Justia Idaho Supreme Court Opinion Summaries

Kelli Sevy sustained a work-related injury on October 31, 2006, and contended that she was totally and permanently disabled. The Industrial Commission found that Sevy failed to meet her burden of establishing total and permanent disability. Although the Commission found that Sevy was “profoundly disabled,” the Commission held that Sevy had failed to demonstrate that the accident contributed to her disability beyond a 2% permanent partial impairment (PPI). Sevy argued on appeal that the Commission’s decision that she did not suffer disability in excess of her impairment is not supported by substantial and competent evidence. Finding no reversible error, the Supreme Court affirmed. View "Kelli Sevy v. SVL Analytical, Inc." on Justia Law

In 2013, claimant Scott Chadwick filed a complaint with the Industrial Commission seeking benefits under the Worker’s Compensation Law from his employer, Multi-State Electric, LLC, and its surety, Idaho State Insurance Fund. Claimant alleged that he had suffered back injuries as a result of two separate accidents at work in 2012. The matter was tried to a referee, but the Commission did not adopt the referee’s recommendations. After considering the Claimant’s prehearing deposition, the testimony presented during the evidentiary hearing before the referee, and the exhibits, the Commission issued its findings of fact, conclusions of law, and order. The Commission found that Claimant failed to prove that he suffered an injury from a workplace accident in a May event and that he failed to prove that a July event occurred. The Commission alternatively found that he had failed to provide timely notice to his employer of both claimed accidents, and that he failed to prove that Employer was not prejudiced by the failure to give timely notice. Therefore, he was denied benefits. Claimant then timely appealed. Finding no reversible error, the Supreme Court affirmed the Commission. View "Chadwick v. Multi-State Electric, LLC" on Justia Law

Claimant Barbara Kelly was an employee of Blue Ribbon Linen Supply, Inc. when a cart rolled over her left foot. She filed for workers’ compensation benefits. Kelly sustained additional injuries in an automobile accident when returning home from an Independent Medical Evaluation (IME) scheduled by the Idaho State Insurance Fund (Surety) in connection with the cart incident. The Industrial Commission concluded that Kelly’s injuries from the automobile accident were not compensable because they did not arise out of and in the course of her employment with Blue Ribbon. The Supreme Court concluded after review that the causal connection between Kelly’s employment and the injuries she sustained as a result of the accident was sufficiently compelling that it held that the injuries arose out of and in the course of her employment. Accordingly, the Court reversed the Commission’s decision and remanded for further proceedings. View "Kelly v. Blue Ribbon Linen Supply, Inc." on Justia Law

On September 17, 2011, Martin Hayes was seriously injured after stumbling on uneven ground hidden by grass while attending his grandson’s Pop Warner football game at the Plummer School Park, which was owned by the City of Plummer. Hayes did not pay any fee or admission to enter the Park. Hayes filed a premises liability claim against the City for his injuries. In turn, the City filed a motion for summary judgment on the basis that the City was entitled to a limit on liability under Idaho’s Recreational Use Statute. The district court granted the City’s motion. Hayes appealed. After review, the Supreme Court agreed with the district court's analysis that the Recreational Use Statute provided limited liability protection because the City did not receive "compensation" or "charge" for use of the land upon which Hayes was injured. View "Hayes v. City of Plummer" on Justia Law

This lawsuit arose out of a fatal helicopter crash that occurred on August 31, 2010, in Kamiah, Idaho. The Idaho Department of Fish and Game had contracted with Leading Edge Aviation, LLC, to fly two Department employees from Clarkston, Washington, to the Selway River in Idaho in order to collect data on salmon spawning. The pilot of the helicopter was Perry J. Krinitt, Jr., the son of the Plaintiff. The two Department employees were Larry Barrett and Danielle Schiff. Plaintiff filed this wrongful death action contending that the accident was caused by the negligence of the Department or its employees. Defendants moved for summary judgment, and, after briefing and argument, the district court granted the motion. Plaintiff then appealed. Because there were genuine issues of material fact regarding the liability of the Defendants, the Supreme Court vacated the judgment and reversed the order granting the motion for summary judgment. View "Krinitt v. Dept of Fish and Game" on Justia Law

In 2004 when he was sixteen years old, claimant Terence Fairchild worked for Kentucky Fried Chicken as a cook. While carrying garbage to a dumpster, he slipped on ice and fell onto a concrete barrier, striking his knees. The impact caused his knees to bleed. He went inside the building, bandaged his knees, and informed his supervisor of the accident. Claimant sought medical care. The physician diagnosed his condition as patellofemoral pain following bilateral patella contusions and prescribed knee braces, stretching exercises, Naprosyn, and ice. He saw the physician one week later and continued to suffer pain in both knees. The physician prescribed physical therapy, which failed to alleviate Claimant’s symptoms. The physician ordered an MRI of Claimant’s left knee a few weeks later. The MRI did not reveal any abnormality. After reviewing the results of the MRI with an orthopedist, the physician continued Claimant on physical therapy and anti-inflammatory medication. Approximately one month following the accident, Claimant filed a complaint seeking benefits under the Worker’s Compensation Law. Claimant sought a second, third and fourth opinions, including one from an orthopedic surgeon. These opinions spanned approximately seven years following the initial fall. In 2007, the orthopedic surgeon suspected claimant suffered a partial posterior cruciate ligament injury to his right knee and concluded that Claimant was entitled to a permanent partial impairment of 3%. In 2011, an examining physician agreed Claimant suffered a partial posterior cruciate ligament injury, but estimated the permanent partial impairment of 7%. In a 2012 hearing, the Industrial Commission found Claimant was not a credible witness based upon its observation of him during the hearing and the differences between his hearing testimony and his prior statements in depositions, interviews, and appointments with medical providers. The Commission concluded that it regarded Claimant’s testimony as suspect where it was not supported by other evidence in the record. The Commission found that Claimant had suffered a right posterior cruciate ligament injury in the accident and that as a result of that injury he had a permanent partial impairment rating of 3%. Finally, the Commission found that Claimant had failed to prove that he had a disability in excess of his impairment. Claimant filed a motion for reconsideration, which the Commission denied. Claimant then appealed. Finding no reversible error, the Supreme Court affirmed the Commission's judgment. View "Fairchild v. Kentucky Fried Chicken" on Justia Law

This case arose out of the claims of several men who joined Boy Scout troops when they were children and were allegedly sexually abused by their scout leaders. The Church of Jesus Christ of Latter Day Saints (LDS Church) sponsored some of the troops at issue in this case. In 2013, Does I–IV filed a complaint (later amended) at the federal district court against Boy Scouts of America and the LDS Church (collectively, Respondents), alleging constructive fraud. The complaint alleged that Respondents knew that boys were in danger of being sexually abused by adult volunteers and that Respondents failed to disclose that danger. The complaint further alleged that Respondents not only remained silent about the dangers of pedophilic scoutmasters, but also affirmatively represented to the boys that each scout leader was a “great guy,” a “wonderful man,” or a “friend to whom you can always turn for advice.” Respondents subsequently moved to certify questions to the Idaho Supreme Court, challenging the constructive fraud claims on several grounds. The United States District Court certified two narrow questions to the Idaho Court regarding the statute of limitations that applied to a constructive fraud claim where the plaintiff alleged a breach of duty resulted in sexual abuse, and when a claim for constructive fraud related to childhood sex abuse accrued. The Idaho Supreme Court found that: (1) Idaho Code section 5-218(4)'s statute of limitations applied to constructive fraud cases; and (2) the "discovery rule" applied to constructive fraud claims for purposes of determining when the cause of action accrued. View "DOE(s) v. Boy Scouts of America" on Justia Law

Appellant Kevin Stokes employed Respondent Sohar Chavez as a part-time irrigator on Stokes's farm. During the course of his employment, Chavez was injured when his finger slipped into the chain of a motor on an irrigation line. Chavez's finger could not be reattached, and a physician amputated it. A few days after the injury, Life Flight billed Chavez $21,201.00 for transport from the farm to the hospital. Chavez then filed a claim for worker's compensation. Stokes, as the employer of Chavez, was uninsured for purposes of worker's compensation law, but paid all medical expenses related to the injury except the Life Flight bill, which he has disputed, contending that the transport was unreasonable. The Idaho Industrial Commission determined that the Life Flight transport was reasonable under Idaho Code section 72-432(1). Stokes appealed the Commission's judgment. Finding no reversible error, the Supreme Court affirmed. View "Chavez v. Stokes" on Justia Law

The State of Idaho appealed a district court judgment denying its motion to vacate portions of a Stipulated Partial Settlement and Award entered by an arbitration panel. This case stemmed from the 1998 Tobacco Master Settlement Agreement, wherein certain cigarette manufacturers entered into an agreement with the State to pay damages for the cost of treating smoking-related illnesses. A dispute arose between the parties as to the amount owed in 2003 and the district court entered an order compelling arbitration. The arbitration panel entered a Stipulated Partial Settlement and Award in March of 2013. In June of 2013, the State moved the district court to vacate, modify, or correct the award. The district court concluded the State did not have standing to move to vacate or modify the award. The State appealed. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Philip Morris, Inc." on Justia Law

Todd Hamilton died in an automobile accident while employed by Alpha Services, LLC. The Idaho Industrial Commission found that the accident arose out of and in the course of Hamilton’s employment and determined that Hamilton’s widow and two children were entitled to statutory death benefits under Idaho’s worker’s compensation laws. Alpha and its surety, Dallas National Insurance Company, argued on appeal to the Supreme Court that the Commission’s decision was not supported by substantial and competent evidence. Finding no reversible error, the Supreme Court affirmed. View "Hamilton v. Alpha Services, LLC" on Justia Law