Justia Idaho Supreme Court Opinion Summaries

The Idaho Department of Health and Welfare’s (“the Department”) cited Grace at Fairview Lakes, LLC (“Grace”), a residential assisted living and memory care facility, for failing to provide a safe living environment for residents and for inadequate training in relation to COVID-19 infection control measures. Grace requested administrative review of the enforcement action, which was affirmed by a Department administrator. Grace then filed an administrative appeal challenging the action, which was affirmed by a hearing officer. Grace then filed a petition for judicial review to the district court. The district court denied all the relief sought by Grace. On appeal to the Idaho Supreme Court, Grace argued the district court erred because the hearing officer’s decision was not supported by substantial evidence in the record as a whole. The Supreme Court found no error in the district court’s decision because there was substantial evidence in the record to support the hearing officer’s order. View "Grace at Fairview Lakes, LLC v. IDHW" on Justia Law

Between 2015 and 2019, BitterSweet Ranch and its managers (“BitterSweet”) leased three parcels of farmland from Frank Sullivan and two of his business entities, The Green Desert, LLC, and The Sullivan Limited Partnership (collectively, “Sullivan”). The parties signed three identical five-year leases (“the Leases”) involving three separate parcels of real property, each owned by one of the three Sullivan parties. The Leases specified that Sullivan was to be responsible for payment of the property taxes, but that those parties were to be reimbursed by BitterSweet, and that BitterSweet was to be responsible for bi-annual rent payments, utilities, and water assessments. For a variety of reasons, the parties purportedly orally agreed to modify the Leases to offset amounts owed to each other throughout the terms of the Leases. Shortly before the Leases were set to expire at the end of their five-year terms, Sullivan claimed that BitterSweet was in breach of the Leases for its alleged failure to make timely rent payments, to pay all property taxes, and to pay the water assessments pursuant to the terms of the Leases. Sullivan then filed three lawsuits (one for each of the Leases and in the names of each of the three parties) in district court. The district court ordered the cases consolidated and then granted summary judgment in favor of BitterSweet, concluding that a genuine issue of material fact had not been created as to whether BitterSweet had breached the Leases. Sullivan appealed the adverse order. Finding no reversible error, the Idaho Supreme Court affirmed. View "Sullivan v. BitterSweet Ranch, LLC" on Justia Law

Mitchell Smith was employed by Amalgamated Sugar Company (“Amalgamated”) in Nampa, Idaho, when he was injured falling from a flight of stairs after the handrail gave out. Amalgamated had contracted with Excel Fabrication, LLC (“Excel”), to construct and install the flight of stairs and the handrail. Smith received worker’s compensation benefits from Amalgamated. Smith then sued Excel as a third-party tortfeasor, alleging that Excel had been negligent in its construction and installation of the staircase. Excel moved for summary judgment, arguing that it was a “statutory co-employee” with Smith and, therefore, it was immune from liability as a result of the exclusive remedy rule. The district court agreed and granted Excel’s motion for summary judgment. The district court then dismissed the case, with prejudice. Smith appealed. Based on the district court’s failure to recognize the differences between an independent contractor from either a contractor or a subcontractor, the Idaho Supreme Court held that the district court erred in granting Excel’s motion for summary judgment: the text of the Worker’s Compensation Law indicated that “independent contractors” were fundamentally different from “contractors and subcontractors” as those terms were used throughout the Idaho Worker’s Compensation Act. Because of this fundamental difference, an independent contractor was not immune from third-party tort liability as a statutory employer. The judgment was reversed and the matter remanded for further proceedings. View "Smith v. Excel Fabrication, LLC" on Justia Law

This appeal was about whether an aggrieved applicant could bring a direct action against a city, its administrators, and its mayor for alleged misconduct pertaining to the granting of a conditional use permit without first exhausting administrative remedies and seeking judicial review. The answer is almost always “no,” but based on the unique facts in this case the Idaho Supreme Court held that the applicant was excused from exhausting administrative remedies. View "Bracken v. City of Ketchum" on Justia Law

After suffering personal injuries and property damage in a multi-car collision with an underinsured motorist, Kelly Lynn Christmann filed suit against her insurer, State Farm Mutual Automobile Insurance Company (“State Farm”). Christmann was seeking to obtain the underinsured motorist benefits provided under her contract of insurance, which she claimed State Farm failed to pay in an amount justly due under her policy. She also alleged that certain terms of her insurance agreement violate public policy. State Farm argued that Christmann waived her rights to additional benefits by failing to comply with the contractual obligations of her insurance policy, thereby prejudicing State Farm’s right to subrogation against the underinsured motorist. The district court awarded summary judgment to State Farm in determining it had been prejudiced by Christmann’s conduct and that the terms of the insurance policy were valid. The court also denied Christmann’s motion for reconsideration and her Rule 60(b) motion for relief. Christmann appealed. Because the record showed State Farm fully settled its claims against the underinsured motorist and waived its subrogation rights, the Idaho Supreme Court concluded it suffered no actual prejudice from Christmann’s actions. Accordingly, the judgment was reversed. View "Christmann v. State Farm Mutual Automobile Insurance Co." on Justia Law

At issue in this case was the distribution of charitable donations received by the International Rescue Committee (“IRC) to aid four refugee families and others in the refugee community who were victims of a mass stabbing incident in Boise, Idaho, in 2018. Mustafa Mohammed and Ekhlas Al Khudhur (“Appellants”) challenged a magistrate court’s order approving the final distribution of funds as proposed by IRC. IRC calculated the final distribution of donated funds to the families using a formula of its own creation based on methodology and principles developed by Kenneth Feinberg, an expert on compensation fund valuation and distribution following high-profile, mass tragedies. The district court, acting in its intermediate appellate capacity, affirmed the magistrate court’s order, which held that a trust had been created and that the proposed distribution method for the donated funds was within IRC’s discretion as trustee. On appeal to the Idaho Supreme Court, Appellants argued the district court erred in affirming the magistrate court's decision by: (1) determining there had been a trust created; (2) concluding that IRC’s final distribution was reasonable or within IRC’s discretion; and (3) prohibiting Appellants from presenting evidence of their respective injuries from the attack. Finding no reversible error, the Supreme Court affirmed. View "International Rescue Committee v. Mohammed" on Justia Law

The issue this case presented for the Idaho Supreme Court's review centered on a wage claim dispute between Pat Stiffler and his previous employer, Hydroblend, Inc. After a dispute arose concerning incentive pay on an allegedly miscoded account, Stiffler filed a complaint for unpaid wages, breach of contract, retaliation, and wrongful termination. The proceedings culminated with two orders from the district court that: (1) awarded summary judgment to Hydroblend concerning treble damages; (2) concluded multiple issues were governed by an arbitration provision in Stiffler’s employment agreement; and (3) denied summary judgment where disputed facts remained at issue. Stiffler appealed the district court’s decisions, arguing that he is entitled to treble damages on all wages under Idaho’s Wage Claim Act, as well as severance pay under his 2019 employment contract. Stiffler also argues that the district court erred by compelling arbitration of some of his claims. The Idaho Supreme Court reversed the district court’s dismissal of Stiffler’s arbitrable claims because they should have been stayed, not dismissed. However, the Court affirmed the district court’s determination that a 2019 Contract controlled the issue of incentive pay while the remaining claims arose under a 2021 Contract and its arbitration agreement. As the prevailing party, Hydroblend was entitled to costs on appeal pursuant to Idaho Appellate Rule 40(a). View "Stiffler v. Hydroblend, Inc." on Justia Law

Shake Out, LLC entered into a contract with Clearwater Construction, LLC (“Clearwater”), to repair the building Shake Out’s restaurant occupied. The relationship between the parties quickly deteriorated, resulting in Shake Out filing a lawsuit against Clearwater. The parties attempted to mediate their dispute but were unsuccessful. After the case had proceeded for some time, Clearwater sought to compel arbitration pursuant to the contract. Shake Out objected, asserting that Clearwater had waived its right to enforce the arbitration clause because it had participated in the litigation for almost ten months before seeking to compel arbitration. The district court concluded Clearwater had not waived its right to seek arbitration and entered an order compelling arbitration and staying the proceedings. Finding no reversible error in that judgment, the Idaho Supreme Court affirmed. View "Shake Out, LLC v. Clearwater Construction, LLC" on Justia Law

Appellant North West Neighborhood Association challenged a district court’s decision upholding Boise City Council’s approval of three interrelated land use applications. The Idaho Supreme Court agreed with Appellant that Boise City Council failed to provide a reasoned statement explaining its approval of the applications as required by section 67-6535(2) of the Local Land Use Planning Act. The Court remanded this matter to the district court with instructions to set aside Boise City Council’s actions and remand to the Council for the adoption of a reasoned statement. View "NW Neighborhood Assoc v. City of Boise" on Justia Law

Holly Rich brought a legal malpractice action against her attorneys, Hepworth Holzer, LLP, and E. Craig Daue and Daue Buxbaum, PLLC (“Daue Buxbaum”) (collectively, “Respondents”), regarding their legal representation of Rich in an underlying medical malpractice action against Eastern Idaho Regional Medical Center (“EIRMC”), Dr. John Lassetter (a cardiologist), and Dr. Charles Phillips (an intensivist) (collectively, “EIRMC providers”). In that action, Rich's claims against the EIRMC providers failed because they were filed after the statute of limitations expired. Rich alleged in this action that those claims were not filed on time because of Respondents’ legal malpractice. Both sides filed substantive motions for summary judgment and the district court found that Rich could not prevail because she had “not disclosed any expert [medical] testimony which complies with the requirements of Idaho law for admissibility.” The district court concluded that, lacking evidence to “set out a prima facie case of medical malpractice,” in the underlying case, Rich’s claim against Respondents for legal malpractice failed. Rich appealed. The Idaho Supreme Court found no reversible error and affirmed. View "Rich v. Hepworth Holzer" on Justia Law