Justia Idaho Supreme Court Opinion Summaries

Appellants Michael Allen, Camp Bench Holdings, LLC, Camp River Holding, LLC, and Campbell Farms, Inc., (collectively, “Allen”) appealed two different district court decisions: one in which attorney fees were not awarded to Allen, and one in which attorney fees were awarded against Allen. The Idaho Supreme Court reversed the district court’s determination that there was no prevailing party between Allen and Neil Campbell. Although the district court dismissed the claim against Campbell Contracting, Allen prevailed on the material terms of the agreement against Neil Campbell. On remand, the district court was instructed to award reasonable attorney fees to Allen based on the materials the parties previously filed. The Supreme Court affirmed the district court’s determination that Campbell Contracting was the prevailing party, but vacated the amount of the attorney fee and cost award and remanded the case so that the district court could respond to Allen’s objections and explain how applying the factors in Idaho Rule of Civil Procedure 54(e)(3) logically lead to the specific amount of fees and costs awarded in this case. Further, as the prevailing party on appeal, the Supreme Court awarded Allen attorney fees and costs associated with his appeal against Neil Campbell. View "Allen v. Campbell" on Justia Law

In 2015, Ralph Isom filed for bankruptcy. Ultimately, a bankruptcy trustee for the estate settled with Isom’s primary creditor, Farms, LLC (“Farms”). As part of the settlement, the bankruptcy trustee conveyed a ten-acre parcel from the bankruptcy estate to Farms. Isom was living on the ten-acre parcel at the time. When Isom refused to vacate the ten-acre parcel, Farms initiated this forcible detainer action. The magistrate court entered judgment for Farms and ordered Isom to vacate the ten-acre parcel. Isom appealed to the district court, but also vacated the property as the magistrate court had ordered. Because Isom had vacated, and thus no longer occupied or owned the ten-acre parcel, the district court held that Isom’s appeal was moot. Further, the district court rejected the merits of Isom’s appeal. Isom appealed the district court’s decision on the merits, but failed to appeal the district court’s holding that his appeal was moot. The Idaho Supreme Court found that because Isom failed to raise, let alone argue against, the district court’s decision as it related to mootness, the issue was considered waived."Isom’s waiver is dispositive. As a result, we will not reach the merits of his appeal as it relates to the sufficiency of proof regarding the forcible detainer action." Judgment was thus affirmed. View "Farms, LLC v. Isom" on Justia Law

The United States Court of Appeals for the Ninth Circuit certified a question of law to the Idaho Supreme Court. The federal court asked whether an Idaho state court order reducing a defendant’s judgment of conviction for felony burglary to a judgment of conviction for misdemeanor petit theft under Idaho Code 19-2604(2) changed the operative conviction for the purposes of Idaho Code 18-310, which prohibited the restoration of firearm rights to those citizens convicted of specific felony offenses. In 2019, defendant Antonio Gutierrez was indicted in the District of Montana on four charges: (1) conspiracy to commit robbery affecting commerce; (2) robbery affecting commerce; (3) possession of a firearm in furtherance of a crime of violence; and (4) felon in possession of a firearm. These charges resulted from a robbery of Dotty’s Casino in Billings, Montana, that involved a firearm. The felon in possession of a firearm charge stemmed from Gutierrez’s previous convictions under Idaho state law for burglary. In 2000, Gutierrez pleaded guilty to two counts of felony burglary. He was sentenced to the Idaho State Correctional Institution for a fixed term of two years and a subsequent indeterminate term of three years. In 2003, acting pursuant to Idaho Code section 19-2604(2), an Idaho district court ordered Gutierrez’s burglary convictions “REDUCED to Misdemeanor Petit Theft.” The order specified that Gutierrez was “not to be considered a convicted felon because he has successfully complied with the terms and conditions of probation and paid all restitution/reimbursement and fines in full.” Based on the plain language of Idaho Code section 19-2604 the Idaho Supreme Court's answer to the Ninth Circuit’s question was no. "A grant of leniency under Idaho Code section 19-2604(2) does not remove a defendant originally convicted of an enumerated felony from the reach of section 18-310(2) and (3)." View "United States v. Gutierrez" on Justia Law

The issue presented for review by the Idaho Supreme Court stemmed from an “unfortunate kitchen accident.” Mary Clare Griffin purchased a bottle of Italian wine, which broke in her hands as she attempted to open it, causing substantial injuries. Griffin and her son, a minor who witnessed the event, brought a product liability suit against Zignago Vetro S.P.A., the Italian manufacturer of the wine bottle; Marchesi Antinori SRL (Antinori), the Italian wine company that purchased the bottle from Zignago, filled it with wine, and exported it to the United States; Chateau Ste. Michelle Wine Estates, Ltd. (Ste. Michelle), the United States importer; S & C Importers and Distributors, Inc. (S&C), the Idaho distributor who purchased the bottle from Ste. Michelle; and, Albertson’s LLC (Albertson’s), the retailer that sold the bottle to Griffin. Zignago successfully moved the district court to dismiss Griffin’s complaint based on a lack of personal jurisdiction. Griffin appealed the district court’s decision, asking the Supreme Court to apply the personal jurisdiction framework established by the United States Supreme Court in World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980). Zignago claimed the district court did not err by applying the stricter test that the United States Supreme Court offered in Asahi Metal Indus. Co. v. Superior Court of California, Solano Cnty., 480 U.S. 102 (1987) (plurality). Griffin also appealed several adverse discovery rulings. The Supreme Court held that the correct test when determining personal jurisdictional issues remains the “stream of commerce” test adopted by the United States Supreme Court in World-Wide Volkswagen. Applying that test to the case here, the Court reversed the district court’s decision to grant Zignago’s motion to dismiss for lack of personal jurisdiction and remand the case for further proceedings. Furthermore, the Court affirmed the district court’s decision granting Antinori’s and Ste. Michelle’s motions for summary judgment and hold that it did not abuse its discretion in failing to grant Griffin’s motion to compel discovery against Antinori and Ste. Michelle. View "Griffin v. Ste. Michelle Wine Estates LTD." on Justia Law

Douglas Waite appealed an Idaho Industrial Commission (“Commission”) decision requiring him to repay unemployment benefits he received, along with interest and penalties. Waite claimed the Commission’s determination that he willfully misstated a material fact for the purpose of obtaining unemployment benefits was not supported by substantial and competent evidence and was incorrect as a matter of law. Additionally, Waite argued the Commission erred when it concluded that Idaho Code section 72-1366(12) required him to repay the unemployment benefits he received. Finding no reversible error, the Idaho Supreme Court affirmed the Commission’s decision and order. View "Waite v. Moto One KTM, LLC" on Justia Law

Medical Recovery Services, LLC, (MRS) sued Michael Eddins to collect on debts that had purportedly been assigned to MRS by Intermountain Emergency Physicians and Intermountain Anesthesia. After a bench trial, the magistrate court dismissed MRS’s complaint, holding MRS lacked standing because it failed to prove a valid assignment occurred. MRS appealed to the district court. That court reversed, holding the magistrate court erred in limiting the admission of two exhibits that MRS relied upon to establish that Eddins’ accounts had been validly assigned to it. Alternatively, the district court held Eddins was judicially estopped from raising the assignment issue at trial because he did not raise it earlier during the litigation. Eddins timely appealed to the Idaho Supreme Court. After review, the Court affirmed the district court’s decision on the magistrate court’s abuse of discretion in limiting the admission of "Exhibit 2." The Court likewise affirmed the district court’s conclusion about an agent of MRS and its standing for the purposes of prosecuting this case. The Court reversed as to all other issues and remanded for further proceedings. View "Medical Recovery Svcs v. Eddins" on Justia Law

Tenant Dennis Florer brought an action against Yar Walizada, his landlord, for breach of the warranty of habitability based on an alleged failure to provide an adequate heat source. Walizada moved to dismiss, asserting that Florer lacked standing to bring the action because, by the time Florer provided written notice under Idaho Code section 6-320, the alleged breach had already been cured. The district court denied the motion and, following a bench trial, entered judgment in Florer’s favor. Walizada appealed, arguing the district court erred in denying his motion to dismiss. After review, the Idaho Supreme Court found: Walizada rented a house without an adequate heat source to Florer; he had an obligation to provide an adequate heat source; he induced Florer to install the stove by promising to offset Florer’s costs against his rent; and he reneged on this promise. The Court found Florer could have sued for breach of the oral agreement to offset the costs of installation against his rent, and given the result below, it appears he would have been successful if he had. However, Florer brought suit under section 6-320, and this suit was not preceded by a written notice allowing three days to cure, the district court’s failure to grant Walizada’s motion to dismiss contradicted the plain language of section 6-320; therefore, the Court reversed its decision. View "Florer v. Walizada" on Justia Law

This appeal stemmed from a years-long dispute between Robert Elgee and the Retirement Board of the Public Employee Retirement System of Idaho (“PERSI”) regarding the payment of retirement benefits accrued during Elgee’s service as a magistrate judge. Elgee became eligible for PERSI benefits in 2010, but operating under an erroneous interpretation of the statutes it administers, PERSI maintained Elgee was not then entitled to receive benefits. Eleven years, numerous administrative determinations, and two judicial review actions later, the parties continued to disagree on issues relating to the calculation of benefits, the interest due on benefits, and whether Elgee was entitled to damages for the tax consequences of receiving a lump sum payment of retroactive benefits. After review, the Idaho Supreme Court affirmed the district court as to the applicable rate of interest, reversed as to the remaining issues, and remanded for entry of judgment. On remand the district court was directed to enter judgment that reflected: (1) the PERSI Board’s determination that Elgee was due interest at the regular rate of interest under the PERSI statutes was affirmed; (2) the PERSI Board’s determination that Elgee was due interest from 2013, rather than 2010, was set aside; (3) the PERSI Board’s determination that Elgee was due benefits under the contingent annuitant option, rather than the regular retirement option was affirmed; (4) the PERSI Board’s determination that Elgee failed to prove his tax loss claim in 2018 was set aside; and (5) the PERSI Board’s determination that tax loss damages were not available under the PERSI statutes was affirmed. View "Elgee v. Retirement Brd. of the Public Employee (PERSI)" on Justia Law

Craig Stark entered into a contract with McCarthy Corporation to construct a storage facility for recreational vehicles and boats. The relationship turned sour after McCarthy sent Stark an invoice for work Stark believed he had already paid for in full. After the parties were unable to resolve their dispute, Stark terminated McCarthy’s contract. McCarthy then filed a lien against Stark’s property and brought suit for breach of contract and to foreclose its lien. Stark, Stark Investment Group, and U.S. Bank, Stark’s construction lender on the project, counterclaimed for breach of contract, breach of the implied covenant of good faith and fair dealing, fraudulent misrepresentation, slander of title by the recording of an unjust lien, and breach of the Idaho Consumer Protection Act (“ICPA”). After a bench trial, the district court largely agreed with Stark's counterclaims and dismissed McCarthy's complaint. McCarthy appealed the district court’s findings, damages award, and attorney fees award. Finding no reversible error, the Idaho Supreme Court affirmed the district court's holdings that McCarthy breached the contract between the parties and McCarthy violated the ICPA. View "McCarthy Corporation v. Stark Investment Group" on Justia Law

In December 2014, Steve Tenny sustained a right-sided lumbar disc herniation injury during the course of his employment with Loomis Armored US (Loomis). He immediately began treatment, receiving a series of right-sided steroid injections in his back. At some point shortly after the second injection, Tenny began to complain of increasing left hip and groin pain and underwent testing and treatment for these symptoms. However, the worker’s compensation insurance surety, Ace American Insurance Co., ultimately denied payment for treatment related to the left-side groin pain. Following the matter going to hearing, the Referee recommended that the Industrial Commission find that the left-sided symptoms were causally related to Tenny’s December 2014 industrial accident. The Industrial Commission adopted the Referee’s findings, and after unsuccessfully moving for reconsideration, the employer and surety (collectively, "Defendants") appealed to the Idaho Supreme Court. At issue before the Supreme Court was the question of causation: Was the left-side groin pain experienced by Tenny causally related to his industrial accident? Finding no reversible error, the Idaho Supreme Court affirmed the Industrial Commission's decision. View "Tenny v. Loomis Armored US, LLC" on Justia Law