status as a contractor for those purposes. The Supreme Court vacated the district court’s amended judgment and remanded with instructions to reinstate its original findings and amended judgment, including the previously awarded attorney fees and costs. The Court also awarded Ward attorney fees and costs on appeal as the prevailing party. View "Ward v. Bishop Construction" on Justia Law

Two siblings, Ryan and Nancy, disputed the administration of their father Hal’s estate and the status of his ownership interest in Tautphaus Park Storage, LLC (TPS), an Idaho storage facility business. Hal, who suffered from progressive dementia before his death, was TPS’s sole voting member and manager, with Nancy assisting in legal and management matters. Several amendments to TPS’s operating agreement changed ownership and management, culminating—after Hal’s death—in Nancy executing further amendments that retroactively transferred Hal’s economic interest to herself and changed accounting records. Nancy, an attorney, served as both Hal’s lawyer and later as personal representative of his estate. Ryan questioned whether Hal’s interest in TPS remained an estate asset and sought access to business records, which Nancy resisted.The siblings litigated issues in two related cases in Bonneville County: a probate case in the Magistrate Court regarding Hal’s estate, and a separate TEDRA (Trust and Estate Dispute Resolution Act) civil action in District Court initiated by Ryan. Both courts and parties at times treated the cases as consolidated. Ryan’s TEDRA complaint sought judicial determination of estate assets, breach of fiduciary duty, fraud, and appointment of a receiver, naming Nancy in both her individual and representative capacities and TPS as defendants. The magistrate court dismissed Ryan’s claims and removed Nancy and TPS as parties, finding that estate matters should be decided exclusively in probate. The district court affirmed, denying Ryan’s motions and dismissing his amended complaint, reasoning that Ryan’s claims were matters for probate only.On appeal, the Supreme Court of the State of Idaho vacated both lower courts’ judgments. It held that Ryan’s claims for judicial determination of estate assets and breach of fiduciary duty fall within TEDRA’s definition of “matters” and may be raised in a separate civil action, not only in probate. The Court reversed the orders dismissing claims and parties, remanded the case for further proceedings, and awarded costs and reasonable attorney fees to Ryan against Nancy personally. View "Monson v. Monson" on Justia Law

Two couples entered into a written agreement for the sale and purchase of a condominium in Idaho, using a standard real estate contract form. The property was identified by its street address, unit number, and condominium name. After agreeing to terms and signing the contract, the sellers informed the buyers that they no longer wished to sell. The buyers, who had already paid earnest money, secured financing, and prepared for closing, sought to enforce the agreement. The sellers refused to proceed, claiming the contract was unenforceable due to an inadequate property description under the statute of frauds and asserting the parties had mutually rescinded the agreement.The case was first heard in the District Court of the First Judicial District, Bonner County. The court denied both parties’ motions for summary judgment on the statute of frauds and specific performance, finding factual disputes. After a bench trial, the district court ruled that the property description in the contract was sufficient to satisfy the statute of frauds. At a subsequent jury trial, the jury found that the contract was valid, had not been rescinded or abandoned, and that the sellers breached it, awarding the buyers damages. The district court, however, granted the sellers’ motion for partial summary judgment, finding the remedy of specific performance unavailable because the buyers had not tendered the full purchase price at closing.On appeal, the Supreme Court of the State of Idaho affirmed that the contract’s property description satisfied statutory requirements and thus dismissed the sellers’ statute of frauds defense. The court held that the district court erred in denying specific performance solely for failure to tender the full purchase price, especially since the sellers’ conduct prevented completion. The Idaho Supreme Court reversed the denial of specific performance and remanded for the district court to consider equitable factors. The court also affirmed the award of attorney fees to the buyers and awarded them costs and fees on appeal. View "McLaughlin v. Moore" on Justia Law

The case arises from a procurement process initiated by Idaho’s Division of Purchasing to select a contractor to provide behavioral health and substance abuse services for the Idaho Department of Health and Welfare. Carelon Behavioral Health, Inc. was initially selected as the winning bidder. However, the other two bidders, Magellan Healthcare and United Behavioral Health (Optum), challenged Carelon’s eligibility, arguing that Carelon had previously been paid by the State for services used to prepare the specifications of the contract, which would bar it from bidding under Idaho Code section 67-9230(8). A determinations officer reviewed the matter and found that Carelon's prior work did influence the contract specifications, rendering it ineligible. The Director of Administration adopted this recommendation, rescinded the intent to award the contract to Carelon, and ultimately awarded it to Magellan.Following this, Carelon filed a complaint in the District Court of the Fourth Judicial District seeking declaratory relief and a writ of mandate to overturn the Director’s decision and reinstate its bid. The district court dismissed the complaint for lack of subject matter jurisdiction, reasoning that Carelon’s claims were, in substance, a request for judicial review of the Director’s procurement decision, which is expressly precluded by the State Procurement Act unless the case arises from a contested case hearing. The court also rejected Carelon’s claims for a writ of mandate and its constitutional challenges to the statute.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s dismissal. The Court held that the State Procurement Act prohibits judicial review of procurement decisions made outside of contested case hearings and that Carelon’s claims could not be recast as an original declaratory judgment action to circumvent this limitation. The Court also found that the statutory bar on judicial review does not violate the separation of powers under the Idaho Constitution and that section 67-9230(8) is not unconstitutionally vague as applied to Carelon. View "Carelon Behavioral Health, Inc. v. State" on Justia Law

A police officer employed by a city suffered injuries during a traffic stop in May 2019. The city, acting as a self-insured employer through a third-party administrator, initially accepted liability for a right hip injury, providing compensation and full salary. Subsequently, the officer developed left hip symptoms, and medical opinions varied on whether these were related to the workplace accident. The employer questioned the connection, declined to authorize further treatment for the left hip, and requested access to medical records and an independent medical examination (IME). After the officer did not cooperate with these requests, the employer sent a letter stating that compensation benefits would be suspended, although the Idaho Industrial Commission later found that no actual suspension occurred.The officer later filed a petition with the Idaho Industrial Commission seeking a declaratory ruling on whether a recent Idaho Supreme Court decision (Arreola v. Scentsy, Inc.) applied retroactively to her situation, which would have affected the employer’s ability to suspend benefits unilaterally. While this petition was pending, the employer filed a complaint with the Commission to resolve disputes about the officer’s entitlement to benefits and failure to attend IMEs. The officer responded with a second petition, challenging the employer’s ability to file such a complaint. The Commission declined to address the first petition on procedural grounds and denied the second on the merits, concluding that it had jurisdiction to adjudicate an employer’s complaint.On appeal, the Supreme Court of the State of Idaho affirmed the Commission’s denial of the first petition, finding the issue moot because the officer’s benefits had not been suspended and thus there was no live controversy. However, the Court set aside the denial of the second petition, holding that under Idaho’s worker’s compensation law, only employees—not employers—may file a complaint (application for hearing) with the Commission to adjudicate claims regarding unpaid or discontinued compensation or income benefits. View "Coronado v. City of Boise" on Justia Law

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