Justia Idaho Supreme Court Opinion Summaries

Wade Chapman (“Wade”) and his six siblings (“Siblings”) were the children of Wilford (“Bill”) Chapman. Bill had a life insurance policy for $7,000,000 that named the Chapman Family Multiple Power Liquidity Trust (“Trust”) as its owner. Wade, along with Siblings, were named as the Trust’s beneficiaries. Wade was also named a trustee. After Bill passed away, Wade learned that he was listed as the sole beneficiary of the life insurance policy and retained the entirety of the death benefit for himself. Siblings sued Wade for breach of fiduciary duty, among other causes of action, arguing that the policy was a Trust asset, and its proceeds should have been distributed equally among them. The district court agreed and granted summary judgment in favor of Siblings. It also awarded prejudgment interest against Wade under Idaho Code section 28-22-104 and attorney fees under Idaho Code section 15-8-201, a provision of the Trust and Estate Dispute Resolution Act (“TEDRA”). The Idaho Supreme Court affirmed the district court’s grant of summary judgment to Siblings, affirmed in part and reversed in part the award of prejudgment interest, and reversed the grant of attorney fees to Siblings under TEDRA. View "Vouk v. Chapman" on Justia Law

Deborah Dorr requested to reopen an unemployment appeal hearing that was to address Dorr’s appeal of the Idaho Department of Labor’s (“IDOL”) decision denying Dorr’s request to backdate her Pandemic Unemployment Assistance claim. After Dorr failed to appear at the hearing, IDOL dismissed her appeal and subsequently denied her request to reopen the hearing. Dorr appealed IDOL’s denial of her request to reopen, and the Idaho Industrial Commission (“the Commission”) affirmed. The Commission determined due process was satisfied and agreed with IDOL that Dorr’s own negligence was insufficient cause to reopen the hearing. Appealing pro se, Dorr petitioned the Idaho Supreme Court for relief. The Supreme Court concluded Dorr’s briefing did not meet the standard for an appeal under Idaho Appellate Rule 35(a)(6) and as such, her arguments were forfeited. The Commission’s decision upholding the Appeal Examiner’s denial of Dorr’s request to reopen her appeal hearing was affirmed. View "Dorr v. IDOL" on Justia Law

Mother Jane Doe appealed a magistrate court's judgment granting a petition to terminate her parental rights to her two minor children, Jane Doe I and John Doe I (the children). The magistrate court determined that Mother had neglected the children as defined in Idaho Code section 16-2002(3)(b), and that termination was in the best interests of the children. On appeal, Mother argued the definition of “neglect” provided in section 16-2002(3)(b) violated the Idaho and the United States Constitutions, and she argues that the magistrate court’s finding that termination was in the children’s best interests was not supported by substantial and competent evidence. After its review of the magistrate court record, the Idaho Supreme Court found the magistrate court found, by clear and convincing evidence that Mother’s parental rights should be terminated. That decision was supported by substantial and competent evidence in the record. It was therefore affirmed. View "IDHW v. Jane Doe" on Justia Law

This appeal arose from an Idaho district court decision affirming a declaratory ruling issued by Respondent Dave Jeppesen (the Director) in his capacity as Director of the Idaho Department of Health and Welfare (the Department). Appellant Grace at Twin Falls, LLC (Grace), a residential assisted living and memory care facility, partnered with a preferred pharmacy to offset costs associated with a software system that coordinated the tracking and delivery of residents’ prescription medications. Because residents who failed to choose the preferred pharmacy did not receive the offset, Grace sought to charge those residents an additional $10.00 each month to cover the difference. Grace brought a petition for declaratory ruling to the Department, asking the Director to declare that Idaho Code section 39-3316(12)(b) and IDAPA 16.03.22.550.12.b did not prohibit Grace from charging the $10.00 fee to those residents who did not choose the preferred pharmacy. The Director denied the petition, declaring that Grace would not “be permitted to assess a non-preferred-pharmacy fee as such fee violates residents’ right to choose their pharmacy or pharmacist . . . .” Grace sought judicial review before the district court, which affirmed the Director’s declaratory ruling. Grace then appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the district court. View "Grace at Twin Falls, LLC v. Jeppesen" on Justia Law

Nathaniel Sheehan lost his job during the COVID-19 pandemic. He applied for and began receiving unemployment benefits. This appeal arose out of the Idaho Department of Labor’s (“IDOL”) later determination that Sheehan was: (1) ineligible for unemployment benefits; and (2) required to repay the benefits he had already received. Sheehan represented himself throughout this case. He appealed these decisions to the Idaho Industrial Commission (“Commission”), claiming he had received misleading instructions concerning notice from IDOL. The Commission dismissed his appeal and later denied his motion for reconsideration. Sheehan then appealed to the Idaho Supreme Court. "While Sheehan presents a poignant story rife with compelling circumstances, we are bound to follow the rules and law of jurisdictional authority." The Court affirmed the Idaho Industrial Commission. View "Sheehan v. Sun Valley Company" on Justia Law

Robert Fulfer, while making a delivery, exited his truck and stepped down into a nine-inch-deep pothole, resulting in serious personal injuries. He was working for Ruan Logistics Corporation (“RLC”), which was contracted as a transportation and cargo-hauling provider by Sorrento Lactalis, Inc. (“SLI”). Fulfer filed a personal injury action against SLI seeking damages based on premises liability and negligence. SLI moved to dismiss pursuant to Idaho Rules of Civil Procedure 12(b)(6) and 12(c), arguing that it was immune from a tort action because it was a statutory employer of Fulfer, meaning that Idaho’s Workers’ Compensation laws provided Fulfer’s exclusive remedy. In response, Fulfer argued that an exception to the exclusive remedy rule applied. The district court determined Fulfer’s complaint failed to state a claim upon which relief could be granted because he: (1) failed to comply with Idaho’s notice pleading requirements by not addressing statutory employer immunity; and (2) failed to allege specific facts required for establishing an exception to the exclusive remedy rule based on the Idaho Supreme Court’s decision in Gomez v. Crookham Co., 457 P.3d 901 (2020), which was controlling at the time. Accordingly, the district court dismissed Fulfer’s complaint without prejudice and later denied Fulfer’s motion to reconsider and for leave to file a second amended complaint. Fulfer appealed. The Supreme Court determined the district court erred in dismissing Fulfer’s first amended complaint pursuant to Idaho Rule of Civil Procedure 12(b)(6) because it satisfied Idaho’s pleading requirements. Further, the Supreme Court concluded the exception to the exclusive remedy rule in I.C. 72-209(3) applied to direct and statutory employers. The case was remanded for further proceedings. View "Fulfer v. Sorrento Lactalis, Inc." on Justia Law

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