Justia Idaho Supreme Court Opinion Summaries

Neurosurgeon Donald Blaskiewicz, M.D. went to work for the Spine Institute of Idaho (the “Spine Institute” or the “Institute”) in 2018. The Spine Institute entered into a Professional Services Agreement (the PSA) with Blaskiewicz containing a non-compete clause, contractually proscribing Blaskiewicz from practicing medicine within fifty miles of the Spine Institute’s office (with an explicit exception for Caldwell) for a period of eighteen months, should his employment with the Spine Institute be terminated for any reason. Pursuant to the PSA, Blaskiewicz had two ways to avoid the non-compete clause: he could either get permission from the Spine Institute to practice medicine within the proscribed area, or he could pay the Spine Institute $350,000 in “liquidated damages.” The PSA also required any disputes to be resolved by arbitration. Less than a year and a half after hiring Blaskiewicz, the Spine Institute terminated his employment. Blaskiewicz filed suit in district court, seeking a declaratory judgment that the non-compete clause was unenforceable. The district court concluded that the non-compete clause was against public policy and void as a matter of law, and granted summary judgment in favor of Blaskiewicz. The Idaho Supreme Court reversed, finding the district court did not cite or analyze the statutes governing non-compete agreements in Idaho. The Court concluded there were genuine issues of material fact such that summary judgment was inappropriate as to whether the non-compete provision was void as a matter of public policy or otherwise enforceable. View "Blaskiewicz v. Spine Institute of Idaho" on Justia Law

The issue this case presented for the Idaho Supreme Court's review centered on the scope of a statutory ditch right-of-way, whether a prescriptive easement could be obtained for overspray from an irrigation pivot, and whether a license agreement could bind succeeding property owners. Historically, the Lavertys flood irrigated their property. In 1999, a pivot irrigation system was constructed on the land now owned by the Chesters. The pivot was designed to intentionally spray water onto parcels 2 and 3 to maximize the irrigation coverage on the Chesters’ property. Irrigation water for that pivot (and for flood irrigation before it) was delivered to the Chesters’ property from the Gini canal through a series of ditches. Parcels 2 and 3 were subject to a ditch easement provided for in a deed executed between the Lavertys and Bevilaqua in 1986 (the “Confirmation Deed”); the Chesters were the Lavertys’ successors in interest with respect to the ditch easement discussed in the Confirmation Deed. In 2009, Dolly Smith, another former owner of parcels 2 and 3, installed a ten-inch diameter culvert in a portion of the North ditch. The Chesters disagreed with the size of the pipe and executed and recorded a license agreement with Smith to govern the installation of a new culvert. In October 2016, Wild Idaho purchased parcels 2 and 3. The relationship between Wild Idaho’s owner, Kyle Arneson, and the Chesters quickly soured. Various disputes between the parties led to Arneson restricting the Chesters’ access to Wild Idaho’s property in the spring of 2017. The Supreme Court concluded the district court's order defining the scope of the Chesters' ditch right-of-way was affirmed in part and reversed in part. The Court found the district court erred in denying the Chesters’ prescriptive easement defense to Wild Idaho’s nuisance and trespass claims. But the district court did not err in striking the license agreement as an unreasonable cloud on Wild Idaho’s title. View "Chester v. Wild Idaho Adventures RV Park, LLC" on Justia Law

Karen and Keith Hood owned real property in Washington County, near Cambridge, Idaho. The Hoods’ property was near property owned by Gayle and Paul Poorman and Rusty Anderson. The Hoods’ property had three decreed appurtenant water rights; the water from two of these water rights was diverted from Rush Creek and conveyed to the Hoods’ property through an irrigation ditch (“the Hood ditch”). The crux of this case involved that portion of the Hood ditch which ran through the Poormans’ and Anderson’s properties. The Hoods filed a complaint in November 2019, seeking to have the district court: (1) enjoin the Poormans and Anderson from interfering with their maintenance of the Hood ditch right-of-way; (2) declare the Hoods’ rights with respect to the right-of-way; and (3) award damages against the Poormans and Anderson for damage done to the Hood ditch right-of way. Anderson sought to have the Hoods reinstall a bridge over the ditch on Anderson’s property. The Poormans asked the district court to require the Hoods to replace removed culverts on the Poormans’ property, and refrain from removing trees and other vegetation outside the scope of the Hood ditch right-of-way. The Poormans also requested monetary compensation for damage to their property as a result of the Hoods’ ditch maintenance, including the removal of trees and vegetation. The district court issued a written decision granting the Hoods’ motion for partial summary judgment that incorporated the limitations proposed by the Poormans and Anderson. The Idaho Supreme Court affirmed in part and reversed in part the district court's judgment. The Supreme Court found that while the district court did not abuse its discretion in choosing to enjoin the Hoods from excessively accessing the right-of-way, some of the district court’s specific limitations on when the Hoods could access the right-of-way were an abuse of discretion because they were either unsupported by evidence in the record or contradicted by the evidence presented at trial. On remand, the Supreme Court gave the district court a mandate to issue two judgments: one defining the purpose, length, width, and location of the primary easement to run with the land and bind the parties’ successors-in-interest; the second second to identify the injunctive relief limiting the Hoods’ exercise of their secondary easement rights and include the declaratory and monetary relief awarded, not to run with the land or bind the Hoods’ successors-in-interest. View "Hood v. Poorman" on Justia Law

Donald and Marjorie Woodfin married in 1997. At the time, Donald had two adult children, Kathleen (Kathy) Gestner and Ray Woodfin, and Marjorie had two adult children, Julie Divine and Colleen Shiras. Donald and Marjorie created the Woodfin Family Trust, a revocable trust, in 1999. Upon the death of the surviving spouse, the 1999 Trust identified the primary beneficiaries as Ray, Kathy, Colleen, and Julie, who would receive a sum of money and any remaining assets in equal shares if either or both settlors were deceased. Marjorie amended the Trust several times following Donald’s death. In 2002, Marjorie’s changes included adding additional successor trustees. Marjorie was diagnosed with breast cancer in 2017. Julie drove Marjorie to meet with attorney Robert Green in Coeur d’Alene regarding another trust amendment. Green met with Marjorie alone. In the meeting, Marjorie explained that she was disappointed in her stepchildren because she believed they had treated her poorly since Donald’s death. Marjorie died on October 12, 2018, at age 92. After learning about Marjorie’s passing, Kathy called Julie to inquire about the Trust and Julie sent Kathy and Ray the May 29, 2018, letter. Kathy and Ray subsequently filed a complaint seeking declaratory relief. Kathy and Ray requested the district court to declare the 2018 amendments were void due to Julie’s undue influence and order Julie to distribute $100,000 to Ray and $100,000 to Kathy. Following a bench trial, the district court determined that the evidence “overwhelmingly supports a conclusion that Marjorie had full testamentary capacity when she amended the Trust on May 29, 2018.” Kathy and Ray timely appealed. Finding no reversible error, the Idaho Supreme Court affirmed judgment against Kathy and Ray. View "Gestner v. Divine" on Justia Law

A dispute over attorney fees arose from the probate proceedings of Eric Milo Hirning’s estate. Appellants challenged the district court’s affirmance of the magistrate court’s decision to allow the personal representatives to recover their legal expenses incurred in the administration of the estate, pursuant to Idaho Code section 15-3-720. The Appellants also challenged the attorney fees awarded to the Respondents on intermediate appeal pursuant to Idaho Code section 12-121. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Uzzle v. Estate of Eric Milo Hirning" on Justia Law

This appeal concerned a divorced parent’s decision to unilaterally relocate her child across international borders without: (1) prior notice to the other parent; or (2) leave of the court. Carla Gray appealed an Idaho magistrate court’s order that modified the existing custodial arrangement and required her to return the child to the United States. Finding no reversible error in the magistrate court's judgment, the Idaho Supreme Court affirmed. View "Gray v. Gray" on Justia Law

Erin Carver alleged that her ex-husband, William Hornish, consented to the marriage of their 16-year-old daughter (“Daughter”) in order to legally emancipate her and circumvent custody provisions in the parties’ divorce decree. Carver learned of the alleged scheme before it was accomplished and filed a motion to prevent Hornish from exercising legal authority to consent to Daughter’s marriage. However, the magistrate court did not rule on the motion before Daughter was married. Carver argued on appeal that the motion should have been granted retroactively, effective to a date before the marriage or, in the alternative, the statute allowing a minor to marry with the consent of only one parent should be declared unconstitutional. The Idaho Supreme Court rejected both arguments, affirming dismissal of Carver's petition because the magistrate court lacked subject matter jurisdiction over Daughter's custody and jurisdiction would not have been restored by granting Carver's motion for nunc pro tunc relief. Furthermore, the Court declined to rule on the constitutionality of the statute, Idaho Code section 32-202. View "Carver v. Hornish" on Justia Law

Desiree Horton served Andrew Horton with an Amended Complaint for Divorce in December of 2016. On June 15, 2017, in lieu of a trial, Desiree and Andrew entered into an oral stipulation on the record specifying how their community property would be divided between them. Because Desiree was employed as a teacher in Italy by the United States government and Andrew was a member of the United States military on active duty, the decree of divorce required specific language to be enforceable as to their respective retirement accounts. The magistrate court stated that, due to this specific language, it would “retain jurisdiction” with respect to the parties’ retirement accounts. A written judgment and decree of divorce was entered on February 26, 2018, and dated nunc pro tunc to June 15, 2017, the date of the parties’ oral stipulation. After later motions and hearings on behalf of both parties, an amended judgment and decree of divorce was entered on October 18, 2018. The later amended judgment and decree did not indicate it was being issued nunc pro tunc. Andrew appealed the decision to enter the amended judgment and decree of divorce to the district court. After oral argument, the district court agreed the magistrate court abused its discretion: (1) by deciding to remove the nunc pro tunc language from the initial judgment entered on February 26, 2018; (2) by requiring Andrew to obtain “Survivor Benefit Coverage” for Desiree; and (3) by excluding, over Andrew’s objection, language related to Desiree’s Federal Employee Retirement System account. The district court ordered that the amended judgment and decree of divorce entered in October 2018, be vacated and the case remanded to the magistrate court for various findings of fact and conclusions of law. Desiree appealed. The Idaho Supreme Court found only that the district court erred in concluding the magistrate court abused its discretion in deciding to reject Andrew’s requested language regarding the FERS account in the Amended Decree. The judgment was thus affirmed in part, reversed in part and the matter remanded for further proceedings. View "Horton v. Horton" on Justia Law

Christopher Luck, as legal guardian and conservator for Ethel Luck, appealed a district court’s dismissal of Ethel’s negligence claim against Sarah Rohel for injuries Ethel sustained in a car accident. On March 13, 2019, the last day before the applicable statute of limitations ran, Amy Clemmons, Ethel’s daughter, signed and filed a pro se Complaint against Rohel on Ethel’s behalf, alleging a single count of negligence. Ethel did not sign the Complaint. The same day, Ethel signed a durable power of attorney designating Clemmons as her attorney-in-fact. Clemmons was a licensed Washington attorney, who, at the time the Complaint was filed, was not licensed to practice law in Idaho. A little over a month later, Clemmons filed a pro se Amended Complaint, which continued to identify the same plaintiff, “AMY CLEMMONS, as Guardian for ETHEL LUCK.” Both Ethel and Clemmons signed the Amended Complaint. Rohel moved to strike the first complaint, arguing Clemmons, who was not licensed to practice law in Idaho, signed the Complaint. Rohel also moved to dismiss the complaint, arguing Clemmons had not been appointed as Ethel’s guardian, was not admitted to the Idaho State Bar and therefore, lacked authority to file the Complaint on Ethel’s behalf. Clemmons subsequently retained an attorney, who filed a notice of appearance on April 23, 2019. The notice of appearance failed to specify whether counsel appeared on behalf of Clemmons, Ethel or both. Counsel argued that Idaho law allowed Clemmons to act as a general guardian and as such, Clemmons was the real party in interest and could initiate a lawsuit pro se, on behalf of Ethel. Additionally, counsel argued that any deficiencies in the Complaint had been cured pursuant to Rule 11 because Ethel signed the Amended Complaint. The district court granted both of Rohel's motions, and Clemmons appealed. The Idaho Supreme Court vacated the district court's judgment, finding it erred in applying the rule of nullity to strike Clemmons' Complaint. The Supreme Court determined the caselaw the trial court used as grounds for its judgment was no longer applicable in light of subsequent amendments to Idaho Rule of Civil Procedure 11. In light of this holding, the Supreme Court remanded this matter to allow the district court to exercise its discretion and determine whether to allow Plaintiff Luck to cure the improper signature. View "Luck v. Rohel" on Justia Law

Brandon and Brandi Kelly married on April 20, 2015, and had a child on June 9, 2015. Brandon filed for divorce on May 30, 2017. This appeal primarily concerned their disputes regarding the division of property and attorney fees. Prior to marriage, Brandon and Brandi entered into a prenuptial agreement (“the PNA”) seeking to establish their rights to various items of property. Brandi and Brandon were represented by separate counsel during the negotiation and execution of the PNA. Before signing the PNA, Brandi reviewed Brandon’s 2014 tax return. Brandi’s attorney requested changes to the PNA’s definitions of separate and community property, which were made. Brandi expressly waived her right to review other financial documentation concerning Brandon’s assets and signed the PNA. During the pendency of the divorce action, and relevant to this appeal, Brandon filed four motions for partial summary judgment and Brandi filed two motions for partial summary judgment, each of which required interpretation of various provisions of the PNA. After review, the Idaho Supreme Court affirmed in part, and reversed in part, certain district court decisions with respect to the parties' PNA. The Supreme Court found the district court erred (1) in affirming the magistrate court’s decision that the PNA barred Brandi from requesting attorney fees for child custody, visitation and support matters; (2) in affirming the magistrate court’s summary judgment decision concluding that Brandon’s payments from EIRMC were his separate property; and (3) when it failed to vacate the award of attorney fees to Brandon for his contempt motions, but did not err when it affirmed the magistrate court’s other deductions from Brandi’s separate property award. View "Kelly v. Kelly" on Justia Law