Justia Idaho Supreme Court Opinion Summaries

This appeal arose in the context of Safeguard Business Systems, Inc.’s (“SBS”) alleged breach of its distributorship agreement with Thurston Enterprises, Inc. (“Thurston”). After a jury trial Thurston was awarded approximately $6.8 million in damages. SBS filed a motion for post-judgment relief, which the district court denied. The Idaho Supreme Court determined the district court correctly decided that SBS breached Thurston’s account protection rights under the Agreement as a matter of law. Furthermore, the district court properly denied SBS’s motions for post-judgment relief on Thurston’s claim for fraud in the inducement of the March 2014 agreement, on Thurston’s claim that SBS breached the pricing guarantee in the Agreement, and on Thurston's claim for good faith and fair dealing because the jury’s findings were supported by substantial evidence. The Supreme Court, therefore, affirmed the district court's judgment. View "Thurston and T3 v. Safeguard" on Justia Law

In December 2016, the J.R. Simplot Company (Simplot) filed suit in Washington state relating to the dissolution of a business relationship between Simplot and two entities Simplot co-owned with Frank Tiegs (Tiegs). Dickinson Frozen Foods (DFF), also operated by Tiegs, was not named as a party in the Washington litigation; however, the complaint contained allegedly defamatory statements about DFF. In March 2017, DFF filed suit in Idaho district court alleging defamation per se against Simplot and its Food Group President Mark McKellar (McKellar), as well as the two law firms who represented Simplot in the Washington litigation: Yarmuth Wilsdon, PLLC (Yarmuth) and Thompson Coburn, LLP (Thompson). DFF also claimed breach of contract against Simplot, claiming Simplot had breached a non-disclosure agreement (NDA). Counsel for Yarmuth and Thompson made special appearances so that they could contest personal jurisdiction, and simultaneously moved for dismissal on that basis. Yarmuth, Thompson, McKellar, and Simplot also sought dismissal or partial summary judgment on the basis of the litigation privilege. The district court dismissed DFF’s claims for defamation per se against all defendants, determining the statements were protected by the litigation privilege. However, the district court declined to rule on Yarmuth and Thompson’s motions to dismiss for lack of jurisdiction in light of its rulings on the merits. Later, the district court granted Simplot’s motion for summary judgment on DFF’s breach of contract claim. DFF appealed. The Idaho Supreme Court determined it lacked personal jurisdiction over Yarmuth and Thompson; the Court affirmed the district court in all other respects. View "Dickinson Foods v. J.R.Simplot" on Justia Law

AmeriTel Inns, Inc. appealed an Idaho Industrial Commission decision granting Megan Keller unemployment benefits after her employment with AmeriTel ended in June 2017. AmeriTel asked the Idaho Supreme Court to adopt a bright line rule that a one-day absence without notice was a voluntary quit under Idaho Code section 72- 1366(5). In the event that the Court declined to do so, AmeriTel argued the Commission’s factual findings that rendered Keller eligible for unemployment compensation benefits were not supported by substantial and competent evidence. Finding no reversible error, the Idaho Supreme Court affirmed the Commission's decision. View "Keller v. Ameritel Inns; IDOL" on Justia Law

The City of Middleton (the City) appealed the district court’s grant of summary judgment to Martin and Patricia Galvin on their claim of prescriptive easement and its award of attorney fees to the Galvins pursuant to Idaho Code section 12-117. In 2016, the Galvins filed a complaint against the City of Middleton for quiet title, declaratory judgment, and a permanent injunction concerning their use of Willis Road, a private road that the City acquired in 2015. The Galvins alleged that their use of Willis Road since 1949 created a prescriptive easement entitling them to use the road for ingress, egress, and farming and irrigation purposes. The City’s answer denied the existence of the easement but did not dispute that the Galvins had used the road for the past sixty years. Finding no reversible error in the grant of summary judgment, the Idaho Supreme Court affirmed. View "Galvin v. City of Middleton" on Justia Law

Bruce Birch appealed a district court decision to affirm a magistrate court decision to award attorney fees against Birch. This case concerned the disposition of the estate of Birch and Linda Bailey’s mother, Ruth Birch. Ruth executed a last will and testament that intentionally omitted Birch. After Ruth’s death in 2011, Bailey was appointed as the personal representative for her estate. The magistrate approved a compromise agreement that allowed Birch and another intentionally omitted sibling to receive equal shares of the estate. After approval of the agreement, Bailey requested Birch pay the estate's attorney fees for preparing the agreement. The magistrate court awarded attorney fees to Bailey. In this appeal, Birch argued the magistrate court’s award of attorney fees was an abuse of discretion because it did not comply with the requirements of the Idaho Rules of Civil Procedure. The Idaho Supreme Court determined the district court erred in awarding fees, reversed and remanded for further proceedings. View "Bailey v. Birch" on Justia Law

On November 20, 2018, the Acting Governor of Idaho issued a proclamation that Proposition 2 had passed, and subsequently the Idaho Code was amended to add section 56-267, a statute to expand Medicaid eligibility in Idaho. Petitioner Brent Regan argued 56-267 violated Idaho’s Constitution by delegating future lawmaking authority regarding Medicaid expansion to the federal government. Regan requested the Idaho Supreme Court declare section 56-267 unconstitutional and issue a writ of mandamus to direct the Secretary of State Lawerence Denney to remove section 56-267 from the Idaho Code. Finding the statute constitutional, the Supreme Court dismissed Regan’s petition and denied his request for a writ of mandamus. View "Regan v. Denney" on Justia Law

Appellants Ryan and Kathryn McFarland owned real property in Garden Valley, Idaho, which feathred three structures insured through Liberty Mutual Insurance Group: a main cabin; a detached garage with an upstairs “bonus room”; and a pump house containing a geothermal well. The policy provided two types of coverage for structures. Coverage A (“Dwelling Coverage”) provided up to $188,500 in coverage for “the dwelling on the ‘residence premises’. . . including structures attached to the dwelling . . .” and Coverage B (“Other Structures Coverage”) provided up to $22,350 for “other structures on the ‘residence premises’ set apart from the dwelling by clear space.” In February 2017, a radiant heater burst in the bonus room and damaged the garage and its contents. After the McFarlands filed a claim, Liberty stated that the damage was covered under the policy. Believing the damage to fall under the Dwelling Coverage, the McFarlands hired contractors to repair the damage. However, after Liberty paid out a total of $23,467.50 in March 2017, Liberty stated that the coverage was exhausted because the damage fell under the Other Structures Coverage. This led the McFarlands to sue, alleging among other claims, breach of contract based on Liberty’s interpretation of the policy. The parties filed cross motions for summary judgment on the issue of whether the damage fell under the Dwelling Coverage or the Other Structures Coverage. Ruling that the policy unambiguously provided coverage for the garage under the Other Structures Coverage, the district court denied the McFarlands’ motion and granted Liberty’s. The McFarlands appealed. Finding that the policy at issue here failed to define the term "dwelling", and the term was reasonably subject to differing interpretations, the Idaho Supreme Court reversed the award of summary judgment and remanded for further proceedings. View "McFarland v. Liberty Insurance Corp" on Justia Law

Vernon K. Smith (Smith) appealed a district court’s award of sanctions. This case originally arose from a contract for the sale of lima beans between Victoria Smith (“Victoria”) and Treasure Valley Seed Company (“TVSC”). As Victoria’s son, Smith filed a complaint against TVSC for breach of contract. The original complaint named Victoria as plaintiff, by and through her attorney in fact, Vernon K. Smith, by and through his “Durable and Irrevocable Power of Attorney.” TVSC learned that Victoria had died three months before Smith’s filing of the complaint. Based on Victoria’s death, TVSC moved to dismiss the complaint, arguing that there was no longer a real party in interest. Smith argued that he was a real party in interest because the power of attorney he drafted was irrevocable. The district court held that Smith’s power of attorney terminated on Victoria’s death and granted TVSC’s motion to dismiss. At the hearing for costs and fees, the district court stated that Victoria’s estate should have brought the action, but because no probate had been filed, there was no real party in interest able to substitute or join. After ruling that the complaint was unreasonable and without foundation, the district court awarded attorney fees to TVSC under Idaho Code section 12-121, to be assessed jointly and severally against Victoria and Smith, as counsel. Smith appealed both the dismissal of the case and the award of attorney fees, but his appeal of the dismissal was not filed timely, so the Idaho Supreme Court only addressed Smith’s appeal of the attorney fees. The Idaho Supreme Court concurred with the district court with respect to termination of the power of attorney. Smith maintained the power of attorney gave him authority to sue on his mother's behalf, and upon remand of the case to the district court to determine the appropriate amount of fees to be assessed, the trial court awarded fees as a sanction under Rule of Civil Procedure 11. The Supreme Court declined of offer Smith "an opportunity for a mulligan" on his arguments about the power of attorney, and found the district court did not abuse its discretion when it awarded attorney fees, or levied sanctions against Smith. View "Smith v. Treasure Valley Seed Co." on Justia Law

2M Company Inc. (“2M”) appealed an Industrial Commission (“Commission”) decision that determined Matthew Atkinson was entitled to reasonable medical benefits for injuries he sustained in an accident on his way to work. The Commission found that an exception to the “going and coming” rule applied based on 2M’s intent to compensate Atkinson for his travel time while going to or coming from work. 2M and its surety, Employer Assurance Company, appealed. Finding no reversible error, the Idaho Supreme Court affirmed the Commission's determination. View "Atkinson v. 2M Company, Inc." on Justia Law

This case began as a highly contentious divorce proceeding between vexatious litigant-appellant Ronald Van Hook and his then-wife Dawn Cannon, in which Van Hook lost custody of his children (hereinafter the Canyon County divorce case). Van Hook was represented by legal counsel only for portions of the divorce proceeding as each of his attorneys withdrew from the case. Following each attorney’s departure, Van Hook filed a new series of pro se motions and objections to the court, which were similar and repetitive. Van Hook filed numerous motions to amend the magistrate court’s temporary custody and visitation orders, disqualify the magistrate judge assigned to the case, change venue, and find Cannon in criminal contempt. He also filed multiple petitions for a writ of habeas corpus. His pro se motions and petitions were continuously denied and largely found to be frivolous. When Van Hook appealed the Canyon County divorce case, the district court found Van Hook’s motion to recuse the magistrate judge frivolous, and that his appeal was also without foundation. The issue this case presented for the Idaho Supreme Court's review arose from an administrative order declaring Van Hook a vexatious litigant under Idaho Court Administrative Rule 59. The Idaho Supreme Court determined Van Hook: met I.C.A.R. 59 (d)(1) because he commenced more than three pro se litigations that were adversely determined against him; met I.C.A.R. 59 (d)(2) because he repeatedly attempted to relitigate the final divorce and custody determinations by the magistrate court; and met I.C.A.R. 59 (d)(3) because he repeatedly filed frivolous motions and pleadings. Therefore, the Supreme Court affirmed the prefiling order declaring Van Hook a vexatious litigant. View "Order Re: Vexatious Litigant (Van Hook)" on Justia Law