Justia Idaho Supreme Court Opinion Summaries

Originally, Western Pacific Timber, LLC (WPT) was solely owned by Timothy Blixseth (Blixseth). Andrew Hawes contended Blixseth hired him to be general counsel for WPT in 2005, and that when he was hired, Blixseth agreed on behalf of WPT to provide him with a severance package based on the length of his employment. After 2012, Blixseth no longer retained any ownership interest or management responsibility in WPT. When WPT terminated Hawes’ employment in 2017, Hawes asserted that he had a severance agreement in place that had been negotiated with Blixseth on behalf of WPT, by which he would receive $100,000 for each year of employment, capped at five years, for a total of $500,000. However, Hawes could not produce a signed copy of any agreement. WPT refused to pay the claimed severance pay, and instead offered a significantly smaller severance package. Hawes rejected WPT’s offer. Hawes then sued WPT for breach of contract. The case proceeded to trial on Hawes’ claim of an oral contract. Ultimately, the jury returned a special verdict finding that WPT was liable to Hawes for $500,000 in severance pay, an award which was later trebled by the district court. The district court also awarded Hawes the full amount of his requested attorney fees which constituted 35% of Hawes’ gross recovery. WPT unsuccessfully moved for a new trial. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Hawes v. Western Pacific Timber LLC" on Justia Law

At the heart of this case was a highway right-of-way proposed and approved in 1908 by the Kootenai County Board of Commissioners (the Board), then purportedly abandoned in 1910. This appeal arose from a decision of the East Side Highway District, the Board’s successor-in-interest, in which it declined to validate this highway right-of-way. In 2017, Gloria Palmer, Trustee of the Palmer Family Trust (the Trust) requested that the District validate the right-of-way. This was opposed by Rande and Debra Warner, and Steffen and Allison Teichmann, over whose land the purported right-of-way traversed. The Warners sought to have the right-of-way abandoned. The Highway District initiated road validation proceedings, after which it declined to validate "Leonard Road No. 2." After this decision, the Highway District granted a motion for reconsideration and reopened the public hearing. After hearing additional evidence and public comments, the Highway District again declined to validate the purported right-of-way. The Trust petitioned the district court for judicial review. The district court affirmed the Highway District’s decision. The Trust again appealed. Finding no reversible error or abuse of discretion, the Idaho Supreme Court affirmed the district court. View "Palmer v. ESHD" on Justia Law

This appeal arose from a district court’s alleged failure to follow the Idaho Supreme Court’s holding in Frizzell v. DeYoung, 415 P.3d 341 (2018) ("Frizzell I") after remand. In Frizzell I, the Supreme Court held that an agreement entered into pursuant to the Trust and Estate Dispute Resolution Act (“TEDRA”), Idaho Code sections 15-8-101, et seq., by Donald Frizzell and Edwin and Darlene DeYoung was only enforceable to the extent that it settled past claims. As a result, the provisions that purported to exculpate Edwin from liability for future negligence or breaches of fiduciary duty after the agreement was executed were deemed void as against public policy. In this appeal, Frizzell argued that after the case was remanded, the district court failed to follow the law of the case by erroneously allowing the DeYoungs to introduce evidence, testimony, and argument concerning conduct that occurred before the agreement was executed. Frizzell also claimed the district court abused its discretion in awarding the DeYoungs attorney fees without considering the factors in Idaho Rule of Civil Procedure 54(e). Finding no reversible error, the Supreme Court affirmed the district court. View "Frizzell v. DeYoung" on Justia Law

This case involved a fee dispute between two attorneys arising from a purported fee-sharing agreement. The underlying case involved an airman in the U.S. Air Force who was injured while driving through Idaho on his way to a posting in Alaska. The airman hired an Alaska attorney, Stephen Merrill, to represent him in pursuit of his personal-injury claims in Idaho. Merrill associated Erik Smith, an Idaho attorney, to act as local counsel in the airman’s suits. At a point in the proceedings, the airman terminated Merrill’s representation. Smith ultimately settled the case and retained the entire attorney fee. Merrill then sued Smith seeking his proportionate share of the fee. Smith moved for summary judgment which was granted by the district court. Merrill appeals. After review of the trial court record, the Idaho Supreme Court concluded the district court erred in granting summary judgment to Smith: Smith failed to meet his burden as the moving party on summary judgment. "When Smith filed his motion for summary judgment, he alleged that it was undisputed that there was no agreement reached between the parties, written or oral. This bald assertion contradicted the crux of Merrill’s complaint that the agreement about fee sharing had been reached over the course of the email correspondence. However, Smith did not support this assertion by presenting evidence or by citing to any admissible evidence in this record." View "Merrill v. Smith" on Justia Law

This case arose from a domestic dispute between Analli Salla and Duane Siercke, and centered on whether any privilege from defamation claims applied to statements made to law enforcement. Salla appealed the district court’s entry of judgment and denial of her motion for a new trial. After misdemeanor domestic battery charges against him were dropped, Siercke filed a civil action against Salla alleging, among other things, defamation. Following a five-day trial, a jury awarded Siercke $25,000.00 on his defamation claim. Salla filed a motion for a new trial, contending the district court erred in instructing the jury on defamation per se because her statements to law enforcement were privileged and her statements did not allege that Siercke had committed a felony. The district court denied the motion and Salla appealed. The Idaho Supreme Court: (1) affirmed the district court’s decision refusing to apply an absolute litigation privilege to the statements made by Salla to law enforcement officers; (2) could not address whether the district court erred in not giving a qualified privilege instruction because that issue was never raised below; and (3) the district court erred in delivering a defamation per se instruction; and (4) reversed the district court’s final judgment and order on Salla’s motion for a new trial. The case was remanded for further proceedings. View "Siercke v. Siercke" on Justia Law

At issue before the Idaho Supreme Court in this case was whether the Public Records Act authorized the Idaho Department of Correction (“Department”) to withhold certain records in response to a public records request. In 2017, Aliza Cover requested records relating to the use of the death penalty in Idaho. The Department provided some records in response, but withheld or redacted others, claiming these records were exempt from disclosure in whole or in part under Board of Correction Rule 135.06 (“Rule 135”). The Department argued Rule 135 was promulgated pursuant to a provision of the Public Records Act that allowed the Board of Correction (“Board”) to identify records as exempt from disclosure through rulemaking. Because there was no evidence that the Board promulgated Rule 135 as a public records exemption, the Supreme Court reversed the district court's judgment permitting the Department to withhold records from Cover on this basis, and remanded for further proceedings. View "Cover v. ID Board of Correction" on Justia Law

In 2018, Derik and Jessica Smith bought property next to Carl and Anita Owen. The Smiths erected a fence along the boundary defined in a survey that was completed as part of their purchase agreement. The Owens disputed the boundary established by the 2018 survey and filed a complaint seeking damages for trespass, deprivation of real and personal property that was in the disputed area, loss in property value, and inability to inhabit and enjoy the property. The Smiths counterclaimed for quiet title and an easement guaranteeing them access to a buried irrigation pipeline that crossed the Owens’ property. The parties each filed a motion for summary judgment. The district court granted the Smiths’ motion for summary judgment, holding the Owens had no right, title or interest in the disputed property and that the Smiths were bona fide purchasers with superior claim to any land described in their deed. The court also granted the Smiths permanent easement rights to the irrigation pipeline. The court dismissed the Owens’ claims for trespass and conversion of personal property. The Owens timely appealed to the Idaho Supreme Court. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Owen v. Smith" on Justia Law

This appeal arose from the probate of Eric Milo Hirning’s will, and concerned a magistrate court’s authority to conduct formal probate proceedings and approve an estate’s final accounting and distribution. Three beneficiaries of the will, appellants Cindy Louise Uzzle, John E. White, and Jody Hirning, challenged the procedural grounds of the district court’s decision on appeal, the propriety of a magistrate court’s order approving the estate’s final accounting and proposed distribution, and the district court’s award of attorney’s fees. After review, the Idaho Supreme Court found no reversible error except that neither party should have been awarded costs or attorney's fees. View "Uzzle v. Estate of Hirning" on Justia Law

This case arose from a number of disputes between two brothers, Galust Berian (Galust) and Ovanes Berberian (Ovanes). In June 2017, Galust and Julia Berian (Galust's daughter and Ovanes' niece) were arrested after Ovanes reported to law enforcement that Galust and Julia had stolen several items from him. After the reported theft, Galust and Julia were arrested for unlawful entry onto property shared by Ovanes and his ex-wife, Socorro Berberian (Socorro), and for resisting arrest. After these charges were dropped, Galust and Julia filed suit against Ovanes and Socorro, alleging intentional infliction of emotional distress, negligent infliction of emotional distress, invasion of privacy, malicious prosecution, defamation, breach of contract, fraud, unjust enrichment, quantum meruit, and conversion. Ovanes counterclaimed for conversion. Ovanes and Socorro moved for summary judgment on all of Galust’s and Julia’s claims, which the district court granted except for their conversion claim. The district court also certified its grant of partial summary judgment as final pursuant to I.R.C.P. 54(b). Galust and Julia appealed the grant of summary judgment, arguing that summary judgment was improper because genuine issues of material fact existed with respect to each of their other causes of action. After review, the Idaho Supreme Court affirmed affirm the grant of summary judgment regarding the tort claims of invasion of privacy and negligent infliction of emotional distress, as well as the contract and fraud claims. However, the Court reversed the grant of summary judgment regarding the claims of intentional infliction of emotional distress, malicious prosecution, and defamation. The matter was remanded for further proceedings. View "Berian v. Berberian" on Justia Law

A group of prisoners (“Petitioners”) sought a writ of habeas corpus based on the conditions of their confinement during the COVID-19 pandemic. The Petitioners were all incarcerated at the Elmore County Jail (“Jail”), contending the conditions of confinement constituted cruel and unusual punishment in violation of the Eighth Amendment to the United States Constitution. More specifically, the Petitioners claimed they were in imminent danger because officials at the Jail did not implement any discernable mitigation measures in response to the COVID-19 pandemic. Elmore County Sheriff Mike Hollinshead and Lieutenant Shauna Gavin (collectively “Officials”) denied this assertion, contending that Petitioners’ request for a writ of habeas corpus should have been denied because the Petitioners did not exhaust their administrative remedies. The Officials filed a motion for summary judgment with the district court, which was granted. The district court also awarded the Officials their attorney fees. Petitioners timely appealed the district court’s decisions to the Idaho Supreme Court, which agreed to hear the appeal on an expedited basis. After that review, the Supreme Court affirmed the district court’s decision granting summary judgment, but reversed the district court’s award of attorney fees. View "Williams v. Hollinshead" on Justia Law