Justia Idaho Supreme Court Opinion Summaries

William Weeks was employed as an equipment operator for Oneida County’s Road and Bridge Department in Idaho. In September 2021, during a period of high COVID-19 transmission, Mr. Weeks continued working as required for critical infrastructure employees. He attended daily morning meetings with coworkers in a break room and often visited local stores. After a coworker became ill and missed work, Mr. Weeks developed COVID-19 symptoms, tested positive, and later died from complications. His wife, JaLyn Weeks, filed a worker’s compensation claim, alleging he contracted COVID-19 at work.The employer denied the claim, and Mrs. Weeks brought her case before the Idaho Industrial Commission. At the hearing, both parties presented expert testimony regarding the likely source and timing of Mr. Weeks’ infection. The Commission found the employer’s expert more persuasive, concluding that it was not possible to determine, by a preponderance of the evidence, that Mr. Weeks contracted COVID-19 at work rather than from other possible sources, such as visits to stores or contact with individuals outside of work. The Commission denied the claim for medical and death benefits.On appeal, the Supreme Court of the State of Idaho reviewed whether the Commission applied the correct legal standard and whether its findings were supported by substantial and competent evidence. The Court held that the Commission properly applied the preponderance of the evidence standard and did not err by refusing to resolve doubts in favor of compensability in occupational disease cases. The Court affirmed the Commission’s decision, holding that Mrs. Weeks failed to prove that Mr. Weeks actually incurred COVID-19 from his employment. The Court did not reach the issue of whether COVID-19 is a compensable occupational disease under Idaho law. View "Weeks v. Oneida County" on Justia Law

A police officer employed by the City of Boise suffered injuries during a traffic stop in 2019, including a right hip injury, which the employer accepted and compensated. Later, the officer developed left hip pain, and her physician initially stated it was unrelated to the work accident, but later opined it was likely related. Disputes arose over medical records and scheduling independent medical examinations (IMEs). The employer, relying on prior Idaho Supreme Court precedent, sent a letter purporting to suspend compensation when the officer did not attend an IME, though the Idaho Industrial Commission later found that no actual suspension occurred. The officer continued to receive salary and some benefits, while her left hip surgery was covered by private insurance.After the Idaho Supreme Court’s decision in Arreola v. Scentsy, Inc., which held only the Commission could order suspension of benefits for failure to attend an IME, the officer sought a declaratory ruling from the Commission regarding retroactive application of Arreola. While that petition was pending, the employer filed a complaint with the Commission to adjudicate issues about the officer’s entitlement to benefits and IME compliance. The officer then filed a second petition, arguing that only employees, not employers, could file such complaints under Idaho’s worker’s compensation law.The Idaho Industrial Commission denied both petitions. It found the first petition was moot because the officer’s benefits were never actually suspended and Arreola applied only prospectively. The Commission denied the second petition on the merits, holding it had jurisdiction to accept complaints from employers under Idaho Code section 72-707 and its own rules.On appeal, the Supreme Court of the State of Idaho affirmed the Commission’s denial of the first petition, finding no justiciable controversy. However, it set aside the denial of the second petition, holding that only employees may file complaints to request hearings on claims for compensation or income benefits under Idaho Code section 72-706, and the Commission exceeded its powers by allowing employer-initiated complaints in such matters. View "Coronado v. City of Boise" on Justia Law

After the death of Rolland Lane, the Lane Family Trust was divided into two sub-trusts, Trust A and Trust B, with Karla Lane serving as the sole trustee of Trust A and John Edwards, Scott Edwards, and Keith “KC” Lane as co-trustees of Trust B. The main asset of the trusts was a house and acreage in Caldwell, Idaho, owned equally by both trusts. Disputes arose over the sale of this property, with Karla seeking to sell it for no less than one million dollars, while the co-trustees of Trust B objected and pursued a different sale arrangement. After a cash offer of $1,350,000 was made, the district court ordered all trustees to accept the offer and close the sale by a specified date. Karla refused to comply, leading to further litigation.The District Court of the Third Judicial District of Idaho, Canyon County, ultimately removed Karla as trustee of Trust A, finding her refusal to follow the court’s order to sell the property constituted grounds for removal under Idaho law. The court appointed KC as the new trustee of Trust A. Karla appealed, arguing that her actions were within her discretionary authority as trustee and that she was acting in the best interests of the beneficiaries by seeking a higher sale price.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court’s order. The Supreme Court held that Karla had waived all arguments on appeal due to significant deficiencies in her briefing, including raising new arguments for the first time on appeal, failing to provide an adequate record, and not articulating how the district court abused its discretion. The Supreme Court also awarded attorney fees and costs to the respondents, finding the appeal to be frivolous. View "Edwards v. Lane" on Justia Law

Noah Gilbert purchased a motor vehicle insurance policy from Progressive Northwestern Insurance Company, initially declining underinsured motorist (UIM) coverage but later adding a UIM endorsement with $25,000 per person and $50,000 per accident limits. The policy included an offset provision, reducing any UIM payout by amounts received from another party’s insurance. Gilbert paid premiums for this coverage but never filed a UIM claim or experienced an accident triggering such coverage. He later filed a putative class action, alleging that Progressive’s UIM coverage was illusory under Idaho law and asserting claims for breach of contract, breach of the implied covenant of good faith and fair dealing, unjust enrichment, fraud, and constructive fraud.The District Court of the Fourth Judicial District, Ada County, reviewed cross-motions for summary judgment. The court raised the issue of standing and ultimately held that Gilbert lacked standing because he had not filed a claim or been denied coverage, and thus had not suffered an injury-in-fact. Alternatively, the court found that Gilbert’s claims failed on the merits: there was no breach of contract or bad faith without a denied claim, no damages to support fraud or constructive fraud, and unjust enrichment was unavailable due to the existence of a valid contract. The court granted summary judgment for Progressive and denied Gilbert’s motion for class certification as moot.On appeal, the Supreme Court of the State of Idaho held that Gilbert did have standing, as payment of premiums for allegedly illusory coverage constituted a concrete injury. However, the Court affirmed the district court’s judgment, finding that Gilbert’s claims failed on the merits because he never filed a claim, was never denied coverage, and did not incur damages. The Court also affirmed the dismissal of the unjust enrichment claim, as an enforceable contract provided an adequate legal remedy. The judgment in favor of Progressive was affirmed. View "Gilbert v. Progressive Northwestern Insurance Co." on Justia Law

The dispute arose over whether certain parcels of land owned by Vintage II, LLC and Christine Holding in Teton County, Idaho, were subject to covenants, conditions, and restrictions (CC&Rs) or other limitations associated with the adjacent Teton Saddleback Vistas Subdivision. The plaintiffs sought to quiet title, arguing their properties were not encumbered by three recorded CC&R instruments. The defendant homeowners association claimed the properties were subject to restrictions, including those set forth in a recorded Master Plan referenced in the plaintiffs’ deeds.The District Court of the Seventh Judicial District reviewed the case after a bench trial. It found that the CC&Rs did not encumber the subject properties due to deficiencies in their recording and description. However, the court concluded that the Master Plan, referenced in the plaintiffs’ deeds, did impose restrictions such as lot numbers, sizes, and open area requirements, and thus encumbered the properties. The court denied the plaintiffs’ request to quiet title, holding that the Master Plan created enforceable restrictions and a common law dedication of open space.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision to admit the Master Plan into evidence, finding it relevant because it was referenced in the deeds and material to the quiet title action. However, the Supreme Court reversed the district court’s conclusions that the Master Plan created restrictive covenants or a common law dedication. The Court held that the Master Plan did not clearly express any binding restrictions or dedication, and thus could not encumber the properties. The amended judgment was vacated, and the case was remanded for entry of judgment in favor of the appellant, Vintage II, LLC. The Court awarded costs to Vintage as the prevailing party. View "Vintage II, LLC v. Teton Saddleback" on Justia Law

A property owner along the shore of Priest Lake in Idaho sought a permit from the Idaho Department of Lands (IDL) for a submerged log structure, which he claimed had existed since the early 1960s. The structure, known as a log crib, was intended to prevent erosion and create a sandy beach. After initially applying for a permit to cover modifications made to the structure, including the addition of cobblestones and sandbags, the owner was denied due to lack of public benefit and evidence of modification. He then submitted a second application under Idaho Code section 58-1312, which allows permits for pre-1975 encroachments if the applicant provides documentation of the structure’s age and proof that it has not been modified since 1974.IDL denied the second application, finding insufficient evidence that the structure had not been modified since 1974, particularly since the owner admitted to adding and later removing materials. The owner appealed, and after a public hearing, the IDL Director issued a Final Order denying the permit, agreeing that while the structure predated 1974, it had been modified. The owner then sought judicial review in the District Court of the First Judicial District, Bonner County, arguing that IDL’s procedures violated his due process rights and that the agency erred in its interpretation of the law. The district court affirmed IDL’s decision, finding substantial evidence supported the denial and that due process was not violated.On further appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Court held that IDL properly denied the permit because the applicant failed to show the structure had not been modified since 1974, and that the agency was not required to follow procedures for new encroachments. The Court also found no due process violation and awarded attorney fees and costs to IDL. View "Wilson v. Idaho State Board of Land Commissioners" on Justia Law

A couple purchased a home from another couple, relying on representations made in a property condition disclosure form as required by Idaho law. After moving in, the buyers discovered significant defects in the home, including unpermitted additions and structural problems that were not disclosed. The buyers hired experts who confirmed that the attic and kitchen additions were structurally unsound and that required permits had not been obtained. The buyers filed suit three years after the sale, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, violation of the Idaho Property Condition Disclosure Act, and fraud.The case proceeded in the District Court of the Third Judicial District, Canyon County. A jury found in favor of the buyers on all claims except the implied covenant of good faith and fair dealing, awarding $63,024 in damages. After trial, the district court granted a directed verdict for the sellers on the Disclosure Act claim, finding it barred by a three-year statute of limitations, but denied the sellers’ motions on the fraud and contract claims. The court also denied the buyers’ request for attorney fees, reasoning they were not the prevailing party.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s denial of the sellers’ motions for directed verdict and judgment notwithstanding the verdict on the fraud claim, holding that the buyers’ fraud claim was not time-barred because they did not discover the fraud until after closing, and that substantial evidence supported the jury’s verdict. The Supreme Court reversed the district court’s dismissal of the Disclosure Act claim, holding that the claim accrued at closing, not upon delivery of the disclosure form, and thus was timely. The Court also held that the buyers were entitled to attorney fees under the purchase agreement and remanded for a determination of the amount. The buyers were awarded attorney fees and costs on appeal. View "VanRenselaar v. Batres" on Justia Law

An employee suffered a severe hand injury, including the amputation of a finger, while operating a table saw without a safety guard at work. After receiving some worker’s compensation benefits, the employee filed a civil tort action against the employer, alleging that the employer’s requirement to use the saw without a guard constituted “willful or unprovoked physical aggression,” which, under Idaho law, would allow a lawsuit outside the worker’s compensation system. The employer did not respond to the lawsuit, and the employee obtained a default judgment for damages.Several months later, the employer moved to set aside the default judgment, arguing that the district court lacked subject matter jurisdiction because the employee’s worker’s compensation claim had been filed first. The District Court of the Fourth Judicial District agreed, stayed enforcement of the default judgment, and directed the parties to seek a determination from the Idaho Industrial Commission on whether the “willful or unprovoked physical aggression” exception applied. The Commission concluded that the exception did not apply, and the district court then set aside the default judgment and dismissed the civil action.On appeal, the Supreme Court of the State of Idaho held that the district court erred by deferring to the Commission on the applicability of the statutory exception and by setting aside the default judgment. The Supreme Court clarified that district courts have concurrent subject matter jurisdiction to determine whether the exception to the exclusive remedy rule applies, even if a worker’s compensation claim was filed first, unless the Commission has already decided the issue. The Supreme Court reversed the district court’s decision, vacated the Commission’s findings, and remanded with instructions to reenter the default judgment in favor of the employee. View "Tyler v. Masterpiece Floors, Inc." on Justia Law

The case involves a dispute between the owners and operators of a tourist attraction, Bear World, and the Idaho Transportation Department (ITD) over the closure of an intersection on Highway 20 in Madison County, Idaho. Bear Crest Limited LLC owns parcels of land leased to Yellowstone Bear World Inc., and Michael Ferguson is associated with both entities. In 1973, the original landowners (the Gideons) conveyed land to ITD’s predecessor for highway expansion, reserving “Access to the County Road Connection.” In 2016, as part of a highway upgrade to controlled-access status, ITD closed the intersection nearest Bear World, requiring visitors to use a more circuitous route, increasing travel distance by about five miles.After the intersection closure, the plaintiffs sued ITD for breach of contract and inverse condemnation, arguing that the closure violated the reserved access right in the Gideon deed and constituted a taking of property without just compensation. Both parties moved for summary judgment. The District Court of the Seventh Judicial District, Madison County, granted summary judgment to ITD, finding that the deed did not guarantee access to Highway 20, only to a county road, and that the closure did not amount to a compensable taking since alternative access remained.On appeal, the Supreme Court of the State of Idaho reversed in part, vacated the district court’s judgment, and remanded. The Court held that Bear Crest Limited had standing and that the Gideon deed unambiguously reserved access to the specific Highway 20 connection, not merely to a county road. The Court found that ITD’s closure of the intersection breached the deed and substantially impaired Bear Crest’s access rights, constituting a taking under Idaho law. The Court directed entry of partial summary judgment for Bear Crest on both claims, reserving damages and other issues for further proceedings. View "Bear Crest Limited LLC v. State of idaho" on Justia Law

Aaron Powers owned a lot within a subdivision governed by covenants, codes, and restrictions (CC&Rs), as well as an adjacent parcel he intended to develop. The adjacent parcel lacked access to a public or private road, so Powers sought to construct a road across a sixty-foot strip of his lot to provide access. After the homeowners association (HOA) denied permission, Powers obtained a boundary line adjustment and amended plat from Teton County, effectively moving the strip into the adjacent parcel. Carl Jordan, a subdivision homeowner and HOA board member, filed suit seeking declaratory and injunctive relief to prevent the road’s construction, arguing that the CC&Rs still applied to the strip and prohibited the road.The District Court of the Seventh Judicial District, Teton County, granted summary judgment for Jordan, declaring that the CC&Rs continued to apply to the strip, that Powers violated the CC&Rs by splitting the lot, and that the CC&Rs categorically prohibited construction of the road. The court issued a permanent injunction against Powers and awarded attorney fees and costs to Jordan. Powers moved for reconsideration, which was denied, and he appealed.The Supreme Court of the State of Idaho affirmed in part and reversed in part. The Court held that the CC&Rs continued to apply to the sixty-foot strip despite the boundary adjustment and that Powers was required to obtain approval from the HOA’s Design Committee before constructing the road, which he had not done. However, the Court reversed the lower court’s declaration that the CC&Rs categorically prohibited road construction and that the boundary adjustment constituted a prohibited lot split, finding those issues either unsupported or moot. The permanent injunction and the award of attorney fees and costs were vacated, and the case was remanded for further proceedings. Neither party was awarded attorney fees on appeal. View "Jordan v. Powers" on Justia Law