Justia Idaho Supreme Court Opinion Summaries

Mandy and Dan Valentine divorced in 2015. In 2017, Mandy petitioned the magistrate court for an order modifying the child custody and support provisions of the divorce decree. The magistrate court did not modify the custody provisions in the decree but concluded that substantial and material changes in circumstances existed to justify modifying the child support order. Mandy appealed several aspects of this ruling to the district court. The district court, sitting in an appellate capacity, affirmed in part and reversed in part the magistrate court’s order. On appeal to the Idaho Supreme Court, Mandy challenged the district court’s conclusion that her student loans and several other sources of income could be combined to calculate her income under the Idaho Child Support Guidelines. Dan cross-appealed, challenging the district court’s conclusion that the magistrate court abused its discretion in calculating his pro rata share of childcare expenses. The Supreme Court determined that while the district court correctly interpreted the Idaho Child Support Guidelines to require the inclusion of gross and, if applicable, potential income in the calculation of Guidelines Income, it erred in concluding that the magistrate court’s failure to make a finding that Mandy was voluntarily unemployed or underemployed before imputing potential income to her was harmless. Second, the district court erred in determining that the magistrate court abused its discretion in ordering Dan to pay his pro rata share of childcare expenses after subtracting the amount of Idaho Child Care Program benefits Mandy received from the total costs. View "Valentine v. Valentine" on Justia Law

Mike Von Jones (“Jones”) appealed the denial of his motion to set aside a sheriff’s sale and the award of attorney fees to Safaris Unlimited LLC (“Safaris”) under Idaho Code section 12-120(5). A jury found there was an enforceable contract between Jones and Safaris, and that Jones breached the contract. Safaris petitioned for and obtained a writ of execution requiring the sheriff to execute upon Jones’s personal and real property, including a pending lawsuit against Jeremy Sligar and Overtime Garage, LLC. At the sheriff’s sale, Safaris (the only bidder present) bought the lawsuit for $2,500.00 via a credit bid. Although Jones received notice of the sheriff’s sale, neither Jones nor his representative attended. Jones did, however, file a motion to set aside the sheriff’s sale of the Sligar Lawsuit. Then Safaris executed on additional personal property of Jones. The sale returned $8,300.00. While both Jones’s and Safaris’ appeals were pending, Jones tendered a $119,238.04 check to the clerk of the court in an attempt to satisfy the remainder of the amended judgment. The district court granted Safaris’ motion for release of funds and determined that the deposited funds were sufficient to satisfy the amended judgment. However, the district court found that the deposited funds exceeded the amount owed by $2,500.00 because Jones’s tender did not account for Safaris’ credit bid to purchase the Sligar Lawsuit. The district court held that Jones had not demonstrated a gross inadequacy of consideration because he failed to establish the litigation’s approximate value. Similarly, Jones failed to show very slight additional circumstances because he could not point to any procedural irregularities “pertaining to either the notice or conduct of the sale.” After denying Jones’s motion to vacate the sheriff’s sale, the district court ordered the clerk of the court to release the remaining $2,500.00 from the tender back to Jones or his attorneys. Jones timely appealed, arguing: (1) the district court erred by concluding Jones’s monetary tender to the clerk of the court did not preclude Safaris from claiming ownership of Jones’s pending lawsuit; (2) the district court abused its discretion by denying his motion to set aside the sheriff’s sale; and (3) the district court erred in awarding costs and fees pursuant to section 12-120(5) for actions taken after Jones’ tender to the clerk. Finding no reversible error, the Idaho Supreme Court affirmed the district court's orders. View "Safaris Unlimited, LLC v. Jones" on Justia Law

Appellants sued Respondents over alleged self-dealing and other purported breaches of fiduciary duty in the administration of a trust. Respondents argued that proceedings in Idaho were improper under the provisions of Title 15, chapter 7 of the Idaho Code (the “trust code”) because they alleged that the principal place of the Trust’s administration was in Indiana. The district court agreed and dismissed Appellants’ complaint. After review, the Idaho Supreme Court determined the district court erred in granting the motion to dismiss. Judgment was reversed and the matter remanded for further proceedings. View "Allen v. Campbell" on Justia Law

Terry and Xiomara Robirds married in Taos, New Mexico in 2004. Prior to the marriage, Terry worked for Halliburton and ConocoPhillips. He participated in employer sponsored retirement plans with both employers. In 2007, Terry and Xiomara purchased a residence in Rigby, Idaho. Xiomara’s name was not listed on the warranty deed, and she executed a quitclaim deed to Terry on June 4, 2007. The seller issued a warranty deed to Terry on June 6, 2007. Xiomara filed for divorce on the grounds of irreconcilable differences in September 2016, and Terry counterclaimed on the same grounds. Xiomara was not proficient in English. The parties attended mediation with a Spanish speaking mediator for Xiomara and reached a partial agreement as to custody, support, and visitation for their only child, but did not resolve the issue of property distribution. Then prior to trial, the parties reached a settlement regarding property division. The record was not clear as to whether Xiomara had an interpreter during the negotiations that resulted in the Property Settlement. Xiomara claimed she did not. Terry averred a Spanish speaking mediator was assigned but did not specifically allege that an interpreter was present during the negotiations which led to the Property Settlement. The divorce decree, entered August 2017 (“Decree”), incorporated the Property Settlement as Exhibit B. Terry appealed the district court’s decision on intermediate appeal, which affirmed the decision of the magistrate court to: (1) set aside a stipulated judgment regarding property distribution; and (2) characterize all of Terry’s retirement accounts as community property, to be divided equally as of the date of divorce. On appeal, Terry argued that the district court erred in affirming the magistrate court’s rulings and in failing to award Terry attorney fees on intermediate appeal. Finding no reversible error, the Idaho Supreme Court affirm the district court. View "Robirds v. Robirds" on Justia Law

In July 2015, R.N. went boating on Lake Coeur d’Alene with his friends, C.N. and B.L. All three boys were sixteen years old at the time. The boat was owned by C.N.’s father. C.N., B.L., and R.N. obtained about 12 beers from an unknown source and consumed them while boating. Later, the boys stopped at Shooters, a restaurant and bar near the south end of the lake. Respondent Tracy Lynn allegedly provided C.N., B.L., and R.N. with an alcoholic drink known as a “Shooter sinker” (also known as a “derailer”). The boys left the restaurant and drank the derailer on the lake. At some point during the trip, R.N. jumped or fell off the boat into the water and drowned. Appellant-plaintiffs Brandi Jones (R.N.'s mother), and Dasha Drahos (R.N.'s sister) filed a complaint against Lynn, alleging she recklessly and tortiously caused R.N.’s death by providing him with alcohol before he drowned in Lake Coeur d’Alene. Lynn moved for summary judgment, asking the district court to dismiss the case because the Plaintiffs failed to comply with the notice requirements under Idaho’s Dram Shop Act. The district court agreed and granted Lynn’s motion for summary judgment after concluding there was no uniform body of federal maritime dram shop law that would preempt Idaho’s Dram Shop Act. Thus, the Plaintiffs had to comply with the Dram Shop Act’s notice requirements. The Plaintiffs appealed to the Idaho Supreme Court. Finding that the district court correctly applied with the Idaho Dram Shop Act after concluding the Act did not conflict with any uniform federal common law, and that the district court did not err in finding Appellants' claims were barred because they did not comply with the Dram Shop Act, the Supreme Court affirmed the grant of summary judgment. View "Jones v. Lynn" on Justia Law

Peyton Gifford and Mollie Gabaldon (“Parents”) filed a complaint as individuals, guardians ad litem for their son, and putative class representatives, alleging that the West Ada Joint School District #2 (“West Ada”) illegally charged tuition fees for the second half-day of kindergarten instruction. The district court dismissed Parents’ complaint for lack of standing because Parents did not pay the allegedly illegal fees. On appeal, the Idaho Supreme Court held that although the district court properly concluded that Parents lacked standing to pursue a claim based solely on an economic injury, it failed to consider whether Parents had standing to assert a second, discrete injury: loss of educational opportunity for their son. Accordingly, the Court concluded Parents had standing to pursue their educational claims. View "Gifford v. West Ada Joint School District #2" on Justia Law

The issue this appeal presented for the Idaho Supreme Court's review centered on a farm lease between Walker Land & Cattle, LLC, (“Walker”) and Sometimes a Great Notion Land and Cattle Company (“SAGN”). The lease agreement required Walker, as tenant, to obtain insurance coverage on “improvements” to the Ririe Farm, which SAGN, as landlord, contended included the property’s five irrigation pivots. The district court granted summary judgment to SAGN, concluding that under the lease agreement irrigation pivots were improvements and Walker defaulted on the lease by failing to provide insurance on the pivots. On appeal, Walker raised several related issues, primarily contending that genuine issues of material fact barred granting summary judgment. Finding no reversible error, however, the Idaho Supreme Court affirmed the award of summary judgment by the district court. View "Stanger v. Walker Land & Cattle" on Justia Law

Brent Meyer appealed pro se a district court’s judgment granting Adam Walker’s breach of contract claim against him. Walker hired Meyer to assist him with the demolition and remodel of a home he had purchased in Soda Springs, Idaho. Walker alleged that in June 2018, the parties entered into an agreement in which Walker agreed to pay Meyer $18,000 in exchange for Meyer’s labor on the home. This contract was subsequently modified by the parties as Meyer performed work on other areas of the home not covered by the contract and Walker paid Meyer more money than provided in the original contract – roughly $60,000. On October 16, 2018, Walker fired Meyer from the job, alleging the labor was not up to industry standards and did not add value to the home. Walker hired another contractor to fix or redo the work completed by Meyer and his subcontractors. Meyer argued the district court erred in concluding he was not a “construction professional” as defined by Idaho’s Notice and Opportunity to Repair Act (“NORA”), Idaho Code sections 6-2501–04, and claimed the case should have been dismissed because Walker failed to comply with the notice requirement of NORA. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Walker v. Meyer" on Justia Law

Eric Christiansen filed a nine-count complaint against respondents, Michael Moser and Potlatch #1 Financial Credit Union (“P1FCU”), following a decision by the Lewiston Roundup Association (“LRA”) to discontinue contracting with Christiansen to produce motorsport events at the LRA’s facility. The complaint alleged that Moser, a P1FCU employee and LRA member, improperly accessed information from Christiansen’s P1FCU account and shared it with the LRA so that it could recreate his business model and produce motorsport events without him. The district court granted summary judgment in the Respondents’ favor on each of Christiansen’s claims. Christiansen appealed, arguing that the district court erred in granting summary judgment because it failed to rule on Christiansen’s motion to compel discovery, failed to grant Christiansen more time to complete discovery, and failed to conclude that genuine issues of material fact precluded dismissal of four of Christiansen’s claims. The Idaho Supreme Court concluded after review that the district court abused its discretion by failing to decide Christiansen’s motion to compel discovery before considering the Respondents’ motions for summary judgment. Accordingly, judgment was reversed and the matter remanded for further proceedings. View "Christiansen v. Potlatch #1 FCU" on Justia Law

Mary Eich appealed a district court judgment ordering her to vacate property owned by the trustees of the Wilbur Eich and Henrietta Eich Revocable Trust (the “Trust”). In 2015, Mary filed an action seeking to quiet title to 2.5 acres of an 80-acre tract of real property owned by her father, who held title to the property as trustee of his Trust. Mary alleged that her parents had gifted her the 2.5 acres with the intent that she build a home and reside there for the rest of her life. On cross-motions for summary judgment, the district court ruled that there was no valid transfer between Mary and her parents, but permitted Mary to pursue an equitable claim of promissory estoppel. After a bench trial, the district court ruled in favor of Mary and that she had a year to obtain Teton County’s approval to partition the 2.5 acres from the remaining Trust property. If she could not do so within the time prescribed, the Trust would have to pay Mary $107,400 for the value of improvements she had made on the land plus her reasonable relocation costs, and Mary would have to vacate the property. Mary worked for several years to separate the 2.5 acres from the remaining Trust property to no avail. In August 2019, the Trust moved to compel enforcement of the district court’s alternative remedy and for entry of final judgment. In January 2020, a newly assigned district court judge granted the Trust’s motion and entered a declaratory judgment ordering the Trust to pay Mary $107,400, plus reasonable relocation expenses, and for Mary to vacate the property. Mary appealed, arguing that the newly assigned district court judge abused his discretion by deviating from the original judge’s equitable remedy. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s decision ordering Mary to vacate the property and for the Trustees to pay Mary $107,400. View "Eich v. Revocable Trust" on Justia Law