Justia Idaho Supreme Court Opinion Summaries

Father John Doe appealed a magistrate court’s judgment terminating his parental rights to his minor children. The judgment also terminated the parental rights of the children’s mother (she appealed in a separate action). Prior to the termination, the children and parents were the subject of a Child Protection Act (“CPA”) proceeding for over two years. When the prosecutors first filed a petition under the CPA, the parents were listed with separate addresses, but were living together. However, the parents ended and rekindled their relationship at various times prior to and during the CPA proceeding. By the time of trial, Father and Mother were permanently separated. The Department became involved in early March 2016 after receiving reports of drug use and neglect involving the children. Prior to this, the Department had received referrals for the family on two occasions in 2013 and 2014. The Department’s investigation revealed that both children had been born premature, exposed to drugs in-utero, and tested positive for methamphetamine at birth. Based on these concerns, the Lincoln County Prosecutor’s Office filed a petition under the CPA in March 2016. In June 2016, the court ordered the parents to follow case plans provided by the Department. Eight months later, the State filed a motion to terminate the parental rights of both parents based on failure to comply with the case plan and on prior neglect. After holding a trial, the court terminated both parents’ parental rights. Father argued on appeal the magistrate court’s finding of neglect was not supported by substantial, competent evidence and that the court erred by not considering how Father’s periods of incarceration affected his ability to comply with the case plan. The Idaho Supreme Court was not persuaded by Father’s arguments and affirmed termination. View "DHW v. John Doe" on Justia Law

John Doe (“Father”) and Jane Doe (“Mother”) appealed a magistrate court's judgment terminating their parental rights to two children (“D.E.” and “T.E.”). The magistrate court terminated Mother and Father’s parental rights on the grounds of neglect and found that termination would be in the best interests of the children. Mother challenged the termination of her parental rights to both children, alleging the magistrate court’s decision was not supported by substantial and competent evidence and that her due process rights were violated when a microphone malfunctioned on days three and four of the termination hearing, resulting in no audio recording for those days. Father claimed the magistrate court erred in denying him a jury trial and in allowing admission of a police video over his objection, and that the magistrate court erred in finding that he failed to comply with his case plan and that the magistrate court’s decision to cease reasonable efforts and visitation was unreasonable. Finding that the magistrate court had substantial and competent evidence to terminate Mother's parental rights to the children, and that her due process rights were not violated when there were issues with the courtroom microphones during hearing days three and four, the Idaho Supreme Court affirmed as to the termination of Mother's rights. Similarly, the Court found substantial and competent evidence to support termination of Father's rights; the magistrate court's finding that Father failed to comply with the case plan was reflected in that evidence. The magistrate court’s decision to not reinstate reasonable efforts and allow visitation was supported by substantial and competent evidence. Therefore, the Supreme Court affirmed termination of Father's rights too. View "DHW v. Jane Doe & John Doe" on Justia Law

Jane Doe (Mother) appealed a magistrate court order terminating her parental rights to her child. The child was born with methamphetamine in her system and was declared in imminent danger, with the Idaho Department of Health and Welfare assuming temporary custody. The case plan entered into for parental reunification focused primarily on abstinence from controlled substances and drug treatment. But Mother struggled with beginning drug treatment and repeatedly relapsed into using methamphetamine. The Department petitioned that Mother’s parental rights be terminated. A three-day termination hearing was held and the magistrate court terminated Mother’s parental rights to Child after finding that she neglected the child and that termination was in the child’s best interest. Mother appealed, arguing that the magistrate court’s finding of neglect was not supported by substantial and competent evidence, and that the court erred in determining termination was in the child’s best interest. Finding no abuse of discretion or other reversible error, the Idaho Supreme Court affirmed. View "DHW v. Jane Doe" on Justia Law

In 2010, Kermit Jackson filed a complaint against Jennifer Crow arising from a 2008 automobile collision. No substantive action took place in the trial court until 2016 when Crow moved for summary judgment. In the interim, Crow filed for bankruptcy in 2014 listing Jackson as a potential unsecured creditor with a claim of unknown value. Jackson filed a proof of claim with the bankruptcy court and eventually received his pro rata share of the distribution of Crow’s assets. Crow received a bankruptcy discharge in 2014, releasing her from personal liability on the claim. Afterwards, Jackson proposed to move forward with this case against Crow as a nominal defendant, seeking to secure a judgment in order to recover from Crow’s insurer, rather than Crow personally. Crow’s motion for summary judgment argued that: (1) allowing Jackson’s case to go forward against her violated the permanent discharge injunction of 11 U.S.C. secs. 524 and 727; (2) even if this procedure did not violate the Bankruptcy Code’s permanent injunction, naming her as a nominal defendant was (a) not permitted by Idaho case law, the Idaho Rules of Civil Procedure, and Idaho’s no-direct-action rule, and (b) violated the Bankruptcy Code’s policy of providing her a financial “fresh start.” In a case of first impression, the district court ruled in favor of Crow, reasoning that allowing the case to proceed against Crow would violate 11 U.S.C. 524 by impermissibly causing negative economic consequences for Crow. The district court further reasoned that allowing Jackson to proceed directly against Crow’s insurer would violate the no-direct-action rule and permitting Jackson to proceed against Crow nominally was not permitted by the Idaho Rules of Civil Procedure or this Court’s precedent. The Idaho Supreme Court concluded the district court erred in granting Crow summary judgment: the district court misapplied the no-direct-action rule in this case. The judgment was vacated and the matter remanded for further proceedings. View "Jackson v. Crow" on Justia Law

The Idaho Supreme Court considered a permissive appeal that presented a case of first impression regarding whether the tort of defamation by implication existed in Idaho. Respondent James Verity was a school teacher in Oregon who lost his teaching license after engaging in an inappropriate relationship with an eighteen-year-old female student, whom he coached at the local high school. He eventually obtained a teaching license in Idaho, and began teaching shortly thereafter. When he was forced to resign his teaching job in Idaho after USA TODAY, KTVB, KGW, Tami Tremblay, and Stephen Reilly published articles and broadcast news reports describing Verity’s misdeeds, he and his wife Sarahna Verity filed a lawsuit alleging defamation by implication. The district court denied the media’s motion for summary judgment and ruled that despite the actual truth of the statements, reasonable minds could find that the media impliedly defamed the Veritys. The media appealed that decision as a permissive appeal under Idaho Appellate Rule 12. The Supreme Court affirmed the district court’s conclusion that Verity was not a public official or a public figure, and affirmed the district court’s conclusion that a reasonable jury could find that KGW impliedly defamed Verity about his having a sexual relationship with a minor. The Court reversed the district court on all of Verity’s remaining claims and remanded for further proceedings. View "Verity v. USA Today, et al" on Justia Law

In 2016, St. Luke’s Health System, Ltd. accepted an indigent patient suffering from meningitis, seizures, and brain lesions. The patient was ready for transfer to another medical facility by February 18, 2016, but was refused by multiple care providers because they did not want to admit an indigent patient without a payor source. St. Luke’s finally contracted with Life Care, another medical facility, to take the patient on the condition that St. Luke’s would guarantee payment for a thirty day period. The patient was transferred to Life Care on March 9, 2016. St. Luke’s applied for medical indigency benefits covering the period of time from the patient’s initial hospitalization until she was transferred to the Life Care facility. Gem County initially approved the application for benefits through February 3, 2016. St. Luke’s appealed that determination, and after a hearing, the Board approved medical indigency benefits from January 26, 2016, until February 18, 2016. The Board entered a written determination titled “Amended Determination of Approval for County Assistance” which set forth the various bills that were approved for payment, but did not in any way reflect the denial of benefits or the reasoning of the Board. St. Luke’s then sought judicial review of the Amended Determination before the district court, which affirmed the Board’s decision. St. Luke’s appealed. The Idaho Supreme Court vacated the Board’s Amended Determination because it did not reflect the partial denial of benefits and because there were no findings of fact or conclusions of law setting forth the basis for the Board’s denial. View "St. Lukes v. Bd of Commissioners of Gem Co" on Justia Law

This appeal stemmed from a dispute between SilverWing at Sandpoint, LLC (“SilverWing”) and Appellant Bonner County, Idaho (the “County”). SilverWing sought to develop a residential hangar and taxiway adjacent to the Sandpoint Airport for residents who wished to park their aircraft in their home garage. SilverWing alleged that “[i]n 2007, the County provided to SilverWing an ALP that reflected the existing location of the Airport’s runway, and made no mention or reference to any plans for the runway to be moved. At the same time, the County promised that there were no plans regarding changes to runway location which would be incompatible with SilverWing’s development.” During the initial stages of engineering for the development, the County informed SilverWing that it needed to move the taxiway from where it was originally planned onto County-owned airport property, to accord with the County’s Airport Layout Plan (ALP). SilverWing proceeded with its development based on the County’s assurances, and built a taxiway and other infrastructure, including streets, to support its development. Once the taxiway was built, SilverWing learned that the placement of the taxiway was not approved by the FAA. After several years of legal maneuvering, SilverWing proceeded against the County in court, ultimately on a theory of promissory estoppel. After trial, a jury returned a verdict in favor of SilverWing. The County filed a motion for judgment notwithstanding the verdict (“JNOV”), which the district court denied. The County appealed. The Idaho Supreme Court reversed the district court’s ruling on the JNOV and vacated its ruling regarding attorney fees. The Court determined the district court erred with respect to JNOV on the claim of promissory estoppel: "SilverWing actually got what it claims the County promised—an FAA approved taxiway in the location where SilverWing built it. SilverWing can now sell its development with no regulatory uncertainty." View "SilverWing v. Bonner County" on Justia Law

At issue in this appeal was the administrative order entered by Administrative District Judge Melissa Moody for the Fourth District declaring appellant, Mark Colafranceschi, a vexatious litigant pursuant to Idaho Court Administrative Rule 59. Colafranceschi and his former wife, Julie Neustadt had been involved in contentious litigation dating back to May 2016. The administrative district judge determined that Colafranceschi had satisfied I.C.A.R. 59(d)(1) because in the preceding seven years he had represented himself in at least three cases that were finally determined adversely to him, and he repeatedly relitigated outcomes in two cases, and propounded discovery requests for improper purposes. Colafranceschi appealed the order, arguing that the administrative judge erred in declaring him a vexatious litigant. The Idaho Supreme Court affirmed the administrative district judge’s order finding Colafranceschi a vexatious litigant and upheld the order prohibiting Colafranceschi from filing any new pro se litigation in the courts of this state without first obtaining leave of a presiding judge. View "Colafranceschi v. Moody" on Justia Law

Burns Concrete, Inc., and Canyon Cove Development Company, LLP, (Canyon Cove), appealed a district court judgment in favor of Nora Mulberry and TN Properties, LLC, (collectively, Mulberry) regarding the extinguishment of a right of first refusal (ROFR). In 1999, Nora and Theodore Mulberry sold a piece of real property to Canyon Cove and included a ROFR to a nearby, distinct parcel of real property (ROFR Property). Twelve days later, Canyon Cove conveyed its interest in both the purchased property and the ROFR to Burns Concrete and recorded the deed to the purchased property with the Bonneville County, Idaho Recorder. In 2005, Nora Mulberry and her husband (now deceased) conveyed the ROFR Property to their wholly owned limited liability company, TN Properties, and subsequently recorded the deed with the Bonneville County Recorder. In 2016, Mulberry filed a complaint seeking declaratory judgment and subsequently a motion for partial summary judgment. The district court entered partial summary judgment in favor of Mulberry finding the ROFR was personal to Mulberry and Canyon Cove, and it was subsequently extinguished when Canyon Cove assigned it to Burns Concrete. On reconsideration, the district court held that the ROFR was a servitude appurtenant to the purchased property, and reaffirmed it was extinguished by Canyon Cove’s conveyance to Burns Concrete. Burns Concrete and Canyon Cove timely appealed. The Idaho Supreme Court reversed and remanded, finding: (1) the ROFR was personal to the parties, and thus, non-assignable; and (2) the ROFR was not extinguished when Canyon Cove purported to assign it to Burns Concrete. Therefore, the district court erred in ruling the ROFR was extinguished after Canyon Cove purported to assign it to Burns Concrete; the matter was remanded for a determination of the other issues raised in the complaint that were previously dismissed as moot. View "Mulberry v. Burns Concrete" on Justia Law

In 2006, T3 Enterprises entered into the Distributor Agreement with Safeguard Business Systems (SBS). In 2014, T3 filed suit alleging SBS had breached the Distributor Agreement by failing to prevent other SBS distributors from selling to T3’s customers and for paying commissions to the interfering distributors rather than to T3. The Distributor Agreement between SBS and T3 contained an arbitration clause indicating disputes must be resolved in a Dallas, Texas based arbitration procedure. The Distributor Agreement also contained a forum selection clause indicating that the Federal Arbitration Act (FAA) and Texas law would apply to any disputes between the parties. Pursuant to this agreement, SBS moved the district court to compel arbitration in Dallas. The district court determined the parties had to submit to arbitration, but that the Dallas forum selection clause was unenforceable, and arbitration was to take place in Idaho. The Arbitration Panel (the Panel) found for T3 and the district court confirmed the award in the amount of $4,362,041.95. The district court denied SBS’s motion to vacate or modify the award. SBS appealed, but finding no reversible error, the Idaho Supreme Court affirmed the district court. View "T3 Enterprises v. Safeguard Business Sys" on Justia Law