Justia Idaho Supreme Court Opinion Summaries

Articles Posted in Idaho Supreme Court - Civil
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The issue this case presented for the Idaho Supreme Court's review concerned an unjust enrichment claim brought by Kenworth, a commercial truck dealer, against Skinner Trucking, one of its customers. Kenworth claimed Skinner was unjustly enriched when Kenworth paid past due lease payments and the residual balance owed on Skinner’s lease with GE Transportation Finance. The district court entered judgment for Skinner on the grounds that, as to the residual value of the trucks, Kenworth had not conferred a benefit on Skinner, and that as to both the residual value of the trucks and the past due lease payments, Kenworth was an “officious intermeddler” because it had voluntarily paid GE without request by Skinner and without a valid reason. In a subsequent order, the district court denied Skinner’s request for attorney fees under Idaho Code sections 12-120(3) and 12-121. Kenworth appealed the district court’s judgment; Skinner appealed the district court’s order regarding costs and fees. The Supreme Court concluded after review: (1) the "officious intermeddler" rule was not an affirmative defense; the district court did not err in concluding Kenworth was an officious intermeddler; and (3) the district court did not err in determining that Skinner was not entitled to attorney fees under the circumstances. View "Kenworth Sales v. Skinner Trucking" on Justia Law

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In 2013 and 2014, mother Jordain Bradford was involved in relationships with both Shad Hamberlin and Matthew Edwards. She did not marry either man. On September 24, 2014, Bradford gave birth to a minor child, T.J.H. Bradford and Hamberlin discussed the timing of her pregnancy and decided that Hamberlin had to be T.J.H.’s father. Bradford did not discuss the pregnancy with Edwards, nor were any additional objective measures, such as a paternity test, taken at that time. When T.J.H. was over nine months old, Bradford and Hamberlin each signed and notarized a Voluntary Acknowledgement of Paternity Affidavit (“VAP”), in which they both acknowledged that Hamberlin was the biological father of T.J.H. The State of Idaho then issued a birth certificate listing Hamberlin as T.J.H.’s father. Bradford and Hamberlin lived with T.J.H., generally in Bradford’s parents’ home, until around September 2016, when they separated. Hamberlin filed suit to establish child custody and child support for T.J.H. Bradford initially answered the petition by admitting, among other things, that she and Hamberlin were the biological parents of T.J.H. and that “both parties should have legal custody and joint physical custody of T.J.H. . . .” Bradford reversed course less than one month later, amending her answer to disavow that Hamberlin was a biological parent of T.J.H., and positing that Hamberlin should not have custody. Bradford amended her answer again in January 2017. This pleading continued to deny that Hamberlin was a biological parent of T.J.H., and affirmatively asserted that Hamberlin “has [no] legal right to have any of the care, custody and control of the minor child. . . .” Bradford also asserted for the first time, as an affirmative defense, that Hamberlin “is not the biological father of the minor child at issue in this matter.” The magistrate court rejected the mother’s effort to rescind the VAP and the district court affirmed that ruling. Bradford appealed, but finding no reversible error, the Idaho Supreme Court affirmed. View "Hamberlin v. Bradford" on Justia Law

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The East Side Highway District (the District) and Gregory and Ellen Delavan (the Delavans) disputed the location of their common boundary relating to a portion of a road, Boothe Park Road, which included a boat ramp located on the shore of Lake Coeur d’Alene. The District asserted a claim to the disputed property under two theories: (1) a boundary by agreement that was established by the location of a fence that was erected by the Delavans’ predecessor in interest; and (2) Boothe Park Road and the boat ramp at its termination was a public highway pursuant to Idaho Code section 40-202(3). In response, the Delavans claimed the boat ramp was on their property, and its use by the public has always been, and remained, permissive. Further, the Delavans claimed the fence which was erected by their predecessor in interest was intended to act as a barrier, not a boundary. After two bench trials, the trial court ruled in favor of the Delavans, finding that the public’s use of the boat ramp had been permissive. As a result, the trial court ruled that the District did not have a right to a public easement based on Idaho Code section 40-202(3). Further, the trial court found that the fence had been erected as a barrier, not a boundary. Instead, the trial court found that the intention of the parties at the time the disputed property was conveyed to the Delavans demonstrated that the Delavans owned the property in dispute. The District appealed. After review, the Idaho Supreme Court held there was substantial and competent evidence to support the trial court’s findings that there was no boundary by agreement and that the Delavans owned the property in dispute. However, the Supreme Court vacated the trial court’s order granting summary judgment in favor of the Delavans because there was no hostility requirement in Idaho Code section 40-202(3). Accordingly, the case was remanded to determine whether the District had a public easement under Idaho Code section 40-202(3). View "Eastside Hwy Dist v. Delavan" on Justia Law

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This case arose out of the termination of Ryan and Lanie Berrett (“the Berretts”) from their jobs with Clark County School District No. 161 (the “School District”), and raised issues regarding the “law of the case” doctrine, the Idaho Protection of Public Employees Act (“Whistleblower Act”), and wrongful termination in violation of public policy. The Berretts sued the School District, alleging that both of their terminations were in retaliation for Ryan Berrett reporting a building code violation to the School District’s board of trustees (the “board”). The district court granted the School District’s motion for summary judgment, finding that Ryan Berrett did not engage in a protected activity under the Whistleblower Act, and that Idaho’s public policy did not extend to protect Lanie Berrett in a termination in violation of public policy claim. The district court also denied the Berretts’ motion for reconsideration. The Berretts timely appealed. The Idaho Supreme Court concluded after review the law of the case doctrine did not preclude the district court from considering the School District’s motion for summary judgment, however, the Court erred in granting summary judgment on Ryan Berrett’s Whistleblower Act claim; the Court found genuine issues of material fact regarding whether Ryan Berrett engaged in a protected activity and causation. The trial court did not err in granting summary judgment on Lanie Berrett’s termination in violation of public policy claim. The matter was remanded for further proceedings. View "Berrett v. Clark County School District" on Justia Law

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Lamont Bair Enterprises, Inc. (“LBE”) was an Idaho corporation based in Idaho Falls that owned residential rental units. One of LBE’s rental units was a four-plex rental property at 547 South Skyline Drive (“the Property”), served by municipal water lines owned and maintained by the City of Idaho Falls (“the City”). On December 28, 2015, a municipal water main broke, causing water to flow beneath the Property’s driveway, crack the concrete basement floor, and flood the basements of all four rental units. The City received an emergency call for assistance in shutting off the water. Believing the incident to be a service line leak (as opposed to a water main break), the City’s response crew first closed the water service line and waited for confirmation that the water flow had stopped. After the crew received notice that water continued to flow into the basement, they isolated the leak to the water main and began repairing the main line. The water was turned back on the following day, and the road and curb were filled back in. None of LBE’s rental units ever experienced flooding from the city’s water lines prior to this flooding incident at the Property. LBE contended the water main “ruptured” due to negligent care (that “the City neglected its water system to the point that literally miles of pipe became past their design life and in need of replacement”) thus failing to exercise reasonable care in maintaining the water supply system. The district court ruled the City was immune from liability under the Idaho Tort Claims Act’s discretionary function exception. The Idaho Supreme Court determined the district court did not err in holding that the City is immune from suit pursuant to the discretionary function exception set forth in Idaho Code section 6-904(1). The Court did not reach the merits of the other issues LBE raised on appeal. View "Lamont Bair Enterprises v. City of Idaho Falls" on Justia Law

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At issue in this appeal was a district court’s dismissal of Rencher/Sundown LLC’s (“Sundown”) complaint against Butch Pearson. The Idaho Supreme Court determined Sundown did not serve the complaint or summons within the six months required by Idaho Rule of Civil Procedure 4(b)(2); Pearson moved to dismiss the complaint. The district court dismissed Sundown’s complaint after finding Sundown could not show good cause for failure to timely serve. The Supreme Court affirmed dismissal of Sundown's complaint. View "Rencher/Sundown LLC v. Pearson" on Justia Law

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Appellants Jerry and JoCarol Losee appeal the district court’s decision granting Deutsche Bank National Trust Company’s motion for summary judgment, arguing the district court erred by refusing to consider their “Chain of Title Analysis” as inadmissible hearsay. The Losees also argue the district court erred in failing to rule on two of their claims against Deutsche Bank. In 2009, the Losees became delinquent in their mortgage payments, eventually defaulting on their home mortgage loan. Over two years after the foreclosure sale was supposed to take place, a second notice of default was recorded on April 20, 2014. However, the foreclosure sale was postponed when the Losees requested a loss mitigation review. The owner of the loan would not allow loan modification, so the Losees were advised that a short sale of the property was the only loss mitigation available. On August 17, 2015, this case commenced when the Losees, acting pro se, filed their “Original Petition for Breach of Contract, Slander of Title for Declaratory Judgment and Motion for Temporary Restraining Order and Application for Temporary Injunction” (“Complaint”) with the district court. In 2017, the Losees submitted a “Notice of Filing for Judicial Review,” to which they attached a “Chain of Title Analysis.” The “Chain of Title Analysis” was a report resulting from a mortgage fraud investigation conducted by a private investigation company they hired. The district court granted the Bank's motion for summary judgment, concluding there was no breach of the Deed of Trust, title to the property had not been slandered or become clouded by assignment, and that the Chain of Title Analysis was inadmissible hearsay not appropriate for consideration by the court on summary judgment. The Idaho Supreme Court found no reversible error in the district court's grant of summary judgment and affirmed. View "Losee v. Deutsche Bank Nat'l Trust" on Justia Law

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Peter Nemeth and his wife Mary Nemeth (deceased), and Peter Nemeth acting as trustee of the Peter and Mary Nemeth Family Trust (collectively, “the Nemeths”), petitioned Shoshone County, Idaho, to validate a public right-of-way across federal land pursuant to Idaho Code section 40-204A and United States Revised Statute 2477 (“R.S. 2477”). The right-of-way followed a road which crossed federal land that Nemeths claimed historically provided access to their property and patented mining claims. When the County failed to act on the petition, the Nemeths filed a declaratory judgment action seeking validation of the right-of-way pursuant to Idaho Code section 40- 208(7). On a motion from the County, the district court dismissed the complaint pursuant to I.R.C.P. 12(b)(6) on grounds that because the Road traversed federal land, only a federal court had jurisdiction to hear the claim, which had to be brought under the federal Quiet Title Act (QTA), 28 U.S.C. section 2409a. The Nemeths appealed, arguing that state courts had jurisdiction to validate rights-of- way on federal land pursuant to R.S. 2477 and that the QTA did not preempt Idaho law that provided for such validation. After review, the Idaho Supreme Court reversed, because the district court erred in dismissing the Nemeths’ action on the basis it lacked subject matter jurisdiction. View "Nemeth v. Shoshone County" on Justia Law

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In its motion for summary judgment, Farmers Insurance Company of Idaho argued that Erica Klein was barred from pursuing a supplemental UIM claim because the five-year statute of limitations in Idaho Code section 5-216 had run. Farmers asserted the statute of limitations began to run on either the date of the accident or the date Klein settled with the third party tortfeasor, both of which occurred more than five years prior to Klein filing her complaint to compel arbitration of her UIM claim. The district court denied Farmers’s motion and subsequent motion for reconsideration, holding that the “breach of contract” rule was the proper method of calculating the accrual date for Klein’s cause of action. Farmers appealed the district court’s denial of both motions. The Idaho Supreme Court determined the issue raised by this case was one of first impression, inasmuch as it was asked to determine when the statute of limitations began to run on a cause of action for UIM benefits under an automobile insurance policy. After considering the different approaches taken by other states, the Court adopted the majority’s “breach of contract” rule and affirmed the district court’s decisions. View "Klein v. Farmers Insurance Co." on Justia Law

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First Bank of Lincoln (First Bank) challenged a district court’s grant of summary judgment in favor of Land Title of Nez Perce County Incorporated (Land Title). In 2011, First Bank loaned Donald Tuschoff $440,000 to purchase the Hotel Lincoln in Lincoln, Montana. The loan was secured by a deed of trust against the hotel. As additional collateral, Tuschoff assigned First Bank his interest in a note and deed of trust on a bowling alley in Washington. Later, following a sale of the bowling alley, Land Title distributed the proceeds to Tuschoff and other interested parties rather than First Bank. First Bank did not learn of the bowling alley sale until it completed its annual loan review of Tuschoff’s hotel loan. Subsequently, Tuschoff defaulted on the hotel loan. First Bank held a non-judicial foreclosure sale of the hotel and placed a full-credit bid of the approximately $425,000 owed to it by Tuschoff. First Bank was able to later sell the hotel for approximately $190,000. First Bank then initiated several lawsuits against various parties in Washington, Montana, and Idaho, seeking to recover the “deficiency” between what it was owed and for what it sold the hotel. Relevant here was First Bank’s suit against Land Title in Idaho. The district court, applying Montana law, granted summary judgment in favor of Land Title. The court determined that First Bank’s full credit bid extinguished Tuschoff’s debt, and once that debt was extinguished, the assignment of Tuschoff’s interest in the bowling alley as collateral for that debt was also extinguished. The Idaho Supreme Court concurred with this conclusion, and affirmed. View "First Bank of Lincoln v. Land Title of Nez Perce County" on Justia Law