Justia Idaho Supreme Court Opinion Summaries

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

This case involves a dispute over a real estate and construction contract. The plaintiffs, Myles Davis and Janelle Dahl, sued their homebuilder, Blast Properties, Inc., and Tyler Bosier, alleging breach of contract, fraud, and violations of the Idaho Consumer Protection Act. The plaintiffs sought to amend their complaint to include a prayer for relief seeking punitive damages. The U.S. District Court granted the plaintiffs' motion to amend their complaint, but certified a question to the Supreme Court of the State of Idaho due to inconsistencies in the interpretation of Idaho Code section 6-1604(2), which prohibits claimants from including a prayer for relief seeking punitive damages in their initial pleading.The U.S. District Court asked the Supreme Court of the State of Idaho to determine the proper means a trial court must apply when considering a motion to amend a pleading to include a prayer for relief seeking punitive damages pursuant to Idaho Code section 6-1604(2). The Supreme Court of the State of Idaho rephrased the question to clarify the obligations of a trial court under Idaho Code section 6-1604(2) when ruling upon a motion to amend a complaint or counterclaim to include a prayer for relief seeking punitive damages.The Supreme Court of the State of Idaho held that section 6-1604(2) requires the trial court to conduct a careful examination of the evidence submitted by the moving party in support of its motion to amend and the arguments made to determine whether there is a "reasonable probability" that the evidence submitted is: (1) admissible at trial; and (2) "sufficient" to support an award of punitive damages. The word "sufficient" means that the claim giving rise to the request for punitive damages must be legally cognizable and the evidence presented must be substantial. The court clarified that the clear and convincing evidentiary standard is the standard for a jury, not the trial court when it is ruling on a motion to amend a pleading to include a prayer for relief seeking punitive damages. View "Davis v. Blast" on Justia Law

The case revolves around a workers' compensation claim filed by Christine Coray after she was injured at her workplace, Idaho Regional Hand & Upper Extremity Center. Following her injury, Coray's physician recommended back surgery. However, after an independent medical examination (IME) requested by her employer and its surety, they denied liability for the surgery and ongoing benefits, arguing that Coray had recovered from the workplace injury and that the surgery was necessitated by preexisting conditions. After undergoing surgery outside of the workers' compensation system, her employer requested a second IME by a different physician. Coray refused and sought a declaratory ruling from the Idaho Industrial Commission on whether the employer must use the same physician for multiple examinations of a single injury.The Idaho Industrial Commission ruled that the employer or surety is not required to use the same physician for multiple examinations of a single injury under Idaho Code section 72-433. However, it also held that each request for an IME is subject to a reasonableness standard, and the burden of proof for establishing reasonableness falls on the employer. Coray appealed this interpretation, while the employer cross-appealed the Commission's conclusion that it bears the burden of proving the reasonableness of a second IME.The Supreme Court of the State of Idaho affirmed the Idaho Industrial Commission's decision. It held that the plain language of Idaho Code section 72-433 does not prohibit an employer or surety from using different physicians to perform multiple examinations of a single injury. The court also affirmed the Commission's ruling that the employer bears the burden of establishing the reasonableness of its requested IME, including its choice of physician, if raised by the employee. View "Coray v. Idaho Regional Hand & Upper Extremity Center" on Justia Law

The case involves a dispute between Blaine Simmons, a landowner, and Tom Loertscher and Josh Williams, cattle owners. Simmons owns land in Bonneville County, Idaho, which is part of a herd district established in 1919. The herd district prohibits livestock from running at large within its boundaries. Loertscher owns Hi Willow Ranch Corporation, which has a permit to graze cattle on a portion of the Bureau of Land Management (BLM) land adjacent to Simmons' property. The BLM land is designated as open range, where livestock may graze and roam freely. Over time, cattle allegedly owned by Williams, grazing on the Loertscher Allotment, have strayed onto Simmons' property. Simmons repeatedly complained to Loertscher and Williams about this and set conditions for them to retrieve their cattle from his land.Simmons filed a small claims action against Loertscher and Williams alleging herd district violations and nuisance. The magistrate judge ruled in favor of Loertscher and Williams, stating that herd district laws do not apply to the Loertscher Allotment, which is on BLM land and designated as open range. The judge also stated that Loertscher and Williams have a common law right to enter Simmons’s Parcel at reasonable times and in a reasonable manner to retrieve their cattle. Simmons appealed this decision to the district court, which affirmed the magistrate court's decision.The Supreme Court of the State of Idaho affirmed the district court's decision. The court concluded that the district court's interpretation of Idaho Code section 25-2402, which excludes open range from any herd district and reinstates Idaho’s “fence-out” rule with respect to cattle straying from open range, was consistent with the history of herd district law and the effect of the 1963 amendment. The court also affirmed the district court's decision regarding the conditions governing the retrieval of cattle from Simmons’s Parcel. The court found that Simmons did not preserve this issue for appeal before the district court, and the issue was waived before this Court. View "Simmons v. Loertscher" on Justia Law

The case involves an individual, referred to as "John Doe," who repeatedly applied for admission to the Idaho State Bar. Doe's applications were denied due to concerns about his character and fitness, including his honesty, judgment, and respect for the rights of others. Doe challenged these denials, arguing that his federal lawsuits against the Idaho State Bar were a necessary defense of his rights and that his conduct was protected by the First Amendment.The Idaho State Bar filed a petition with the Idaho Supreme Court, seeking permission to reject Doe's third application and to prohibit him from filing future applications for a specified period. Doe cross-petitioned, seeking immediate admission to the Idaho State Bar.The Idaho Supreme Court denied Doe's cross-petition, finding that he had not demonstrated that he met the essential eligibility requirements to practice law. The court granted the Idaho State Bar's petition in part, allowing it to reject Doe's third application and prohibiting Doe from filing a new application for two years. The court found that Doe had not shown a significant change in his circumstances that would render him eligible to practice law. The court also ordered the Idaho State Bar to refund Doe's application fee. View "ISB v. John Doe" on Justia Law

In this case, Laurie Barton, a third-year law student at the University of Idaho, was accused of violating the university's honor code by committing academic misconduct during a final examination. Despite denying the allegations, she was sanctioned with degree denial after a series of Honor Court proceedings. Barton exhausted her administrative review options, including an appeal to the Idaho State Board of Education, and then petitioned for judicial review. The district court denied her petition. Instead of appealing this decision, Barton sued the Board of Regents of the University of Idaho and Idaho State Board of Education, alleging nine causes of action, all of which the district court dismissed at summary judgment.The district court's judgment was affirmed by the Supreme Court of the State of Idaho. The Supreme Court found that Barton had failed to raise a genuine issue of material fact that the University violated its duty of good faith and fair dealing or that it made a specific promise that induced her action. The court also found that Barton's motion for a protective order was implicitly denied and moot, as the case was resolved on summary judgment. The court concluded that Barton's appeal was pursued frivolously, unreasonably, and without foundation, and awarded attorney fees and costs to the University. View "Barton v. Board of Regents" on Justia Law

The case revolves around a dispute over a permit application to repair and maintain Imperial Gulch Road (IGR), which provides access to the property of the appellant, Jeffrey "Jae" Hill. The respondent, Blaine County, denied the permit application, concluding that it did not have the authority to issue the permit because it had previously declined to validate IGR. Hill filed a petition for judicial review of the Board’s decision.The district court affirmed the Board’s denial in part and vacated its decision in part. The court concluded that the Board did not validate IGR and therefore the Board lacked authority to issue the requested permit. However, the court remanded the matter back to the Board to determine if the Board had authority to issue the permit under a public easement theory. Hill appealed, arguing that the district court erred by determining that the Board had not validated IGR.The Supreme Court of the State of Idaho affirmed the district court’s decision. The court held that the district court did not err when it affirmed the Board’s decision that it lacked authority to grant Hill’s permit because it had not validated IGR. The court found that Hill failed to establish that the Board’s decision denying his permit was arbitrary, capricious, or an abuse of discretion. The court did not disturb the district court’s order vacating the Board’s decision in part and remanding the matter to the Board for further proceedings. View "Hill v. Blaine County" on Justia Law

Michelle Oksman sued the City of Idaho Falls after slipping and falling on a wet surface in the lobby of the West Deist Aquatic Center, a facility owned and operated by the City. Oksman alleged negligence on the part of the City. The district court initially granted the City's motion for summary judgment, concluding that the City had no actual notice of a dangerous condition and did not fail to take reasonable action to remedy potential hazards. However, the court later withdrew its grant of summary judgment after Oksman identified the person who had allegedly stated that people frequently fell in the area where she had fallen. The case proceeded to a jury trial, during which the district court limited Oksman's testimony and declined to give a jury instruction Oksman requested regarding the reasonable value of necessary services. The jury returned a verdict in favor of the City, and the district court dismissed Oksman's complaint with prejudice. Oksman appealed.The Supreme Court of the State of Idaho vacated the district court's judgment and remanded the case for a new trial. The Supreme Court found that the district court had erred in limiting Oksman's testimony about a statement made by the manager of the aquatic center, which was crucial to Oksman's case. The Supreme Court also provided guidance on issues likely to arise again on remand, including the use of depositions for impeachment and the use of leading questions. The Supreme Court further vacated the district court's award of costs to the City as the prevailing party. Neither party was awarded attorney fees on appeal. View "Oksman v. City of Idaho Falls" on Justia Law

The case revolves around a dispute over the ownership of funds in a joint checking account following the death of one of the parties named on the account. Karon “Kelly” Kelso was originally a joint owner of a checking account with his wife, Sandra Kelso. After Sandra's death, Linda Applington, a friend of Kelly’s, began helping Kelly process his monthly bills. Kelly later added Linda on his checking account as a joint owner with the right of survivorship. After Kelly's death, his son, Greg Kelso, became the personal representative and sole heir of Kelly’s estate. Greg sought to have the funds transferred to Kelly’s estate, but Linda claimed ownership of the account under the right of survivorship and declined to transfer the funds.The district court granted summary judgment in favor of Linda, finding clear and convincing evidence that Kelly intended Linda to have the funds in his account upon his death. Greg appealed to the Supreme Court of the State of Idaho.The Supreme Court of the State of Idaho reversed the district court’s grant of summary judgment and remanded for a jury trial. The court found that there were inconsistencies in the testimonies of Linda and Janet Overman, an employee of the bank, which raised questions about their credibility. The court held that summary judgment was not proper when the record raises any question as to the credibility of witnesses. The court also vacated the award of attorney fees to Linda, stating that the prevailing party has not been determined and fees may be considered at the conclusion of the case. View "Kelso v. Applington" on Justia Law