Justia Idaho Supreme Court Opinion Summaries

Articles Posted in Idaho Supreme Court - Civil

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This case arose from the division of a three-member accounting firm, Siddoway, Wadsworth & Reese, PLLC. The three members of the firm were the personal professional corporations solely owned by each accountant. In early 2015, Reese PC signed a purchase agreement to buy a one-half interest in the client base of Siddoway PC for $200,000. This purchase agreement included an arbitration clause. In August of 2015, Siddoway left the accounting firm, taking several employees and the clients’ information with him. Following Siddoway’s departure, the firm (now named Wadsworth Reese, PLLC), along with its remaining members, filed a complaint in the district court against Siddoway and his personal professional corporation and two of the employees who followed him. Siddoway counterclaimed. The parties brought a range of claims. Reese PC and Siddoway PC also went to arbitration for claims related to their purchase agreement, but the arbitrator determined the purchase agreement was void for failure of a condition subsequent. The remaining claims between the parties were tried by the district court. The district court ultimately decided to “leave the parties where it found them.” This included final determinations pertinent to this appeal: (1) dissociation of Siddoway’s personal professional corporation as a firm member; (2) Siddoway and Siddoway PC were not entitled to attorney fees for compelling arbitration; (3) Siddoway PC failed to show unjust enrichment from the void purchase agreement; and (4) the firm could fund Reese’s personal professional corporation’s litigation and arbitration costs because resolving the purchase-agreement dispute served a legitimate business purpose. Siddoway and Siddoway PC appealed. The Idaho Supreme Court affirmed the district court’s judgment: Siddoway and Siddoway PC were not entitled to attorney fees for compelling arbitration, nor did they show unjust enrichment or breach of membership duties. View "Wadsworth Reese v. Siddoway & Co" on Justia Law

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Mario Ayala was injured while driving a company truck in 2009, and was injured again in 2013 after falling from a ladder. After the hearing, but before the referee issued “recommended findings and determination” in accordance with Idaho Code section 72-717, the Industrial Commission reassigned the case to itself over Ayala’s objection. Citing the referee’s backlog of cases and a need for efficiency, the Industrial Commission issued an order finding that Ayala’s low-back condition was not causally related to his 2009 truck wreck, that he was not totally and permanently disabled under the odd-lot worker doctrine, and that he suffered disability of 40% of the whole person inclusive of impairment of his 2009 and 2013 industrial accidents. The Idaho Supreme Court set aside the Commission’s findings of fact, conclusions of law and order because Ayala was denied due process when the Industrial Commission reviewed Ayala’s claims and issued a decision without the referee’s recommended findings and determination. The Court also set aside the Industrial Commission’s post-hearing order on motion for reconsideration and order on motion for reconsideration, modification and consolidation, and remanded this matter for a new hearing. View "Ayala v. Meyers Farms" on Justia Law

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Jun Yu appealed the dismissal of his claims for alleged violations of 42 U.S.C. section 1983 and breach of contract. Idaho State University dismissed Yu from its doctoral program in clinical psychology in May 2013, with his final administrative appeal denied on October 2, 2013. Yu, a citizen of the People’s Republic of China, was completing his Ph.D. in clinical psychology at Idaho State University. He completed all the requisite coursework, wrote and defended his dissertation, but still had to complete a one-year clinical internship. After not matching any programs with the Association of Psychology Postdoctoral and Internship Centers, Yu set up an alternative internship with the Cleveland Clinic Center for Autism in Ohio. However, he was dismissed from the Ohio internship early due to performance concerns and subsequently dismissed from Idaho State University’s doctoral program. After exhausting his appeals with the university, Yu received a final letter on October 2 that denied his appeal and immediately made his dismissal effective. In March 2014, Yu filed a notice of tort claim against ISU pursuant to the Idaho Tort Claims Act (ITCA), alleging negligent infliction of emotional distress and a violation of Title VI of the 1964 Civil Right Act. Eighteen months later he filed a lawsuit in the U.S. District Court for the District of Idaho alleging violations of Title VI of the Civil Rights Act, deprivation of constitutional rights under 42 U.S.C. section 1983, and negligent infliction of emotional distress. Yu later amended his complaint to include allegations of denial of procedural and substantive due process, promissory estoppel, and breach of contract, totaling 18 claims against ISU. No individual defendants were named in the notice of claim or in his federal action. The Idaho Supreme Court affirmed the district court’s dismissal of Yu’s claims because they were untimely. View "Yu v. ID State University" on Justia Law

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Aspen Park, Inc., a nonprofit organization, sought a property tax exemption from Bonneville County, Idaho for its low-income apartments. The County’s Board of Equalization denied an exemption because some of the apartments were leased to tenants with incomes above 60 percent of the county’s median income level, a requirement set forth in Idaho Code section 63-602GG(3)(c). Aspen Park appealed to the Idaho Board of Tax Appeals, arguing that the statute allowed vacant apartments to be leased to higher-income earners. After the Board of Tax Appeals denied tax exempt status, Aspen Park filed a petition for judicial review with the district court. The district court granted Bonneville County summary judgment after deciding that to be eligible for a tax exemption under Idaho Code section 63-602GG, every apartment must be rented to low-income individuals or remain vacant. Aspen Park appealed, but finding no reversible error, the Idaho Supreme Court affirmed. View "Aspen Park v. Bonneville County" on Justia Law

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At issue in this case was whether Brent Austin filed a timely complaint for additional worker's compensation benefits with the Idaho Industrial Commission when it was filed more than a year after his employer, Bio Tech Nutrients, and its surety, Employers Compensation Insurance Company, (collectively “Defendants”) stopped paying worker’s compensation benefits. The Commission held that the one-year statute of limitations to file a complaint was tolled because the Defendants did not send a Notice of Claim Status (“NOCS”) when they submitted Austin’s final payment; as such, the Commission concluded Austin’s complaint was timely filed. After review, the Idaho Supreme Court determined the Commission was correct in tolling the statute of limitations, and affirmed. View "Austin v. Bio Tech Nutrients" on Justia Law

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This appeal centered on the distribution of water to water right 95-0734 in the Twin Lakes-Rathdrum Creek Drainage Basin. Sylte Ranch, LLC, was the current claimant on water right 95- 0734, which dated from 1875 and provided natural flow stockwater from Rathdrum Creek. In September 2016, Idaho Department of Water Resources (IDWR) issued a letter of instructions to the local watermaster in response to a complaint that he was releasing storage water from Twin Lakes contrary to a 1989 Final Decree that established all existing rights to Twin Lakes’ surface waters, tributaries, and outlets. These instructions led Sylte to file a Petition for Declaratory Ruling, arguing that IDWR should set aside and reverse the instructions because they improperly limited water right 95-0734 to Twin Lakes’ natural tributary inflow. Twin Lakes Improvement Association, et al., and Twin Lakes Flood Control District intervened in the case. Following cross motions for summary judgment, IDWR issued a Final Order, in which it upheld the instructions and granted intervenors’ motion for summary judgment. Sylte then sought judicial review and the district court affirmed IDWR’s Final Order. Sylte timely appealed to the Idaho Supreme Court. The Supreme Court affirmed the district court’s determination to uphold IDWR’s Final Order because the instructions complied with the plain language of the 1989 Final Decree. View "Sylte v. IDWR" on Justia Law

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This case involved a dispute over how the Idaho Public Employee Retirement Board calculated the annual cost of living adjustment (COLA) for retirees who participated in the Firemen’s Retirement Fund (FRF). The Idaho Industrial Commission held that the definition of “paid firefighter” included part-time firefighters. The effect of the Commission’s decision resulted in a smaller annual COLA for retired firefighters. On appeal, the Idaho Retired Firefighters Association, and Sharon Koelling and John Anderson alleged the Board’s inclusion of part-time firefighters violated statutory and constitutional provisions. The Association and the Individual Claimants sought a ruling from the Idaho Supreme Court reversing the Commission’s decision, and a ruling that would exclude part-time firefighters from the Board’s annual COLA calculations, the effect of which would be an increase in the annual COLA applicable to retired firefighters. The Supreme Court vacated the Commission’s decision because it lacked the necessary jurisdiction to decide the question presented to it. View "Idaho Retired Firefighters v. Public Employy Retirement Bd" on Justia Law

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This case involved an appeal brought by Aerocet, Inc., and its surety, the State Insurance Fund, in which they appealed an Idaho Industrial Commission decision involving two worker’s compensation claims brought by George McGivney. The Commission awarded McGivney benefits for injuries he sustained to his left knee while working for both Aerocet and Quest Aircraft (Quest). The Referee consolidated the two cases and issued a recommendation that attributed the vast majority of liability to Quest. The Commission rejected the bulk of the Referee’s recommendations and apportioned liability equally between Aerocet and Quest. Aerocet appealed, alleging the Commission inappropriately consolidated McGivney’s two injury claims. Aerocet also argued the Commission failed to determine McGivney’s disability in excess of impairment from his 2011 accident at Aerocet prior to his 2014 accident at Quest, and that the Commission erred in its application of Brown v. Home Depot, 272 P.3d 577 (2012). Aerocet also contended the Commission’s decision was not supported by substantial and competent evidence. After review, the Idaho Supreme Court affirmed the Commission’s decisions. The matter was remanded back to the Commission to enable it to calculate the amount due Quest’s surety from Aerocet’s surety for any amounts overpaid by Quest’s surety. View "McGivney v. Aerocet, Inc" on Justia Law

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Buck and Laurie Graybill appealed an award of attorney fees to Regdab, Inc., following entry of a default judgment against them in an action to foreclose on a mechanic’s lien. Graybill objected to the award of attorney fees and costs because Regdab failed to plead in its complaint a specific dollar amount for attorney fees in the event of default as required by Idaho Rule of Procedure 54(e)(4)(B). The district court ruled that the Rule 54(e)(4)(B) pleading requirement was inconsistent with Idaho Code section 45-513, the provision which mandated an award of certain costs and reasonable attorney fees in mechanic’s lien foreclosure actions. The district court then granted Regdab’s motion for default judgment and awarded the principal amount owed on the mechanic’s lien plus $8,134.62 in attorney fees and costs. Graybill appealed. The Idaho Supreme Court agreed with Graybill that Regdab was required to plead a specific amount of attorney fees to be awarded in the event of default. Accordingly, the Supreme Court vacated the default judgment and remanded this case with instruction to enter a default judgment consistent with the Supreme Court's opinion. View "Regdab, Inc. v. Graybill" on Justia Law

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Starting in February of 2014, Philip McGimpsey (“McGimpsey”) and his wife Jolene leased a home from D&L Ventures, Inc. D&L was a Nevada corporation owned by David Asher and his wife Georgina. The residential property McGimpsey leased from D&L was located in Eagle, Idaho. D&L obtained the Property in a 2013 foreclosure sale and received a trustee’s deed, which excluded any warranties. A dispute arose out of a breach of contract claim between the McGimpsey and D&L, who entered into a combined lease/Buy-Sell Agreement for the property. On discovering that D&L was an unregistered Nevada corporation conducting business in Ada County, McGimpsey failed to close on the purchase of the home in 2017, because he believed D&L to be in violation of Idaho Code section 30-21-502(a). After the closing date passed, D&L informed McGimpsey that the contractual provisions terminated upon his failure to close and reminded McGimpsey he had to vacate the property, pursuant to the Buy-Sell Agreement. About a month later, D&L registered with the Idaho Secretary of State as a Nevada corporation and filed all of its tax returns and paid its other obligations. McGimpsey subsequently filed a complaint against D&L, and the corporation counterclaimed against McGimpsey and third-party defendants. D&L moved for summary judgment that was granted in part and denied in part. The district court ultimately concluded that D&L had the legal ability to convey the property via warranty deed and that McGimpsey breached the Buy-Sell Agreement by failing to close and failing to show that his breach was excused by D&L’s alleged inability to convey marketable title. McGimpsey and third-party defendants timely appealed and their appeals were consolidated. The Idaho Supreme Court affirmed the district court’s award of summary judgment to D&L because Idaho Code section 30- 21-502 did not impair the validity of contracts; therefore, D&L had the legal ability to convey the property via warranty deed. View "McGimpsey v. D&L Ventures" on Justia Law