Justia Idaho Supreme Court Opinion Summaries

A couple began constructing a residential barndominium and lived in an RV on their property in Sandpoint, Idaho. After a heavy snowstorm caused the collapse of the partially constructed dwelling and damaged utility connections to their RV, they made claims under their State Farm homeowner’s insurance policy for structural losses, personal property damage, demolition and outbuilding losses, additional living expenses (ALE), and alleged unreasonable delays. State Farm paid over $120,000 but denied further claims, citing lack of required documentation and inventories.The couple filed suit in the District Court of the First Judicial District, Bonner County, alleging breach of contract, bad faith, and negligent adjustment. State Farm moved for partial summary judgment, arguing the plaintiffs failed to substantiate their losses and did not incur ALE as defined under the policy. The district court struck several exhibits as inadmissible hearsay, including a letter from a medical expert and a timeline of events, and granted summary judgment to State Farm. The court concluded that the plaintiffs had not complied with policy conditions, failed to substantiate their claimed losses, and that their claims were fairly debatable.On appeal, the Supreme Court of the State of Idaho reviewed evidentiary rulings for abuse of discretion and the grant of summary judgment de novo. The Court affirmed the district court’s exclusion of evidence as inadmissible hearsay and lack of personal knowledge. It held that the plaintiffs did not establish entitlement to ALE, failed to substantiate structural and personal property losses, and provided insufficient evidence of bad faith or negligent adjustment. The judgment of the district court was affirmed, with State Farm awarded costs on appeal. View "Espinosa v. State Farm" on Justia Law

BBC, LLC, contracted Germer Construction, Inc. to provide construction services for a subdivision development. A dispute arose regarding the amount owed, leading to arbitration as required by contract. The arbitrator awarded Germer nearly $1,000,000, including costs and fees. BBC sought a court order to vacate the arbitration award, while Germer requested confirmation of the award and entry of judgment. Germer also moved for a temporary restraining order and preliminary injunction, claiming BBC was dissipating assets. The district court granted an ex parte temporary restraining order restricting BBC’s asset transfers. At a hearing, the district court required BBC to post a $1,000,000 surety bond and Germer a $250,000 bond, characterizing them as “equivalent” to supersedeas bonds, then dissolved the restraining order and denied preliminary injunctive relief.BBC petitioned the Idaho Supreme Court for writs of prohibition or mandamus to vacate the district court’s order and prohibit further pre-judgment asset restrictions, arguing the district court lacked authority to require the bond or injunctive relief solely to secure a potential monetary judgment. The Idaho Supreme Court stayed the district court’s order and sought briefing from Germer and the Attorney General.The Supreme Court of Idaho held that the district court exceeded its authority by requiring BBC to post a surety bond to secure a potential money judgment for an unsecured debt. The court found no rule, statute, or inherent equitable power authorizing such relief in this context. The court issued a writ of review, vacating the district court’s order, including both bond requirements. BBC was found to have no adequate, speedy remedy at law, and the requested writs of prohibition and mandamus were denied. The case was remanded for further proceedings consistent with the opinion. View "BBC LLC v. LATAH COUNTY DISTRICT COURT" on Justia Law

The dispute centers on real property originally acquired by John and Constance Clark as part of a family farming operation. In 1988, two parcels were conveyed to their son, Jay Clark, who subsequently transferred the properties to Clover Hollow Farms, Inc., a corporation formed shortly before the conveyance with John Clark as its sole shareholder. Jay Clark served as vice-president and director of Clover Hollow. According to Jay Clark, his parents promised that Clover Hollow would hold the property in trust for him as a premarital asset, to be returned upon demand or subject to his exclusive control. Years later, Jay Clark assigned his interests in one of the properties to C & H Properties, LLC, operated by his children.After John Clark was placed under a conservatorship, the conservator, Judith Appleby, adopted corporate resolutions nullifying Jay Clark’s authority and authorizing the corporation to join litigation seeking a declaration that Jay Clark had no interest in the corporate stock, real property, or tangible property. Jay Clark filed counterclaims challenging the validity of these resolutions and seeking to regain title to the properties. The District Court of the Third Judicial District, Canyon County, granted summary judgment to the Estates and Clover Hollow. It ruled that judicial estoppel barred Jay Clark’s claims due to his failure to disclose the properties in bankruptcy and found that his claims under constructive trust, promissory estoppel, and unjust enrichment failed as a matter of law. The court also upheld the corporate resolutions enacted by Appleby.The Supreme Court of the State of Idaho reviewed the district court’s rulings. It held that Ms. Appleby, as executor, lacked authority under Clover Hollow’s bylaws and the Idaho Business Corporation Act to convene a special shareholder meeting and enact corporate resolutions, rendering those actions invalid. Consequently, Clover Hollow was never properly joined in the litigation. The Supreme Court vacated the judgment, reversed the grant of summary judgment on Jay Clark’s sixth counterclaim, and remanded the case with instructions to allow reasonable time for proper joinder of Clover Hollow as a party. View "Estate of Clark v. Clark" on Justia Law

The dispute centers on statements made by an attorney during a media interview concerning the fallout from a business partnership between two individuals, one of whom was accused of embezzlement and criminal wrongdoing. The attorney commented publicly about the circumstances that led to the criminal charges against his client and the civil dispute with his client’s business partner. After criminal charges against the client were dismissed, the business partner sued the attorney and his former law firm for defamation and defamation per se, specifically challenging statements in the interview that allegedly impugned his reputation and business fitness.Prior to trial, the District Court of the Sixth Judicial District, Bannock County, granted summary judgment on ordinary defamation claims due to a lack of pleaded special damages and dismissed one defendant by stipulation. The case proceeded to a jury trial solely on defamation per se claims. The plaintiff requested a jury instruction defining defamation per se to include statements imputing conduct incompatible with the plaintiff’s lawful business, trade, or profession. The district court declined, instructing the jury that defamation per se was limited to statements imputing criminal conduct punishable by imprisonment or involving moral turpitude. The jury found for the defendants, and the district court denied the plaintiff’s motion for a new trial.On appeal, the Supreme Court of the State of Idaho reviewed whether the district court erred in its jury instructions on defamation per se. The Court held that Idaho law does recognize statements imputing unfitness in the conduct of a person’s business, trade, or profession as a category of defamation per se. The district court’s failure to instruct the jury on this category constituted prejudicial error. Accordingly, the Supreme Court vacated the judgment and remanded the case for a new trial, denying attorney fees to the respondents. View "Taylor v. Davis" on Justia Law

A developer began constructing and selling duplex-style condominiums in Bonner County, Idaho, using a standard real estate purchase and sale agreement (PSA) form. The buyers, including a real estate agent and his wife, entered into PSAs for two units, planning to use them as personal and investment properties. The PSAs referenced detailed “Plans and Specifications” for the construction and finishes of the units, but no such documents were attached or ever created. Disputes later arose over the scope and quality of the promised finishes, especially after the developer communicated price increases and clarified the options for base and upgraded finishes. The buyers sued to enforce the contracts and sought specific performance, while the developer counterclaimed for a declaration that the PSAs were invalid due to indefiniteness.The District Court of the First Judicial District, Bonner County, conducted a bench trial. It found that the PSAs for the disputed units were missing essential material terms, specifically the absent Plans and Specifications, which left the scope of work, finishes, and price adjustments undefined. The court concluded that no enforceable contract was formed and denied the buyers’ request for specific performance. The developer was ordered to return deposits but was deemed the prevailing party, entitling him to attorney fees and costs. The district court also conditioned a stay of its judgment pending appeal on the posting of an additional bond.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s judgment. It held that the PSAs were invalid and unenforceable because they omitted material terms necessary to define the contractual obligations. The buyers’ challenge to the additional bond was deemed moot given the disposition of the contract claims. The award of attorney fees to the developer was upheld, and the Supreme Court granted him attorney fees and costs for the appeal as the prevailing party. View "SCHUSTER v. MILBRATH" on Justia Law

This case stems from a fatal plane crash in which a pilot, Chelsea Brittney Infanger, collided with exhaust stacks owned by a processing plant near the Burley Municipal Airport in Idaho. The stacks, which extended over 100 feet high, were situated within the runway’s approach path and had been the subject of prior regulatory concern. The pilot’s parents brought a wrongful death suit, alleging that the Idaho Department of Transportation’s Division of Aeronautics negligently failed to regulate or mitigate the known risk posed by these stacks, arguing that various statutory, common law, special relationship, and contractual duties compelled the Division to act.After settlements with other defendants, the case proceeded against the Division in the District Court of the Fourth Judicial District, Ada County. The Division moved for summary judgment, contending it owed no individualized duty to the deceased under the Airport Zoning Act, common law, or through a special relationship, and that it was immune under the Idaho Tort Claims Act. The district court agreed, holding that the Division’s statutory duties were general obligations to the public, not specific duties to individual aviators, and found no basis for liability under special relationship or contract theories. The court granted summary judgment to the Division, and the plaintiffs appealed.The Supreme Court of the State of Idaho affirmed the district court’s decision. It held that the Airport Zoning Act did not create a tort duty to a particular class of persons, but rather imposed general obligations for public safety, and thus could not support a negligence per se claim. The Court also found that the plaintiffs did not preserve or demonstrate the elements necessary for a special relationship or assumed duty sufficient to impose liability. The Court declined to award attorney fees, but granted costs to the Division. View "Infanger v. State of Idaho, Idaho Department of Transportation" on Justia Law

A local man participated in a drag show at a public event in Coeur d’Alene City Park, performing on stage before an audience that included children. A member of the audience recorded the performance and sent the video to a local blogger, who did not attend the event. After reviewing the video, the blogger posted content on social media accusing the performer of exposing his genitalia to minors during the show. The blogger edited and posted a version of the video with a blurred area, claiming it covered fully exposed genitals, and invited public scrutiny and police investigation. These statements led to public backlash, an official investigation (which was closed for lack of evidence), harassment of the performer, job loss, and significant mental distress.The performer sued the blogger for defamation and defamation by implication in the District Court of the First Judicial District, Kootenai County. Both parties filed motions for summary judgment, which were denied. The court ruled that the performer was not a public figure or limited-purpose public figure, allowing him to seek punitive damages. At trial, the jury found in favor of the performer, awarding substantial compensatory and punitive damages, and found that the blogger acted with actual malice. The district court entered judgment accordingly. The blogger appealed, raising ten alleged errors related to jury instructions, verdict forms, damages, and legal standards.The Supreme Court of the State of Idaho reviewed the appeal. It declined to address most issues due to pervasive deficiencies in the appellant’s briefing, including lack of cogent argument, fabricated authority, and unpreserved issues. The Court held that even if the district court erred in determining the performer was not a limited-purpose public figure, the error was harmless because the jury found actual malice. The Court affirmed the district court’s judgment and awarded costs to the respondent. View "Posey v. Bushnell" on Justia Law

A plaintiff, seeking to secure retirement funds, sold an apartment complex in 2017 and was introduced to Ronald Hill, who represented himself as a financial advisor but was only licensed as an insurance producer. Hill persuaded the plaintiff to invest the sale proceeds in a product offered by Future Income Payments, LLC (FIP), and also to purchase an Indexed Universal Life (IUL) insurance policy, initially from Minnesota Life and later from Pacific Life. Hill proposed that the proceeds from the FIP investment would fund the premiums for the Pacific Life IUL policy. FIP was subsequently exposed as a Ponzi scheme, resulting in the plaintiff’s loss of the investment and inability to pay the insurance premiums.The plaintiff and other parties filed suit in the District Court of the Third Judicial District, Canyon County, Idaho, asserting claims including negligence against Hill and Pacific Life. By trial, only Hill and Pacific Life remained as defendants, with the plaintiff as the sole remaining claimant. The trial proceeded on a common law negligence claim. The jury found both Hill and Pacific Life negligent, determined Hill was acting as Pacific Life’s agent, and apportioned 60% of fault to Pacific Life and 40% to Hill. The district court entered judgments against Pacific Life, including joint and several liability with Hill for a portion of damages. Pacific Life appealed, challenging the district court’s denial of motions for directed verdict.The Supreme Court of the State of Idaho reviewed the appeal and held that, under Idaho law, Pacific Life owed no duty to protect the plaintiff from pure economic loss absent an applicable exception to the economic loss rule. The Court further found insufficient evidence to establish Hill acted as Pacific Life’s agent when marketing the FIP investment. The Court vacated the judgments against Pacific Life and remanded with instructions to enter judgment in favor of Pacific Life. View "Shelstad v. Pacific Life Insurance" on Justia Law

The petitioner was convicted by a jury of felony lewd conduct with a minor and two counts of felony sexual abuse of a child, resulting in substantial concurrent prison sentences. He later submitted a petition for post-conviction relief, alleging that his trial counsel failed to communicate his acceptance of a plea offer from the State, which would have resulted in a considerably lighter sentence. The petitioner claimed in an affidavit that he instructed his trial counsel to accept the State’s offer, but the offer was withdrawn after counsel failed to convey his acceptance.The District Court of the First Judicial District, Bonner County, granted the State’s motion for summary disposition and dismissed the petition, concluding that the petitioner’s affidavit was conclusory and lacked admissible evidence. On appeal, the Idaho Court of Appeals affirmed the district court’s judgment, relying in part on statements made by the petitioner’s post-conviction counsel at the summary disposition hearing, which were interpreted as a concession that the claim lacked merit. The petitioner then filed a petition for review with the Supreme Court of Idaho.The Supreme Court of Idaho reviewed the district court’s decision directly and held that the petitioner’s post-conviction counsel’s statements did not constitute a binding concession, and that the petitioner had presented sufficient admissible, non-conclusory evidence in his affidavit to create a genuine issue of material fact. The Court explained that the petitioner’s factual assertions regarding the plea offer and his instructions to counsel were within his personal knowledge and were not conclusory. Accordingly, the Supreme Court vacated the district court’s judgment, reversed the order summarily dismissing the petition for post-conviction relief, and remanded the case for further proceedings. View "Ennis v. State of Idaho" on Justia Law

Snap, a Delaware corporation, sued Vertical Raise, an Idaho LLC, and an individual, alleging tortious interference, misappropriation of trade secrets, and unfair competition. Liability was resolved in Snap’s favor on summary judgment. At trial, the jury awarded Snap $750,000 in unjust enrichment damages and $250,000 in punitive damages. However, the district court mistakenly entered judgment for $800,000, not $1,000,000. Snap sought an additur or new trial and discretionary costs. The district court granted both: costs were awarded, and the damages were increased via additur, but without giving Vertical Raise the option to accept or reject it.Vertical Raise appealed to the Supreme Court of Idaho, which in the prior case, Snap! Mobile, Inc. v. Vertical Raise, LLC, 173 Idaho 499, 544 P.3d 714 (2024), affirmed the costs award, reversed the grant of additur or new trial, and remanded with instructions to reinstate the jury verdict and enter an amended judgment accordingly. After remand, Vertical Raise’s surety bond paid the judgment and costs, but not post-judgment interest. Disputes arose over whether interest accrued from the dates of the original and amended judgments, or only from the post-remand judgment.In the present appeal, the Supreme Court of Idaho reviewed whether the district court erred by awarding post-judgment interest starting from the entry dates of the original and amended judgments. The Court held that post-judgment interest accrues from the dates when the original and amended judgments were entered, not from the date of the post-remand judgment, even if later judgments modify the amount owed. The Third Amended Judgment was affirmed. The Court also awarded Snap its attorney fees under Idaho Code section 12-121, finding Vertical Raise’s appeal unreasonable and without foundation. Costs on appeal were awarded as a matter of course. View "SNAP! MOBILE v. VERTICAL RAISE" on Justia Law