Justia Idaho Supreme Court Opinion Summaries

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

Nathan Smith appealed a district court order granting summary judgment in favor of his former employer, Kount, Inc., and denying his cross motion for summary judgment on the grounds that the compensation agreement he signed unambiguously required Smith to remain employed until a specified date to earn the bonus compensation, and Smith resigned before that date. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgment. View "Smith v. Kount Inc." on Justia Law

Pheasant Run VI, LLC, Robert Drinkard, and Nancy Drinkard (collectively, “the Drinkards”) appealed a district court’s order renewing a judgment for Alpha Mortgage Fund II (“Alpha”) for $1,842,509.59. Pheasant Run was a company wholly owned by the Drinkards. Pheasant Run obtained a loan from Alpha. Robert and Nancy acted as guarantors for the loan. Pheasant Run ultimately defaulted on the loan and Alpha foreclosed on property the Drinkards used as collateral for the loan. Although Alpha recouped the property, a significant deficiency existed between the amount Pheasant Run owed and the property’s fair market value. Alpha thereafter sued Robert and Nancy for the amount of the deficiency. The Original Judgment was entered in 2010, and renewed in 2015. Alpha did not record the 2015 judgment. In 2020, Alpha moved the district court to again renew the Original Judgment pursuant to Idaho Code section 10-1111. The Drinkards objected, leading to this appeal. The Idaho Supreme Court found the district court did i not err when it granted Alpha’s motion to renew the Original Judgment, even though the 2015 judgment was not recorded: the judgment remained unsatisfied, and Alpha’s motion was filed within five years of the most recently renewed 2015 judgment. Accordingly, judgment was affirmed. View "Alpha Mortgage Fund v. Drinkard" on Justia Law

After Anne Herr petitioned for divorce from John Herr, John asserted that two investment accounts opened during the marriage were his separate property. The magistrate court disagreed, finding that separate and community property had been commingled in the accounts, triggering the presumption that all assets in the accounts were community property. Because John did not present an argument to rebut this presumption, the magistrate court ordered the accounts divided equally between the parties. The district court affirmed the magistrate court’s decision on intermediate appeal. John argued to the Vermont Supreme Court that the district court’s decision should be reversed because evidence sufficient to trace his separate property was admitted at trial. The Supreme Court affirmed because John was obligated to present an argument at trial to rebut the presumption that the assets were community property, not merely to provide evidence from which an argument could have been made. View "Herr v. Herr" on Justia Law

The law firm Hepworth Holzer, LLP (“Hepworth Holzer” or “the firm”), petitioned the Idaho Supreme Court for a writ of mandamus or prohibition, seeking relief from a district court order disqualifying it as counsel for Dr. Gary Tubbs in a personal injury lawsuit against Bogus Basin Recreational Association, Inc. (“Bogus Basin”). Bogus Basin was represented by Elam & Burke in the proceedings. Elam & Burke moved to disqualify Hepworth Holzer after an associate attorney who worked at Elam & Burke when Tubbs initiated his lawsuit went to work for Hepworth Holzer and assisted the firm on a memorandum in support of a motion to reconsider filed in the case. The district court granted Elam & Burke’s motion. The district court ordered that “[a]ny attorney associated with Hepworth Holzer, LLP, including [the associate attorney], are disqualified from any further representation of [Dr.] Gary Tubbs in this matter and from providing any information from its files after January 21, 2021, and cannot relay any information discussed or received about this case after January 21, 2021[,] to Tubbs or any new attorney/firm representing Tubbs.” Hepworth Holzer contended the district court’s disqualification and gag order was clearly erroneous and unconstitutional. Finding the district court erred in issuing its disqualification order, the Supreme Court granted Hepworth Holzer's request for mandamus relief. The disqualification and gag order were vacated; and a new judge was ordered to preside over further proceedings. View "Hepworth Holzer, LLP v. Fourth Judicial District" on Justia Law

The issue presented for the Idaho Supreme Court's review was one of first impression involving a magistrate court’s custody determination of an eight-year-old developmentally delayed and hearing-impaired child (Child) who was removed from his father’s (Father) care by law enforcement on an emergency basis. Child was found home alone by representatives of the Idaho Department of Health and Welfare (IDHW or the Department). After a shelter care hearing, the magistrate court determined that there was reasonable cause to believe that Child fell within the jurisdiction of the CPA based on a lack of a stable home environment. Father objected to the magistrate court’s exercise of jurisdiction, arguing that because Father had been granted joint custody of Child with Child’s mother (Mother) by a California court, the UCCJEA applied, which required the magistrate court to consult with the California court that had previously entered the custody order before the magistrate court could proceed in Idaho. After contacting and communicating with the California judge’s representative, the magistrate court conducted an adjudicatory hearing, ultimately vesting custody of Child with the Department. Finding no reversible error in this judgment, the Supreme Court affirmed the magistrate court's decision. View "IDHW v. John Doe" on Justia Law

Cynthia Hilton appealed a trial court's decision to deny her motion to divide an omitted asset: a company partially owned by her ex-husband, Lance Hilton. Cynthia alleged that because the stipulated divorce decree did not list the company as community or separate property, it was an omitted asset and she was entitled to half of its retained earnings allocable to Lance. The magistrate court denied Cynthia’s motion on the basis that it had previously determined the company was Lance’s separate property. On intermediate appeal, the district court affirmed. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Hilton v. Hilton" on Justia Law

Linsay and Kylee Gatsby married in June 2015. They later decided Kylee would attempt to conceive a child through artificial insemination, using semen donated by a mutual friend. It was undisputed that Kylee is the child’s biological mother. The birth certificate worksheet, which Kylee signed, designates Kylee as “mother,” and the word “father” on the form is crossed out and “mother” written by hand in its place to also identify Linsay as the child’s mother. The Idaho Department of Health and Welfare issued a Certificate of Live Birth identifying both Kylee and Linsay as the child’s mothers. Both Kylee and Linsay shared in caregiving, but Kylee was the child’s primary caregiver. The following summer the couple had an argument. Both Linsay and Kylee had been drinking, and Kylee became drunk. Kylee shoved Linsay off a bed. Then Linsay punched Kylee, breaking her nose. The child was in the bedroom during the fight, and Linsay’s two children from a prior relationship were also in the home. Kylee was arrested and subsequently pleaded guilty to misdemeanor domestic battery. Kylee had also committed an act of domestic violence years earlier. On July 5, 2017, a No Contact Order (“NCO”) was issued, which prohibited Kylee from seeing the child except at daycare. On August 29, 2017, Linsay filed for divorce. Kylee filed an Answer and Counterclaim, asserting that Linsay had “no legal claim or standing to any custody or visitation” to the minor child. The issue this appeal presented for the Idaho Supreme Court's review centered on Idaho law pertaining to artificial insemination, paternity, and parental rights in light of the U.S. Supreme Court’s ruling in Obergefell v. Hodges, 576 U.S. 644, 647 (2015). The district court affirmed the magistrate court’s ruling that Linsay had no parental rights to the child under Idaho’s common law marital presumption of paternity because she conceded that she lacked a biological relationship with the child. The district court also affirmed that Linsay had no parental rights under the Artificial Insemination Act because she did not comply with the statute’s provisions. The district court further ruled that Linsay would have had parental rights if she had filed a voluntary acknowledgment of paternity or adopted the child, but she did not do so. Finally, the district court affirmed that Linsay did not have third party standing to seek custody and, in the alternative, that custody or visitation would not be in the child’s best interest if Linsay did have third party standing. Accordingly, the district court's judgment was affirmed. View "Gatsby v. Gatsby" on Justia Law

Sharon Bruno appealed following a bench trial on a quiet title matter. Bruno and her father Howard Frost sought to quiet title to an express easement, pursued quiet title for an easement by prescription, and requested an injunction against two other nearby property owners. The gravamen of the suit was to establish an easement for irrigation hand lines and piping as well as to ensure access to irrigation equipment. The hand lines had been in place since the early 1980s. They originated at a pump near the Payette River and crossed an adjacent property now owned by Dana and Elisa Gilbert (the Gilberts) before reaching Bruno’s property. Bruno also contended that the way she and her father accessed the pump since its installation in 1981 was over a driveway on what was now the Gilberts’ property, as well as a switchback on adjacent property now owned by Alfred Alford. The Gilberts counterclaimed alleging trespass and slander of title. They also sought a declaratory judgment to extinguish the express easement which had been in effect since 2011. Alford also counterclaimed alleging trespass and seeking a declaratory judgment that Bruno had no interest in his property for purposes of accessing the pump. Bruno unsuccessfully moved for summary judgment and for a preliminary injunction. The claims were bifurcated, with the easement-related claims to be tried first before a judge, and the trespass claims to follow before a jury. At the close of the first trial, the district court found that the express easement clearly allowed Bruno ingress and egress along the legal description of the easement; however, the district court rejected the requested prescriptive easement across the Gilberts’ driveway and the switchback on Alford’s property. The district court found that any use of these roads had been permissive and therefore did not satisfy the requirements for a prescriptive easement. Accordingly, the district court dismissed Bruno’s prescriptive easement-related claims. After unsuccessfully moving for reconsideration, Bruno moved the district court to enter a 54(b) certificate to enable an immediate appeal, which was granted. Bruno then timely appealed. After review, the Idaho Supreme Court found no reversible error in the district court's judgment and affirmed. View "Frost v. Gilbert" on Justia Law