Justia Idaho Supreme Court Opinion Summaries

Robert Nelson, a car salesman, sustained a back injury on March 29, 2018, while working for Dependable Auto Sales. He experienced significant back pain the following day, leading to a diagnosis of acute back pain with left radiculopathy. Nelson filed a worker’s compensation claim and underwent various treatments and evaluations. Medical opinions varied, with some attributing his back issues to preexisting conditions and obesity, while others recognized a work-related aggravation. Nelson also had a history of preexisting injuries, including knee surgeries and osteoarthritis.Nelson settled his worker’s compensation claim with his employer in September 2019 and subsequently filed a claim against the Idaho Industrial Special Indemnity Fund (ISIF) for total and permanent disability benefits. The Idaho Industrial Commission denied his claim, finding that Nelson failed to prove he was totally and permanently disabled or that he suffered a permanent impairment due to the work-related accident. The Commission’s decision was influenced by its determination that Nelson was not a credible witness, citing inconsistencies in his testimony and a prior conviction for insurance fraud.The Supreme Court of Idaho reviewed the case and affirmed the Commission’s decision. The Court found that substantial and competent evidence supported the Commission’s credibility determination, despite some errors in the Commission’s findings. The Court upheld the Commission’s conclusion that Nelson was not totally and permanently disabled, as the evidence indicated that there was still a labor market for him, even under the most restrictive limitations. The Court did not address the alternative finding regarding permanent impairment. View "Nelson v. State of Idaho, Industrial Special Indemnity Fund" on Justia Law

Jessica Wiseman and her children sued Dr. Nathan Rencher and others for the wrongful death of Eric Wiseman, alleging medical malpractice and gross negligence. Rencher, the only defendant subject to Idaho's prelitigation screening panel requirement, moved for summary judgment, arguing that the Wisemans failed to comply with this requirement. He supported his motion with the panel’s advisory decision, filed under seal. The district court granted Rencher’s motion, concluding that the Wisemans did not meet the prelitigation requirement based on the advisory decision. The Wisemans also sought to disqualify the district judge, which was denied.The district court, part of the Seventh Judicial District of Idaho, ruled that the advisory decision could be considered to determine compliance with the prelitigation requirement. The court found the statutes ambiguous and concluded that they allowed limited review of the advisory decision. The court also ruled that the statutes controlled over conflicting Idaho Rules of Evidence. Consequently, the district court granted summary judgment in favor of Rencher, finding no genuine issue of material fact regarding the Wisemans' compliance with the prelitigation requirement.The Supreme Court of Idaho reversed the district court’s decision, holding that the prelitigation screening statutes unequivocally precluded judicial review of the advisory decision for any purpose. The court emphasized that the statutes clearly stated there should be no judicial review and that parties should not be affected by the panel’s conclusions. The Supreme Court remanded the case for further proceedings. Additionally, the court declined to disqualify the district judge on remand, distinguishing this case from precedent and finding no appearance of bias. Neither party was awarded attorney fees on appeal, as both prevailed in part. View "Wiseman v. Rencher" on Justia Law

The case involves a dispute between Brian L. Porter, trustee of the Brian L. Porter Revocable Trust, and Marvin A. Remmich, manager of McMillan Storage LLC, an Idaho limited liability company. The conflict centers on the management of the LLC and the conduct of its members. Remmich initially filed a complaint in California against Porter, alleging various breaches related to the construction of the LLC’s storage facility. Porter later filed a complaint in Idaho, accusing Remmich of mismanaging the LLC. Both parties reside in California, and the LLC’s principal place of business is also in California.In the California action, the court denied Porter’s motion to dismiss on grounds of forum non conveniens, retaining jurisdiction over the case. Subsequently, the Idaho District Court dismissed Porter’s claims without prejudice under Idaho Rule of Civil Procedure 12(b)(8), which allows for dismissal when another action between the same parties for the same cause is pending. The district court reasoned that the California court could adjudicate the entire controversy, and concurrent litigation would lead to increased costs and potentially inconsistent judgments.The Supreme Court of Idaho affirmed the district court’s decision. It held that the district court did not abuse its discretion in dismissing the Idaho action. The court found that the parties and claims in both actions were essentially the same, and the California court was in a position to resolve the entire dispute. The court emphasized considerations of judicial economy, minimizing litigation costs, and avoiding inconsistent judgments. Consequently, the Idaho action was dismissed without prejudice, and Porter was directed to pursue his claims in the California court. View "Porter v. Remmich" on Justia Law

The case involves a failed business relationship between Mike Jones, Jeremy Sligar, and Sligar's business, Overtime Garage, LLC. Jones claimed they formed a joint venture in 2011 to buy and sell used vehicles, which Sligar disputed. The relationship deteriorated, and Sligar terminated the venture in 2016. Jones filed a complaint in 2016 seeking a declaratory judgment, dissolution of the joint venture, and other relief. Sligar counterclaimed for similar relief. During the litigation, Safaris Unlimited, LLC, bought Jones's interest in the case at a sheriff's sale and settled the case by dismissing Jones's claims against Sligar.The District Court of the Fifth Judicial District, Twin Falls County, denied Jones's motion to set aside the judgment in the first case (Sligar I) and granted summary judgment to Sligar in the second case (Sligar II), finding that Jones's claims were barred by res judicata. The court also awarded attorney fees to Sligar and Safaris, finding Jones's motion to set aside the judgment was frivolous and untimely. Jones appealed these decisions, arguing the consolidation of small claims actions with Sligar I was improper and that his Rule 60(b) motion was timely.The Supreme Court of Idaho affirmed the district court's decisions. It held that the consolidation of the small claims actions with Sligar I was proper, as the small claims were related to the disputed property in Sligar I. The court also found that Jones did not file his Rule 60(b) motion within a reasonable time, as he delayed over five months without a valid reason. Additionally, the court upheld the summary judgment in Sligar II, agreeing that Jones's claims were barred by res judicata. The court awarded attorney fees to Sligar for the appeal in Sligar I but not in Sligar II, as Sligar did not prevail on its cross-appeal. View "Jones v. Sligar" on Justia Law

This case involves an insurance dispute following a fatal car accident. Jay Lanningham was killed in a car accident caused by an underinsured motorist. Lanningham had an insurance policy with Farm Bureau Mutual Insurance Company of Idaho that included underinsured motorist (UIM) coverage. However, Farm Bureau denied the UIM claims made by Lanningham's adult children, Jeremy and Jamie, for their father's wrongful death. The insurance company argued that the siblings did not qualify as insured persons under the policy since they did not reside with Lanningham.The District Court of the Fourth Judicial District of the State of Idaho granted Farm Bureau's motion for summary judgment, ruling that the insurance company rightfully denied payment to Jamie and Jeremy as they did not qualify as insured persons under the policy.The Supreme Court of the State of Idaho affirmed the lower court's judgment in favor of Farm Bureau. The court found that the plain language of Lanningham’s insurance policy precluded non-insureds from recovering UIM benefits. The court also held that the policy did not violate Idaho Code section 49-1212(12), which prohibits reduced liability coverage for family or household members. Furthermore, the court found that the case law precedent, Farm Bureau Mutual Insurance Company of Idaho v. Eisenman, was applicable and remains good law. The court concluded that neither Jamie nor Jeremy, as non-insured heirs, could recover UIM benefits under the plain language of the policy and Idaho Code section 41-2502. View "Lanningham v. Farm Bureau" on Justia Law

The case revolves around Thomas E. Hennig, Jr., who was discharged from his job at Money Metals Exchange, L.L.C. after making a controversial comment on the company's instant messaging system. Hennig referred to himself as his employer’s “good little Nazi” in a joke about enforcing the company’s time clock rules. After his termination, Hennig applied for unemployment benefits, but his application was denied by the Idaho Department of Labor (IDOL) on the grounds that he was discharged for misconduct connected with his employment. Hennig appealed this decision to the Idaho Industrial Commission, which upheld the IDOL's decision.Hennig then appealed to the Supreme Court of the State of Idaho, arguing that the Commission’s decision was unsupported by competent and substantial evidence. He contended that his use of the term "Nazi" was not objectively unprofessional and that the company had tolerated racist remarks from another employee. The Supreme Court of Idaho reversed the Commission’s decision and remanded the case for further proceedings. The court found that the Commission had failed to properly analyze whether the company's expectations of Hennig's behavior were objectively reasonable, given evidence that it had tolerated racist comments from another co-worker and then promoted him to a supervisory position. The court also found that the Commission had failed to consider Hennig's claim that the company had encouraged his unorthodox humor. View "Hennig v. Money Metals Exchange" on Justia Law

This case involves a dispute between siblings Elizabeth and Jason Carter, who are both licensed dentists and co-owners of Carter Dental. In 2020, Jason accused Elizabeth of misusing the practice’s funds for her personal benefit. The parties agreed to mediation, which resulted in a settlement agreement that included a noncompete clause. Elizabeth later refused to sign a written mutual release, leading Jason to move to enforce the settlement agreement. The district court found the settlement agreement and noncompete clause enforceable and dismissed the case with prejudice. Elizabeth appealed, arguing that the noncompete clause and the settlement agreement were unenforceable.The Supreme Court of the State of Idaho affirmed the district court's judgments. The court found that Elizabeth was estopped from arguing that the settlement agreement was unenforceable because she had not appealed the district court’s dismissal of the case with prejudice. The court also held that the district court did not err in awarding attorney fees and costs to Jason and Carter Dental. The court concluded that Jason and Carter Dental were entitled to attorney fees and costs on appeal. View "Carter Dental v. Carter" on Justia Law

This case involves a dispute between two neighboring landowners, David W. Axelrod, as Trustee of the David W. Axelrod Family Trust, and Reid Limited Partnership (RLP) and Michael Reid, an individual. The dispute arose from a settlement agreement concerning the real property and easement rights of the two parties. Axelrod purchased a property in Teton County in 2003, which was not accessible by road. Reid, who owned and operated an organic dairy farm nearby, preferred Axelrod to build onto an existing dirt road on Reid's property rather than using two easements provided in Axelrod's deed. In 2004, Axelrod built onto the existing dirt road, referred to as the "RLP Easement." However, the relationship between Axelrod and Reid began to sour in 2011, leading to a series of disputes and legal actions.The district court initially concluded that Axelrod did not have an express easement for use of the RLP Easement, but he did have an easement by estoppel. The parties then executed a settlement agreement and stipulated to dismiss the suit. However, disagreements over the implementation of the settlement agreement led to further litigation. The district court granted Axelrod's motion for summary judgment, concluding that Reid had failed to properly support any assertion of fact or address the assertions of fact in Axelrod's motion for summary judgment.On appeal, the Supreme Court of the State of Idaho affirmed in part, vacated in part, and remanded the case for further proceedings. The court affirmed the grant of summary judgment against Reid individually and affirmed the district court's judgment dismissing RLP's counterclaims for conversion and violation of the implied covenant of good faith and fair dealing. The court also affirmed the judgment of the district court on Axelrod's breach of contract claim and the judgment of the district court refusing to allow amendment of the pleadings to add RFLP as a party. However, the court vacated the judgment of the district court dismissing RLP's trespass claim. The court also vacated the attorney fee award as against RLP and remanded for further proceedings consistent with this opinion. View "Axelrod v. Reid Limited Partnership" on Justia Law

The case involves Scott and Natalie Pinkham, who contracted with Three Peaks Homes, LLC, for the construction of a custom home. The construction did not go as planned and the contract was terminated before the home was completed. Three Peaks subsequently filed two $600,000 mechanics’ liens against the Pinkhams’ home. The Pinkhams then filed a complaint against David Plate, Rebeccah Jensen, Three Peaks, Rebel Crew Construction, LLC, and Legacy Management Enterprises, LLC, asserting several causes of action.The district court denied the Pinkhams’ motion for summary judgment. Later, the Pinkhams’ attorney, Lance Schuster, filed a motion to withdraw as counsel for Plate, Jensen, Three Peaks, and Legacy, which the court granted. The court ordered Appellants to appoint another attorney or appear in person within twenty-one days of service of the order, failing which, the court may enter default judgment against them. The court clerk served a copy of the withdrawal order on Appellants via first class mail.The Pinkhams moved for the entry of default and default judgment against Appellants and for dismissal of Appellants’ counterclaims with prejudice. The district court granted the Pinkhams’ motion without a hearing. Appellants later secured new counsel and filed a motion to set aside the default and default judgment under Idaho Rule of Civil Procedure 60(b)(1), (4), and (6). The district court denied Appellants’ motion.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision denying the motion to set aside the default and default judgment. The court held that the district court did not err in concluding that Appellants failed to demonstrate good cause to set aside the entry of default. The court also held that Appellants have failed to establish a right to relief under Rule 60(b). The court declined to award attorney fees on appeal. View "Pinkham v. Plate" on Justia Law

This case involves a dispute over water rights between James Whittaker and Whittaker Two Dot Ranch LLC (collectively "Whittaker") and Bruce and Glenda McConnell. The McConnells own seven water rights associated with their property adjacent to Lee Creek, which they historically diverted from two points: the Upper Diversion and the Lower Diversion. However, after a 2014 enforcement action by the Idaho Department of Water Resources (IDWR), the McConnells lost their ability to divert water via the Lower Diversion because they failed to claim it in the Snake River Basin Adjudication (SRBA). The McConnells subsequently filed an application to add the Lower Diversion as an authorized point of diversion to their seven water rights. Whittaker, the McConnells’ upstream neighbor, protested the application, fearing that the additional diversion point would injure his junior water rights.The IDWR hearing officer approved the McConnells’ application, determining that the transfer would not injure Whittaker’s water rights. The officer used the historic confluence of Stroud Creek and Porcupine Creek, located upstream of the Upper Diversion, for the injury analysis. Whittaker appealed to the Director of IDWR, who affirmed the hearing officer's decision. Whittaker then sought judicial review from the district court.The district court reversed the Director's decision, holding that the modern confluence, located downstream of the Upper Diversion, should be used for the injury analysis. The court found that the West Springs Ditch, which diverts water from Stroud Creek through Whittaker’s property, was an alteration of the stream flow and not an unauthorized diversion. The court concluded that approving the McConnells’ application would injure Whittaker’s water rights and held that the application could be approved subject to a condition subordinating the use of the McConnells’ Lower Diversion to Whittaker’s water right. The McConnells appealed to the Supreme Court of the State of Idaho.The Supreme Court reversed the district court's decision. The court held that the West Springs Ditch is a diversion, not an alteration, of Stroud Creek. The court also found that the West Springs Ditch is an unauthorized diversion because it was not claimed as a point of diversion in the SRBA. Therefore, the court concluded that the Director of IDWR correctly used the historic confluence for the injury analysis. The court held that the district court erred in using the modern confluence for the injury analysis and reversed the district court’s decision. View "Whittaker v. Idaho Department of Water Resources" on Justia Law