Justia Idaho Supreme Court Opinion Summaries

The United States District Court for the District of Idaho certified a question of law to the Idaho Supreme Court. Plaintiff was a prisoner in the custody of the Idaho Department of Correction (IDOC), currently incarcerated at the Idaho State Correctional Institution (ISCI). He asserts that he, and all IDOC prisoners, have a state-created liberty interest in being employed, arising from Idaho Code [section] 20-209. Plaintiff asserted the statute contained a "very specific, clear, and unambiguous" mandate that the Board of Correction must provide all inmates with employment during incarceration. The federal court asked the Idaho Supreme Court for guidance on plaintiff's contention: whether Idaho Code section 20-209 required the state board of correction to provide employment for all prisoners, and, if so, what was the minimum the board must do to implement the statute’s mandate? The Supreme Court responded, finding 20-209 required the Board to make employment available for all prisoners in the form of: (1) labor assignments as prescribed by the Board’s rules and regulations; and/or (2) implementation of statutory work programs managed by the Board in accordance with its rules and regulations. The Board retained discretion to manage these prisoner employment opportunities pursuant to its broad control over the correctional system. Section 20-209 did not create a right to paid or unpaid work during a prisoner’s period of incarceration or establish an employer-employee relationship between the Board and the prisoner. At a minimum, the Board must comply with legislation controlling its responsibilities managing prisoner employment and with its own rules and regulations. View "Goodrick - Certified Question of Law" on Justia Law

This appeal arose from Stan and Donna Griffiths' divorce. Donna appealed the trial court's decisions: (1) denying her motion to dismiss Stan’s appeal; and (2) reversing in part and affirming in part the magistrate court’s division of the marital estate. On appeal, Donna argued the district court erred in denying her motion to dismiss Stan’s intermediate appeal pursuant to the acceptance of the benefits doctrine. Donna further argued the district court erred in reversing several of the magistrate court’s rulings, including its valuation of hospital ownership shares, its award of an equalization payment to Donna, and its award of spousal maintenance to Donna. Stan cross-appealed, arguing that the district court erred in affirming the magistrate court’s admission of expert testimony and unequal division of marital property. After review of the trial court record, the Idaho Supreme Court determined the district court did not err in denying Donna’s motion to dismiss the appeal pursuant to the acceptance of the benefits doctrine, and did not err in affirming the magistrate court's admission of expert testimony. However, the district court erred in reversing the magistrate court’s valuation of the MVH Class A units, and erred in concluding that the magistrate court failed to consider Stan’s tax consequences. Further, the Supreme Court concluded the trial court erred in reversing Donna's equalization payment award, and in remanding her spousal maintenance award. Judgment was affirmed in part and reversed in part. The matter was remanded for further proceedings. View "Griffiths v. Griffiths" on Justia Law

In the summer of 2014, Mark and Jennifer Porcello sought to purchase property In Hayden Lake, Idaho. After making various pre-payments, the amount the couple was still short on a downpayment. Mark and Jennifer could not qualify for a conventional loan themselves. They hoped another property in Woodinville, Washington, owned by Mark’s parents, in which Mark and Jennifer claimed an interest, could be sold to assist in the purchase of the Hayden Lake property. In an effort to help Mark and Jennifer purchase the property, Mark’s parents, Annie and Tony Porcello, obtained financing through a non-conventional lender. "In the end, the transaction became quite complicated." Annie and Tony’s lawyer drafted a promissory note for Mark and Jennifer to sign which equaled the amount Annie and Tony borrowed. In turn, Mark signed a promissory note and deed of trust for the Hayden Lake house, in the same amount and with the same repayment terms as the loan undertaken by his parents. In mid-2016, Annie and Tony sought non-judicial foreclosure on the Hayden Lake property, claiming that the entire balance of the note was due and owing. By this time Mark and Jennifer had divorced; Jennifer still occupied the Hayden Lake home. In response to the foreclosure proceeding, Jennifer filed suit against her former in-laws seeking a declaratory judgment and an injunction, arguing that any obligation under the note had been satisfied in full when the Woodinville property sold, notwithstanding the language of the note encumbering the Hayden Lake property. Annie and Tony filed a counter-claim against Jennifer and a third-party complaint against Mark. A district court granted Jennifer’s request for a declaratory judgment. However, by this time, Annie and Tony had died and their respective estates were substituted as parties. The district court denied the estates’ request for judicial foreclosure, and dismissed their third-party claims against Mark. The district court held that the Note and Deed of Trust were latently ambiguous because the amount of the Note was more than twice the amount Mark and Jennifer needed in order to purchase the Hayden Lake property. Because the district court concluded the note and deed of trust were ambiguous, it considered parol evidence to interpret them. Ultimately, the district court found the Note and Deed of Trust conveyed the Hayden Lake property to Jennifer and Mark “free and clear” upon the sale of the Woodinville property. Annie’s and Tony’s estates timely appealed. Finding that the district court erred in finding a latent ambiguity in the Note and Deed of Trust, and that the district court's interpretation of the Note and Deed of Trust was not supported by substantial and competent evidence, the Idaho Supreme Court vacated judgment and remanded for further proceedings. View "Porcello v. Estates of Porcello" on Justia Law

Plaintiff-appellant Nicole Packer was injured when she fell from an unlit loading dock at the Kingston Plaza in Idaho Falls, Idaho. Packer, working as a vendor at a Christmas-themed exposition, alleged she had been directed to use the rear exit by a representative of Riverbend Communications, LLC, the organizer of the exposition and the occupier of the property at the heart of this litigation. The rear exit was unlit, and when Packer left the building, she was unable to re-enter. Because of the lack of light, Packer did not realize she was on a loading dock which was five feet above the adjoining pavement. When she proceeded towards the lit parking lot, she fell to the asphalt and was seriously injured. Packer sued Kingston Properties (owner of the property), as well as Riverbend Communications, LLC. Following discovery, the defendants sought and were granted summary judgment. Packer unsuccessfully moved for reconsideration. She timely appealed the district court’s decision granting summary judgment in favor of Riverbend. After review, the Idaho Supreme Court determined the district court erred in granting summary judgment in favor of Riverbend because Packer was an invitee; the district court erred as a matter of law in determining Packer was a licensee. Because Packer was an invitee, Riverbend owed her the duty to warn her of hidden or concealed dangers and to keep the property in reasonably safe condition. On these facts, the Supreme Court concluded a jury could have reasonably concluded that Riverbend breached either or both of the duties it owed to Packer. Accordingly, the district court’s decision granting summary judgment was reversed. View "Packer v. Riverbend Communications" on Justia Law

In 1996, Jack K. Davis (“Jack Sr.”) and Jeanne H. Davis created the Davis Family Trust (“Trust”), of which they were the grantors, trustees, and primary beneficiaries. The Trust was revocable until either Jack Sr. or Jeanne died, at which time it would become irrevocable. Upon the death of the surviving grantor, the Trust would terminate and the property would be divided equally among Jack Sr. and Jeanne’s three children: John (Jack) Davis (“Jack”), Greg Davis, and Drinda Ann Bell. The Trust became irrevocable in 2003 when Jack Sr. died. Nearly thirteen years later, Greg filed a complaint against his mother Jeanne, and his siblings Jack and Drinda, demanding: (1) an accounting and removal of trustees; (2) an order enjoining the expenditure of any funds; and (3) the appointment of a receiver. The magistrate court denied Greg’s motion to compel an accounting, finding that Greg and his siblings were “contingent residual beneficiaries” who did not have any rights relative to the Trust until Jeanne’s death. On intermediate appeal, the district court reversed, holding the magistrate court failed to give due consideration to the distinction between revocable and irrevocable trusts. The district court held Greg’s rights vested at the time the Trust became irrevocable when Jack Sr. died in 2003. The district court remanded the case for further proceedings. Jack appealed to the Idaho Supreme Court, but finding no reversible error, the Supreme Court affirmed the district court. View "Davis v. Davis" on Justia Law

The issue this case presented for the Idaho Supreme Court's review centered on a waste ditch that drained surface water from property owned by Lora Roberts through property owned by Thomas and Deanna Jensen (the Jensens). The ditch itself passed through a man-made culvert under a county road between the properties. The Jensens filled in the portion of the waste ditch located on their property in 2013. In February 2017, Roberts’ property experienced significant flooding. The flooding damaged her home as well as horse feed stored in the barn. It also forced her to relocate her horses from her property. Roberts filed an action against the Jensens, alleging trespass and nuisance, as well as seeking a declaratory judgment to establish that Roberts had an interest in the waste ditch on the Jensens’ property as an easement on the basis that the ditch was an established natural servitude. The district court ultimately granted the Jensens’ motion for summary judgment against Roberts, and denied Roberts’ motion for summary judgment. The district court also dismissed the nuisance claim because the flooding was not caused by a natural servitude, and therefore a nuisance action was not applicable. The district court then denied Roberts’ request for a declaratory judgment. Roberts moved unsuccessfully for reconsideration, and her appeal followed. After review of the trial court record, the Supreme Court affirmed the district court’s order granting summary judgment against Roberts. View "Roberts v. Jensen" on Justia Law

This appeal involved the enforceability of a premarital agreement between Julie Neustadt and Mark Colafranceschi. Before the two were married, they entered into a premarital agreement that required Neustadt to obtain a two-million-dollar life insurance policy naming Colafranceschi as the beneficiary. The agreement required Neustadt to keep the policy in force after termination of the marriage. During the divorce proceedings, Neustadt challenged the enforceability of this provision, arguing that the insurance clause was void as against public policy to the extent it applied after divorce. The magistrate court agreed that the contractual provision was void as against public policy. However, on appeal, the district court reversed, concluding the insurance clause did not violate any public policy in Idaho. Neustadt appealrf, arguing that the district court erred in finding the insurance clause valid and enforceable because, following the parties’ divorce, Colafranceschi had no insurable interest in Neustadt’s life. Colafranceschi also filed a cross-appeal, arguing: (1) the magistrate court erred in denying certain discovery requests; (2) the lower court erred by failing to address his objection to Neustadt’s motion in limine; and (3) the lower courts’ erred in their findings that Colafranceschi failed to prove he was fraudulently induced to sign the premarital agreement to get him to return to the couple’s marital home. The Idaho Supreme Court affirmed the district court decision in its entirety: (1) the Insurance Clause was not void as against public policy; (2) any error regarding discovery was forfeited; (3) there was no evidence that the magistrate court coerced Colafranceschi into withdrawing his extreme cruelty claim; and (4) substantial and competent evidence supported the magistrate court’s conclusions that Colafranceschi was not fraudulently induced regarding equity in the Osprey home. View "Neustadt v. Colafranceschi" on Justia Law

In 2015, the Kenworthys began construction on a two-story boat garage on Lake Coeur d’Alene. The Newtons’ property overlooked the location of the Kenworthys’ boat garage. The new structure was much larger than the original boat garage and had a second floor. After construction began, the Newtons took issue with the size of the new structure, and sued the Idaho Department of Lands (IDL) and the Kenworthys’ related family entities (the LLC Respondents), asserting claims of public and private nuisance and requesting injunctive relief to mandate the removal of the offending structure. The parties filed cross-motions for summary judgment. The district court held that the Newtons failed to establish that the boat garage was illegal and that their nuisance claims failed as a matter of law. The district court subsequently entered judgments in favor of IDL and the LLC Respondents. After the district court denied the Newtons’ motion for reconsideration, the Newtons appealed. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Newton v. MJK/BJK MBK Lake" on Justia Law

Royal Von Puckett made the winning $100 bid at a sheriff’s sale for two unsatisfied divorce judgments totaling over $230,000. His attorney, Vernon Smith, was the judgment debtor on both judgments. Sharon Bergmann, Smith’s ex-wife, was the judgment creditor on both judgments. The district court concluded that the sale should have been set aside because of grossly inadequate consideration and procedural irregularities associated with the sale. Puckett appealed that order. Finding the district court did not abuse its discretion in setting aside the sheriff's sale, the Idaho Supreme Court affirmed. View "Puckett v. Bergmann" on Justia Law

The issue this case presented for the Idaho Supreme Court's review was the judicial review of a validation order issued by the Worley Highway District Board of Commissioners (the Highway District). The order validated Road No. 20 (also known as Sunny Slopes Road) across the Northwest and Northeast Quarters of Section 34, Township 47 North, Range 4 West, Boise Meridian, Kootenai County, Idaho. The purported road crossed properties owned by the Richel Family Trust and property owned by Jeanne Buell. The Trust did not contest the validation of the road in the Northwest Quarter of Section 34. However, the Trust requested judicial review of the validation of a portion of the road in the Northeast Quarter of Section 34. The district court affirmed the Highway District’s validation order. The Trust appealed the judicial review and affirmation, arguing the deed that purportedly conveyed the public right-of-way was void because it contained an insufficient description due to the loss of extrinsic evidence mentioned in the deed. Additionally, the Trust argued that many of the Highway District’s factual findings and legal conclusions were not supported by substantial and competent evidence. Further, the Trust argued that if the Highway District’s validation order was affirmed, it amounted to an unconstitutional taking under both the Idaho and United States constitutions. After review, the Supreme Court affirmed the district court’s order affirming the Highway District’s validation order. The Court determined the Trust could not establish an actual taking. View "Richel Family Trust v. Worley Hwy Dist" on Justia Law