Justia Idaho Supreme Court Opinion Summaries

Amanda Mitchell filed for a civil protection order against Nicholas Ramlow in October 2020, alleging that he was stalking her by tracking her movements and placing a tracking device on her car. The magistrate court issued a temporary ex parte protection order and scheduled a hearing. Due to COVID-19 mask mandates, Ramlow was denied entry to the courthouse for refusing to wear a mask, leading to the hearing being rescheduled. At the rescheduled hearing, Ramlow was again absent, and the magistrate court issued a one-year protection order requiring him to attend a 52-week domestic violence course and review hearings.Ramlow filed a motion for reconsideration, which was denied. He then appealed to the district court. The protection order was extended but expired before the district court heard the appeal. The district court requested supplemental briefing on mootness and ultimately dismissed the appeal as moot, finding no applicable exceptions to the mootness doctrine. Ramlow appealed the district court's decision, arguing that his appeal still presented justiciable issues and fell within exceptions to the mootness doctrine.The Supreme Court of Idaho reviewed the case and affirmed the district court's dismissal. The court held that the appeal was moot because the protection order had expired, and no exceptions to the mootness doctrine applied. The court found that the issues were too fact-specific to be capable of repetition yet evading review, there were no collateral legal consequences, and the case did not raise issues of substantial public interest. The court also declined to vacate the expired protection order and denied attorney fees to both parties, awarding costs to Mitchell as the prevailing party. View "Mitchell v. Ramlow" on Justia Law

Nattalia Castell was employed as a senior accountant for Money Metals Exchange, LLC. She was discharged after allegedly mishandling an Idaho Department of Labor (IDOL) notice regarding her boyfriend's unemployment benefits application. Castell applied for unemployment benefits, but an IDOL appeals examiner excluded her boyfriend from testifying, denied her request to reopen the hearing to read a statement, and found that she was terminated for employment-related misconduct, making her ineligible for benefits.Castell appealed to the Idaho Industrial Commission, which denied her request to reopen the hearing and affirmed the appeals examiner's decision. The Commission found that Castell's actions constituted misconduct, as she failed to disclose a conflict of interest and mishandled the notice. Castell then appealed to the Idaho Supreme Court.The Idaho Supreme Court reviewed the case and affirmed the Commission's decision. The Court held that the appeals examiner did not err in excluding the boyfriend's testimony or in denying Castell's request to reopen the hearing. The Court also found that the Commission's determination that Castell was discharged for employment-related misconduct was supported by substantial and competent evidence. The Court concluded that Castell's actions disregarded a standard of behavior that Money Metals had a right to expect from its employees, and her claim of retaliation was not supported by evidence. View "Castell v. IDOL" on Justia Law

TCR, LLC, a Wyoming limited liability corporation, filed a lawsuit against Teton County, Idaho, after the County refused to record a Condominium Plat for property within a planned unit development (PUD) owned by TCR. TCR sought declaratory and injunctive relief, claiming the lot had already been approved for condominium development, and also alleged breach of a 1996 settlement agreement between the County and TCR’s predecessor. The district court granted TCR’s motion for summary judgment on the declaratory and injunctive relief claim, ordering the County to record the Condominium Plat, but granted the County’s motion for summary judgment on the breach of contract claim.The district court found that the County had previously approved amendments to the PUD Plat in 2018 and 2019, allowing TCR to build sixteen standalone condominiums on Lot 12B. The County’s refusal to record the Condominium Plat was based on an alleged site plan from 1995, which the district court found inadmissible. The district court concluded that the County had no legal basis to refuse the recording and enjoined the County from preventing TCR’s attempts to record the Plat.The Supreme Court of Idaho affirmed the district court’s decision to grant TCR’s claim for declaratory and injunctive relief, holding that the County had no valid reason to refuse the recording. However, the Supreme Court reversed the district court’s grant of summary judgment to the County on the breach of contract claim, finding that there were genuine issues of material fact regarding whether the County breached the 1996 Settlement Agreement. The case was remanded for further proceedings on this issue.The Supreme Court also found that the district court erred in denying TCR’s second motion to enforce, which sought to compel the County to issue building permits after the Condominium Plat was recorded. The Court awarded TCR its attorney fees and costs on appeal, concluding that the County acted without a reasonable basis in fact or law. View "TCR, LLC v. Teton County" on Justia Law

This case involves the reformation of a trust to remove male beneficiary restrictions and replace them with gender-neutral language to benefit successive generations of the Terteling family. Joseph L. Terteling, his former wife Carolyn E. Terteling, and their three granddaughters filed a petition to reform Terteling Trust No. 6 to reflect the alleged original intentions of the trustors to benefit Joseph’s successive generations, regardless of gender. Thomas J. Terteling, a contingent beneficiary, objected, arguing that the petitioners could not demonstrate by clear and convincing evidence that a mistake was made in the drafting of the Trust or that it was the intention of all the trustors to benefit successive generations regardless of gender.The magistrate court granted the petition, concluding that the stipulated facts demonstrated by clear and convincing evidence that a drafting error had occurred in restricting the class of beneficiaries to male children only. The court found that the trustors intended to benefit all the children and descendants of Joseph, regardless of gender. Thomas J. appealed to the district court, which affirmed the magistrate court’s decision.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The Court held that substantial and competent evidence supported the magistrate court’s findings that a mistake occurred in the drafting of the Trust and that the trustors intended to benefit a gender-neutral class of heirs. The evidence included declarations from Joseph and Carolyn, a 1978 affidavit signed by all the trustors, and TEDRA agreements from 2013 and 2021. The Court concluded that the male-only beneficiary restriction was a mistake and that the original intent of the trustors was to benefit successive generations of the family, regardless of gender. View "Terteling v. Terteling" on Justia Law

In 2018, Dustin Clover sustained injuries while removing irrigation drip tape from a seed field while working for Crookham Company. Clover filed a complaint against Crookham, alleging that his injuries fell within an exception to the exclusive remedy rule under Idaho’s Worker’s Compensation statutes, which allows for a separate civil action if the employer commits an act of “willful or unprovoked physical aggression.” Crookham moved for summary judgment, arguing that Clover failed to provide evidence supporting this claim. The district court agreed and granted summary judgment in favor of Crookham. Clover’s motion for reconsideration was also denied, leading him to appeal.The District Court of the Third Judicial District of Idaho initially reviewed the case. The court found that Clover’s injuries occurred during the course and scope of his employment and were covered by worker’s compensation. It concluded that Clover did not present sufficient evidence to show that Crookham’s actions met the “willful or unprovoked physical aggression” exception to the exclusive remedy rule. The court granted summary judgment to Crookham and denied Clover’s motion for reconsideration, which included new evidence and arguments that were deemed untimely and insufficient to alter the court’s original decision.The Supreme Court of the State of Idaho reviewed the case on appeal. The court affirmed the district court’s decision, holding that Clover failed to demonstrate that Crookham engaged in conduct knowing that employee injury would result. The court found no evidence that Crookham consciously disregarded knowledge of a significant risk posed by the drip tape lifter. Additionally, the court upheld the district court’s exclusion of evidence related to subsequent remedial measures and denied Clover’s motion for reconsideration, concluding that the new evidence presented did not raise a genuine issue of material fact. The Supreme Court awarded costs to Crookham as the prevailing party. View "Clover v. Crookham Company" on Justia Law

This case involves child custody proceedings between Isaac William Hess and Lisa Ann Hess, who have two minor children registered as members of the Cherokee Nation. Isaac alleged that Lisa abused the children by spanking them with a PVC pipe and claimed she was a negligent mother. During the proceedings, Isaac's father was briefly granted emergency guardianship by the District Court of the Cherokee Nation, but the case was dismissed due to jurisdictional issues. The Idaho magistrate court awarded Lisa sole physical custody and joint legal custody with final decision-making authority, and ordered Isaac to pay child support backdated to January 1, 2021.Isaac appealed to the district court, arguing that the magistrate court erred by not consulting with the Cherokee Nation court regarding jurisdiction, failing to refer his child abuse allegations to the Idaho Department of Health and Welfare (DHW), focusing on only one statutory factor in awarding custody, effectively granting Lisa sole legal custody without proper findings, and backdating the child support award. The district court affirmed the magistrate court's decisions on jurisdiction, the child abuse referral, and physical custody, but Isaac appealed further.The Supreme Court of Idaho affirmed the district court's decisions on jurisdiction, the child abuse referral, and physical custody. The court held that the magistrate court correctly determined it had jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) and that Isaac's allegations did not constitute child abuse under Idaho law. However, the court reversed the district court's affirmation of the magistrate court's decisions on legal custody and backdated child support. The magistrate court's legal custody decision was found to be internally contradictory, and its decision to backdate child support deviated from the Idaho Child Support Guidelines without explanation. The case was remanded for further proceedings on these issues. The court also awarded Lisa partial attorney fees for responding to Isaac's jurisdictional argument. View "Hess v. Hess" on Justia Law

The case involves the Schrivers, who sought damages after their cat, Gypsy, died following a veterinary procedure and was subjected to an unauthorized necropsy by Dr. Raptosh and Lakeshore Animal Hospital. The Schrivers claimed non-economic damages for emotional distress and loss of companionship, arguing that the emotional bond between pet and owner should be compensable. They also sought economic damages based on the pet's value to them.The District Court of the Third Judicial District of Idaho granted summary judgment in favor of Dr. Raptosh and Lakeshore on several claims, including negligent infliction of emotional distress, intentional infliction of emotional distress, and lack of informed consent. The court denied the Schrivers' claim for emotional distress damages related to trespass to chattels/conversion but allowed the "value to owner" measure of economic damages for the loss of Gypsy.The Supreme Court of Idaho affirmed the district court's decision in part and reversed in part. The court upheld the denial of emotional distress damages for trespass to chattels/conversion, agreeing that such damages are limited to independent torts of negligent or intentional infliction of emotional distress. The court also affirmed the summary judgment on the negligent infliction of emotional distress claim, holding that veterinarians do not have a duty to prevent emotional harm to pet owners. However, the court reversed the summary judgment on the intentional infliction of emotional distress claim related to the unauthorized necropsy, finding that a jury should decide if the conduct was extreme and outrageous. The court affirmed the use of the "value to owner" measure of damages, excluding sentimental value.The case was remanded for further proceedings on the intentional infliction of emotional distress claim. The Schrivers were awarded costs on appeal, but attorney fees were not granted to Dr. Raptosh and Lakeshore, as the primary issue of liability remains unresolved. View "Schriver v. Raptosh" on Justia Law

Catherine Sullivan, trustee of the Catherine Sullivan Family Trust of 2000, owns residential property adjacent to Megan Gruver's equestrian facility, Silver Bell Ranch, in Blaine County, Idaho. Gruver was issued a conditional use permit (CUP) in 2019 to operate the facility, which Sullivan did not appeal. In 2021, Gruver sought modifications to the CUP to hold three events per year, board additional horses, and hire more staff. Sullivan objected, citing concerns about noise, traffic, and property devaluation, but the Blaine County Board of Commissioners approved the modified CUP with conditions.Sullivan appealed the Board's decision to the district court, arguing that the Board erred in categorizing Silver Bell Ranch as an "Outdoor Recreational Facility" rather than an "Agricultural Business" and that the modifications would prejudice her substantial rights. The district court affirmed the Board's decision, finding that Sullivan failed to show how the modifications prejudiced her substantial rights and that her arguments regarding the categorization of the facility were time-barred because she did not appeal the 2019 CUP.The Idaho Supreme Court reviewed the case and affirmed the district court's decision. The Court held that Sullivan's arguments regarding the categorization of Silver Bell Ranch were time-barred and that she failed to establish prejudice to her substantial rights under Idaho Code section 67-5279(4). The Court also found that the district court acted within its discretion in excluding Sullivan's arguments related to prejudice that were raised for the first time in her reply brief. Blaine County was awarded attorney fees on appeal under Idaho Code section 12-117(1), while Gruver was not entitled to attorney fees as she was not an adverse party to Blaine County. Both Blaine County and Gruver were awarded costs on appeal. View "Sullivan v. Blaine County" on Justia Law

Jacob Wilde and Mickayla Taggart, formerly married, are parents to a minor child, E.W. Following their divorce in 2018, Wilde was ordered to pay $143.07 per month in child support. Wilde later filed petitions to modify the custody arrangement and child support, citing Taggart's alleged incapacity and unemployment. Taggart responded, explaining her inability to work due to an autoimmune disease and requested child support modification based on the Idaho Child Support Guidelines.The magistrate court found that Taggart's income had been minimal since the petition was filed and imputed her income at minimum wage. Wilde's income was determined to be $58,240 annually. The court retroactively modified child support to $420.34 per month starting August 2019, creating an arrearage for Wilde. Wilde's motion to reconsider was denied, and the magistrate court reaffirmed its decision, adjusting the child support amount to $485.34 from June 2021.Wilde appealed to the district court, which affirmed the magistrate court's decision. The district court found that the magistrate court had substantial evidence to support its findings and did not abuse its discretion in making the child support modification retroactive.The Idaho Supreme Court reviewed the case and upheld the district court's decision. The court found that the magistrate court acted within its discretion, supported by substantial evidence of the parties' changed incomes. The court noted that Wilde had been aware of the potential for retroactive modification and had not disputed the child support calculations. The Supreme Court awarded attorney fees and costs to Taggart, deeming Wilde's appeal frivolous and without foundation. View "Wilde v. Taggart" on Justia Law

In this case, the State of Idaho removed five minor children from their parents' home following allegations of physical abuse. The children ranged in age from sixteen years to fourteen months. Law enforcement responded to a report of an altercation between the mother and the eldest child, during which the mother admitted to hitting the child with a plastic hanger. Other children reported frequent physical discipline, including being hit with belts and hands. The children were declared to be in imminent danger and were removed from the home.The Bannock County Prosecutor’s Office filed a petition under the Child Protective Act (CPA) to place the children in the custody of the Idaho Department of Health and Welfare (IDHW). The magistrate court held a shelter care hearing and found reasonable cause to believe the children were in danger, placing them in temporary custody of IDHW. The parents objected, arguing that the removal violated their constitutional rights and that the magistrate court’s findings were unsupported by substantial evidence.The Idaho Supreme Court reviewed the case and affirmed the magistrate court’s adjudicatory decree. The Court declined to rule on the constitutionality of the initial removal because the parents failed to raise the issue in the lower court. The Court also found that the challenge to the shelter care order was moot because it was supplanted by the adjudicatory decree. The Court held that the magistrate court did not abuse its discretion by allowing the older children to remain in the courtroom during the hearing and found that substantial and competent evidence supported the magistrate court’s decision to vest legal custody of the children in IDHW. The Court also declined to consider the parents' argument under the Idaho Parental Rights Act because it was raised for the first time on appeal. View "IDHW v. Doe" on Justia Law