Justia Idaho Supreme Court Opinion Summaries

This case arose from a medical malpractice action involving a partial foot amputation and sentinel lymph node biopsy (“SLNB”). John Beebe was diagnosed with aggressive melanoma on his foot. After his diagnosis, oncology specialists recommended a forefoot amputation and a SLNB. The SLNB involved the removal of a lymph node near John’s stomach to assist the oncologist with staging the cancer. Both procedures were performed at North Idaho Day Surgery, LLC, d/b/a Northwest Specialty Hospital (“NWSH”), after which the removed forefoot was placed into a pathology specimen bag and the lymph node was placed in a specimen cup. Purportedly, both specimens were subsequently placed in a second sealed bag, which was then placed in a locked drop box at NWSH for pickup by Incyte Pathology, Inc. Two days after the surgeries, NWSH received notice from Incyte that the lymph node was missing. NWSH subsequently searched the operating rooms, refrigerators, and the dumpster, but did not find the missing specimen. The Beebes filed a complaint against NWSH for medical malpractice and negligence and against Incyte for simple negligence. They later amended their complaint to add Cheryl’s claim for loss of consortium. The Beebes appealed the jury verdict in favor of NWSH, arguing the district court erred when it granted summary judgment for NWSH and dismissed Cheryl’s loss of consortium claim prior to trial. The Idaho Supree Court vacated the jury verdict because the district court gave a “but for” jury instruction on the issue of proximate cause instead of a “substantial factor” instruction. Further, the Supreme Court reversed and remanded the district court’s grant of summary judgment and dismissal of Cheryl’s loss of consortium claim. View "Beebe v. North Idaho Day Surgery, LLC" on Justia Law

Christine and Thomas O'Holleran married in 2005. They had no children. In 2015, Christine filed for divorce and in her complaint alleged “[t]hat [Thomas] is guilty of physical and mental abuse toward [Christine], and such is sufficient that this marriage should be terminated at the fault of [Thomas].” In his response and counterclaim, Thomas requested a divorce on the grounds of habitual intemperance, extreme cruelty, and irreconcilable differences. Christine subsequently moved to amend her divorce complaint to add a tort claim for emotional and physical abuse and requested damages in excess of $10,000. In his answer to Christine’s amended complaint, Thomas asserted an affirmative defense arguing that the magistrate court lacked jurisdiction to hear Christine’s tort claim. The magistrate court granted Christine’s motion to amend her complaint. The magistrate court held a bench trial on the claims asserted in the Amended Complaint, granting the divorce on grounds of irreconcilable differences, divided the parties’ real and personal property, and awarded Christine spousal maintenance. The decision did not address Christine’s tort claim. Thomas and Christine both filed motions to reconsider, but neither mentioned the magistrate court’s lack of findings and conclusions regarding Christine’s tort claim. Similarly, the magistrate court did not address Christine’s tort claim in its order denying reconsideration. The issue on appeal to the Idaho Supreme Court was whether the magistrate court had authority to decide a tort claim by one spouse against another as an ancillary matter to a divorce proceeding. The Supreme Court determined Idaho Code sections 1-2208 and 1-2210 and I.C.A.R. 5 limited the case types that could be assigned to magistrate courts to those specified in the Seventh Judicial District’s order on local rules. That order did not give the magistrate court authority to decide civil cases seeking damages in excess of $10,000. Nor was the tort claim an ancillary matter to the divorce proceeding. Accordingly, the district court erred when it determined the magistrate court had authority to decide Christine’s tort claim. View "O'Holleran v. O'Holleran" on Justia Law

Treasure Valley Home Solutions, LLC, (“TVHS”) filed a complaint against Richard Chason alleging breach of contract and requesting specific performance of a real estate purchase contract after Chason refused to move forward with the transaction. Chason moved for summary judgment, arguing the Agreement lacked definite terms and was therefore unenforceable. The district court granted Chason’s motion for summary judgment after concluding the Agreement was a mere “agreement to agree.” The district court also awarded Chason attorney fees. TVHS appealed both orders. The Idaho Supreme Court concluded after review that the district court did not err when it granted Chason’s motion for summary judgment because a valid contract was never formed between the parties. However, the district court erred when it awarded Chason attorney fees pursuant to Idaho Code section 12-120(3) because the evidence did not establish that a commercial transaction was the gravamen of the claim between TVHS and Chason. Neither party was awarded attorney fees or costs on appeal. View "Treasure Valley Home Solutions, LLC v. Chason" on Justia Law

In this appeal, the issue presented was whether a contract for the sale of business assets also contained language conveying an enforceable leasehold interest in real property in favor of the buyer. At summary judgment, the district court determined that the Ellis Family Trust owned the real property underlying this leasehold dispute, and that the contract selling the assets of Pullover Prints Corporation (“PPC”) to 616, Inc. (“616”) did not convey a leasehold interest to 616 because material terms necessary to form a valid and enforceable lease were missing. Instead, the district court concluded that the contract involving the sale of assets only contained an “agreement to agree” on the terms of a written lease at a later date. Accordingly, the district court entered judgment in favor of the Ellis Family Trust. 616 appealed, arguing that all material terms necessary to form a valid and enforceable lease could be found within the asset contract. Respondents PPC, Mae Properties, LLC (“Mae”), and Ellis in his individual capacity and in his capacity as trustee for the Ellis Family Trust, cross-appealed the district court’s decision regarding their collective motion for attorney fees. Finding no reversible error in either the appeal or cross-appeal, the Idaho Supreme Court affirmed. View "616 Inc. v. Mae Properties, LLC" on Justia Law

This appeal arose from a district court’s decision denying a motion for sanctions and attorney fees against Roy Gilbert’s former attorney, William Mitchell. The underlying litigation giving rise to the sanctions request stemmed from a dispute over a medical transport business and the business relationship between Gilbert and Richard Radnovich. Gilbert was the sole member of two LLCs: Resilient Transportation Leasing, LLC, and Resilient Transport LLC. According to Gilbert’s complaint, Radnovich was allegedly the owner of two business entities: Injury Care Emergency Medical Services (ICEMS) LLC and “Injury Care EMS,” as well as other entities not at issue in this appeal. In 2017, Gilbert executed an agreement purporting to sell Resilient Transport, LLC, to Injury Care EMS, LLC. According to Gilbert, Injury Care EMS, LLC, was never formed. Gilbert alleged that this “fictitious” LLC was an alter ego of Radnovich. The parties signed a supplement to the agreement which amended the business name for ICEMS, LLC to ICEMS, P.C, and clarified that Resilient Transport, LLC, would be subsumed by ICEMS, P.C. into another fictitious business called “Resilient Transport Operated by Injury Care EMS,” and that Resilient Transport, LLC would later be dissolved. Following a breakdown in both the agreement and the relationship, Gilbert sued Radnovich and the business entities. Mitchell filed the initial and amended complaint on behalf of Gilbert against Radnovich. Later in the proceedings, a second attorney substituted for Mitchell and soon after, both sides stipulated to dismiss the case with prejudice. A few weeks later, Radnovich filed a motion for sanctions and attorney fees against Mitchell. The district court denied the motion. Radnovich appealed, arguing the district court abused its discretion in denying sanctions and attorney fees against Mitchell. Finding no reversible error or abuse of discretion, the Idaho Supreme Court affirmed the district court’s decision. View "Gilbert v. Radnovich" on Justia Law

Ross Lamm and Leslie Preston each began separate businesses during their marriage. After Lamm filed for divorce from Leslie Preston, they stipulated to a custody and support order for their children, as well as the division of most of their marital estate; however, they could not reach an agreement on the valuations of their respective businesses. Following a bench trial, the magistrate court determined that the couple’s 25% interest in one of those businesses, Black Sage Acquisition, LLC, was worth $163,373 based on its fair market value. All remaining value was found to be Lamm's personal goodwill. Preston first appealed the magistrate court’s valuation and division of certain business assets in her divorce proceedings to the district court, which upheld the magistrate court’s ruling. She then appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the magistrate court's order. View "Lamm v. Preston" on Justia Law

This appeal arose from a contempt order entered against Jeff Katseanes (“Jeff”) and an order of disgorgement entered against his attorney, Justin Oleson. As part of a divorce agreement between Judy Katseanes, now Judy Yancey (“Judy”), and Jeff, Jeff was required to pay Judy spousal support. Following several years of insufficient payments, Judy filed a lawsuit to seek enforcement of spousal support. During the proceedings, the district court orally granted Judy’s request for a Qualified Domestic Relations Order (“QDRO”) assigning Judy 100% of Jeff’s 401k plan. After the court orally issued its order in open court, but before the district court signed a written order reflecting the oral ruling, Jeff withdrew all of the funds from the 401k. The district court ordered Jeff to return the funds and provide an accounting. When the accounting was not timely provided, the district court held Jeff in criminal contempt and sentenced him to five days in jail. The court also granted an order of disgorgement against his attorney after discovering Jeff’s attorney fees had been paid with funds from the 401k. Jeff appealed to the Idaho Supreme Court, arguing the order of contempt and order of disgorgement were improper because the QDRO did not become effective until the written order was signed by the court. Finding no reversible error, the Supreme Court affirmed. View "Katseanes v. Katseanes" on Justia Law

The issue this case presented for the Idaho Supreme Court's review centered on whether the Idaho Constitution protects abortion from the legislature's broad power to enact laws concerning the public’s health, welfare, and safety. Planned Parenthood Great Northwest, Hawaii, Alaska, Indiana, Kentucky, and Caitlin Gustafson, M.D., on behalf of herself and her patients (collectively “Petitioners”), brought three petitions, each seeking a writ of prohibition and declaratory relief blocking implementation and enforcement of recently enacted laws in Idaho. Petitioners also raised various facial challenges, claiming these laws offend important constitutional principles, such as equal protection, due process, the special laws provision, the separation of powers doctrine, and purported “informational privacy” protections under the Idaho Constitution. Petitioners further claimed that the Idaho Human Rights Act limited the legislature’s ability to regulate abortion through the Total Abortion Ban and 6-Week Ban. After careful consideration of the issued raised, the Idaho Supreme Court denied Petitioners’ requests for extraordinary writs of prohibition and declaratory relief. View "Planned Parenthood Great Northwest, et al. v. Idaho" on Justia Law

This issue this appeal raised for the Idaho Supreme Court's review centered on the proper legal standards for assessing discovery sanctions against trial counsel, and for proving the character of property during divorce proceedings. Appellant Josh Erickson argued the magistrate court erred by applying the community property presumption to three retirement accounts he owned prior to marriage. Josh argued he failed to produce documents during discovery that could have established these accounts were his separate property because the Respondent Amy Erickson, did not give timely notice that she was seeking an interest in the retirement accounts. Josh argued the magistrate court then imposed inequitable sanctions at trial for his alleged discovery violations by preventing him from presenting evidence relevant to the claims Amy was permitted to make outside the discovery window. Josh appealed the magistrate court’s decision to the district court, which affirmed. After review, the Supreme Court affirmed the district court’s determination that Josh failed to establish that the retirement accounts were his separate property. The Court reversed the district court’s denial of Amy’s request for attorney fees and remanded for consideration on the merits. View "Erickson v. Erickson" on Justia Law

In 2019, an Idaho district court granted Respondents Matthew and Bonnie Latvalas’ claim for a prescriptive easement over a road known as “South Camp Bay Road” to reach their property located on the shores of Lake Pend Oreille. Because the prescriptive easement was created by the operations of an active mine, the district court determined that the scope of the easement included the ability to transport labor and materials to build a home on the Latvalas’ property. In Latvala v. Green Enterprises, Inc., 485 P.3d 1129 (2021) (Latvala I), the Idaho Supreme Court affirmed the district court’s determination that the Latvalas had a prescriptive easement over South Camp Bay Road. However, the Court vacated the district court’s judgment after concluding it had impermissibly expanded the scope of that easement. On remand, the parties disputed whether the Supreme Court’s decision prohibited the Latvalas’ proposed residential use of South Camp Bay Road, or only the construction of a residence on the Latvalas’ property. The district court entered a second amended judgment that prohibited the Latvalas from using South Camp Bay Road to construct a residence on their property, but did not restrict the Latvalas from using the road for residential purposes. Appellants Green Enterprises, Inc., James and and Julie Frank, and Larimore and Kathryn Cummins (neighboring landowners) timely appealed. Finding no reversible error in the latter district court judgment, the Supreme Court affirmed: “Because possibly driving across South Camp Bay Road will do nothing to increase the burden on the servient landowners, we affirm the district court’s second and third amended judgments because they are consistent with our holding in Latvala I. The Latvalas may not use South Camp Bay Road to build a residence; they may drive along Camp Bay Road to access a residence. Whether and to what extent that burden may or could change in the future is a question for another day. On the record before us we will not hypothesize on what the outcome would be under those theoretical scenarios.” View "Latvala v. Green Enterprises, Inc." on Justia Law