Justia Idaho Supreme Court Opinion Summaries

The case involves property owners Brenda and Ray von Wandruszka and Robert R. Davis, who sued the City of Moscow after the city adopted a resolution in 2021 revising its utility billing process. The new policy required property owners to sign contracts making them responsible for tenants' unpaid water bills, under threat of water service termination. The plaintiffs signed the contracts under protest and claimed they were unenforceable adhesion contracts signed under duress.The District Court of the Second Judicial District of Idaho reviewed cross-motions for summary judgment. The court ruled that the city was not authorized to recover tenants' unpaid utility charges from property owners, citing City of Grangeville v. Haskin. However, it also ruled that the city could require owner-occupied properties to enter agreements to pay for water consumed. Both parties appealed the split decision.The Supreme Court of Idaho reviewed the case and clarified that City of Grangeville does not prohibit municipalities from collecting tenants' unpaid utilities from property owners if there is a contractual basis. The court found that the utility billing agreements were not secured under duress, as the city's actions were not coercive. However, the court determined that the lien provisions in the agreements were too vague and indefinite to be enforceable, rendering the contracts invalid.The Supreme Court of Idaho affirmed the district court's summary judgment in favor of the plaintiffs regarding tenant-occupied properties but reversed the summary judgment in favor of the city concerning owner-occupied properties. The case was remanded for further proceedings consistent with the opinion. The plaintiffs were awarded costs as the prevailing party, but no attorney fees were granted to either side. View "Von Wandruszka v. City of Moscow" on Justia Law

Roberta Evans underwent a total hip replacement surgery performed by Dr. Mark B. Wright at St. Luke’s Magic Valley Regional Medical Center. Post-surgery, Evans experienced persistent pain and discomfort, which led her to seek a second opinion. Another doctor confirmed that her hip bone socket was abnormally anteverted, and subsequent revision surgery revealed a periprosthetic joint infection. Evans filed a lawsuit against Dr. Wright and St. Luke’s, alleging negligence in their follow-up care and treatment.The District Court of the Fifth Judicial District of Idaho dismissed Evans’s case, ruling that her claim was barred by the two-year statute of limitations under Idaho Code section 5-219(4). The court found that Evans’s surgical complications were objectively ascertainable by March 4, 2019, indicating that some damage was present. Her motion for reconsideration was denied.The Supreme Court of Idaho affirmed the district court’s decision. The court held that Evans’s medical malpractice claim was time-barred, as the statute of limitations began when her symptoms indicated some damage, which was before April 6, 2019. The court also found that the district court did not err in dismissing Evans’s complaint and that her equitable estoppel argument was without merit. The court denied attorney fees to both parties but awarded costs to Dr. Wright and St. Luke’s as the prevailing parties. View "Evans v. Wright" on Justia Law

Kerry Angelos filed a defamation lawsuit against Greg and Susan Schatzel, alleging they created a website that published defamatory comments about him. During the lawsuit, Angelos faced financial difficulties, leading to his interests in the lawsuit being auctioned at a sheriff’s sale to satisfy a preexisting judgment. Greg Schatzel purchased Angelos’s interests and substituted himself as the plaintiff, subsequently dismissing the lawsuit with prejudice. Angelos appealed, arguing that his defamation claims were personal and could not be deemed “property” subject to execution under Idaho law.The District Court of the Fourth Judicial District of Idaho granted Schatzel’s motion to substitute as the plaintiff and denied a motion by another creditor, Pacific Global Investment, Inc. (PGI), to intervene. The court found no legal basis to support Angelos’s contention that the sheriff’s sale was invalid or that substituting Schatzel violated public policy. Consequently, the court dismissed the lawsuit with prejudice.The Supreme Court of Idaho reviewed the case and held that defamation claims are personal and not assignable under Idaho law, referencing the precedent set in MacLeod v. Stelle. The court concluded that Angelos’s defamation claims could not be subject to execution as “other property” under Idaho Code section 11-201. The court vacated the district court’s order granting Schatzel’s motion to substitute and the judgment dismissing the case with prejudice. The case was remanded to determine which of Angelos’s remaining claims, if any, were properly transferred to Schatzel through the sheriff’s sale. The court also denied Schatzel’s request for attorney fees, awarding costs to Angelos as the prevailing party. View "Angelos v. Schatzel" on Justia Law

Grand Peaks, a nonprofit healthcare provider, applied for a full property tax exemption for its clinics and administrative offices in Rexburg, Idaho, under Idaho Code section 63-602C. Grand Peaks argued that it qualifies as a charitable organization and uses its property exclusively for charitable purposes, providing healthcare to underserved communities regardless of patients' ability to pay. The Madison County Board of Equalization granted a partial tax exemption of sixty-five percent, citing concerns about competition with for-profit healthcare providers and the revenue generated from insured patients.Grand Peaks appealed to the District Court of the Seventh Judicial District, which found that Grand Peaks qualified as a charitable organization and used its property exclusively for charitable purposes. However, the district court remanded the case to the Board for further fact-finding, suggesting that the partial tax exemption might be appropriate due to the "revenue-generating" nature of some of Grand Peaks' activities. The district court vacated the Board's sixty-five percent exemption, deeming it arbitrary and capricious.The Supreme Court of Idaho reviewed the case and reversed the district court's order for remand. The Court held that Grand Peaks is entitled to a full tax exemption under Idaho Code section 63-602C. The Court clarified that the proper test for tax exemption focuses on the exclusive use of the property for charitable purposes, not the income generated from the property. The Court found substantial and competent evidence supporting that Grand Peaks' properties are used exclusively for its charitable mission. The case was remanded to the district court with instructions to grant Grand Peaks a one hundred percent tax exemption for the properties at issue. Grand Peaks was awarded costs on appeal. View "Upper Valley Community Health Svcs, Inc. v. Madison County" on Justia Law

While employed as a bookkeeper for Castlerock Homes, Sarah Brizzee embezzled over $230,000 by writing fraudulent checks and using the company credit card for personal purchases. She also created fraudulent lien waivers and invoices to cover her tracks. The crimes were discovered in October 2018, and Brizzee was charged with grand theft and forgery in April 2019. She pleaded guilty to one count of each and was sentenced in March 2020 to a unified sentence of seven years, with two years determinate and five years indeterminate, but the court retained jurisdiction, placing her on a rider program. She was released from incarceration in October 2020 and placed on probation until October 2026.The District Court of the Seventh Judicial District of Idaho found that Idaho Code section 5-248 created a one-year statute of limitations for crime victims to file civil claims, starting from the offender's release from incarceration. Since Brizzee was released from her rider in October 2020, the court ruled that Castlerock's complaint, filed in September 2022, was untimely and dismissed the case with prejudice.The Supreme Court of Idaho reviewed the case and held that Idaho Code section 5-248 does not create a one-year limitations period but instead tolls the applicable limitations period until one year after the offender has been released from incarceration and has fully satisfied the sentence imposed. The court found that the district court erred in dismissing Castlerock’s complaint as untimely. The Supreme Court vacated the judgment and remanded the case for further proceedings, clarifying that the statute of limitations was tolled during Brizzee's incarceration and for one year after her release, making Castlerock's complaint timely. View "JK Homes, LLC v. Brizzee" on Justia Law

The Idaho Attorney General filed a petition seeking to prevent an initiative from appearing on the 2024 general election ballot. The initiative, proposed by Idahoans for Open Primaries, aims to replace Idaho’s closed party primary system with a non-partisan "top four primary" and implement ranked-choice voting for the general election. The Attorney General argued that the signatures supporting the initiative were obtained through false statements, violating Idaho Code section 34-1815, and that the initiative violated the single-subject rule of the Idaho Constitution by proposing two distinct changes to election laws.The Idaho Supreme Court dismissed the Attorney General’s petition on procedural grounds. The court held that allegations of fraud in the signature-gathering process must first be adjudicated in the district court. The court emphasized that its original jurisdiction to issue writs of prohibition and mandamus is limited and that the Secretary of State has no clear legal duty to invalidate signatures based on alleged fraud without a prior judicial determination. The court also found that the Attorney General’s challenge to the initiative on the grounds that it violated the single-subject rule was not ripe for review, as the initiative had not yet been approved by voters.The Idaho Supreme Court concluded that the Secretary of State’s role in the initiative process is ministerial and does not include adjudicating the validity of signatures based on alleged misrepresentations. The court dismissed the petition, allowing the initiative to proceed to the ballot, but noted that the Attorney General could pursue his claims in the appropriate district court. View "Labrador v. Idahoans for Open Primaries" on Justia Law

Samuel Hickman was electrocuted while working on a construction site when a boom crane contacted overhead power lines. Hickman and his wife filed a personal injury lawsuit against Boomers, LLC, its owner Michael Landon, and employee Colter James Johnson, alleging negligence and recklessness. Boomers moved for summary judgment, claiming immunity under Idaho’s Worker’s Compensation Law. Hickman argued that the accident fell under the “willful or unprovoked physical aggression” exception to the exclusive remedy rule. The district court granted summary judgment for Boomers and denied Hickman’s motion for reconsideration.The district court applied the 2020 amended version of Idaho Code section 72-209(3), which clarified the “willful or unprovoked physical aggression” exception, and concluded that Boomers did not intend to harm Hickman or have actual knowledge that injury was substantially likely. Hickman appealed, arguing that the district court should have applied the pre-amendment version of the statute and the standard from Gomez v. Crookham Co., which interpreted the exception to include conscious disregard of knowledge that an injury would result.The Supreme Court of Idaho reversed the district court’s decision, holding that the pre-amendment version of section 72-209(3) and the Gomez standard should apply. The court found that the additional evidence submitted by Hickman in his motion for reconsideration created a genuine issue of material fact regarding whether Johnson consciously disregarded the known risk of injury from the power lines. The case was remanded for further proceedings consistent with this opinion. View "Hickman v. Boomers, LLC" on Justia Law

This case involves a dispute over the sale of surplus state property owned by the Idaho Transportation Department (ITD). The property, located at 3311 West State Street in Boise, was declared surplus after a flood rendered its largest building unusable. The Idaho Department of Administration (DOA) initiated a bidding process, and the petitioners, a group of business entities, submitted the highest bid. Despite negotiating a purchase and sale agreement, the DOA did not finalize the sale due to legislative actions that revoked its authority to dispose of the property and transferred control back to the ITD Board.The petitioners filed an original action in the Idaho Supreme Court seeking writs of prohibition and mandate. They argued that the legislative provisions revoking the DOA's authority were unconstitutional, violating the single-subject rule of the Idaho Constitution. They sought a declaratory judgment to invalidate these provisions and compel the DOA to complete the sale. The Idaho House of Representatives and its Speaker intervened, and the State Board of Examiners disclaimed further participation, having fulfilled its statutory duties.The Idaho Supreme Court held that the petitioners lacked standing to bring the action. The court found that while the petitioners demonstrated a distinct and palpable injury from the halted sale, they failed to show that a favorable decision would redress their injury. The court noted that the petitioners did not have a legally enforceable right to purchase the property, as the DOA had discretion in concluding the sale. Additionally, the court determined that the petitioners did not meet the criteria for relaxed standing, as other parties, such as the DOA and ITD, could potentially bring the constitutional claim. Consequently, the court dismissed the petition for writs of prohibition and mandate. View "Hawkins Companies, LLC v. State" on Justia Law

The Idaho Attorney General filed a petition seeking to prevent an initiative from appearing on the 2024 general election ballot. The initiative, proposed by Idahoans for Open Primaries, aims to replace Idaho’s closed party primary system with a non-partisan “top four primary” and implement ranked-choice voting for the general election. The Attorney General argued that the signatures supporting the initiative were obtained through false statements and material omissions, violating Idaho Code section 34-1815, and that the initiative violated the single-subject rule of the Idaho Constitution by proposing two distinct changes to election laws.The Idaho Supreme Court dismissed the Attorney General’s petition on procedural grounds. The court held that allegations of fraud in the signature-gathering process must first be adjudicated in the district court. The court emphasized that its original jurisdiction to issue writs of prohibition and mandamus is limited and that such writs are proper only when a state actor has a clear legal duty to act. The court found that the Secretary of State had no clear legal duty to invalidate the signatures based on the Attorney General’s allegations and that the Secretary’s role in the initiative process is ministerial, not adjudicatory.The court also addressed the Attorney General’s claim that the initiative violated the single-subject rule. It concluded that this issue was not ripe for review because the initiative had not yet been approved by voters. The court stated that substantive challenges to an initiative’s constitutionality are not justiciable before the initiative becomes law. The court’s decision does not preclude the Attorney General from pursuing his claims in the district court. View "Labrador v. Idahoans for Open Primaries" on Justia Law

John Gomez, Gilbert Hurtado, and Jesus Hurtado were members of G&H Dairy, LLC, which defaulted on its loans in 2013. To avoid bankruptcy, they negotiated with Wells Fargo and signed a Letter of Intent (LOI) to distribute G&H's assets among themselves. Gomez and Jesus Hurtado purchased the personal property assets and assumed portions of G&H’s debt, but they could not agree on the sales price for the real property. Gomez sued the Hurtado brothers and G&H for breach of contract, estoppel, unjust enrichment, and breach of fiduciary duty, and sought judicial dissolution of G&H. The Hurtados counterclaimed for damages and also sought dissolution.The District Court of the Fifth Judicial District of Idaho granted summary judgment for the Hurtados on Gomez’s breach of contract claim, ruling the LOI unenforceable, but denied summary judgment on the other claims. After a bench trial, the court ordered the dissolution and winding up of G&H and dismissed the remaining claims. Gomez appealed.The Supreme Court of Idaho affirmed the district court’s decision. It held that the LOI was unenforceable as it was an offer contingent on future agreements and lacked definitive terms. The court also found no breach of fiduciary duty by the Hurtados, as the LOI was unenforceable and the parties had not agreed on the real property transfer terms. The court dismissed Gomez’s quasi-estoppel claim, concluding that the Hurtados did not change their legal position since the LOI was not enforceable. The court also upheld the district court’s final accounting and winding up of G&H, finding no error in the characterization of transactions or member allocations. The court awarded attorney fees to the Hurtados, determining that Gomez’s appeal was pursued unreasonably and without legal foundation. View "Gomez v. Hurtado" on Justia Law