Justia Idaho Supreme Court Opinion Summaries

This appeal stemmed from a worker’s compensation case in which Michael Vawter sought compensation from his employer, United Parcel Service (UPS), for a back injury he claimed he suffered as a result of his employment. UPS attempted to establish that Vawter did not suffer a compensable injury, but if he did the State's Industrial Special Indemnity Fund (ISIF) was liable for a portion of his benefits. Ultimately, the Idaho Industrial Commission found that Vawter was totally and permanently disabled and that UPS was solely responsible for Vawter’s disability benefits because it was estopped from arguing Vawter had a preexisting condition, a necessary element of ISIF liability. UPS appealed, arguing: (1) the accident causing Vawter’s injury did not arise out of his employment; (2) the Commission improperly applied the doctrine of quasi-estoppel to prevent it from asserting a preexisting condition; and (3) the Commission improperly awarded Vawter attorney fees. Vawter and ISIF both cross-appealed. Upon review, the Supreme Court reversed the Industrial Commission’s determination that Vawter was not entitled to recover all medical expenses incurred between the date of the accident and September 27, 2010. The Court affirmed the Industrial Commission in all other respects. View "Vawter v. United Parcel Service, Inc." on Justia Law

In 2006, the Christensens began construction of a fabric building adjacent to the property line shared with the McVicarses. After its completion, the McVicarses filed a nuisance action alleging that increased noise, traffic, and dust diminished the value of their property and interfered with the enjoyment of their property. After a bench trial, the district court ruled in favor ofMcVicarses, finding the Christensens’ course of conduct unreasonably interfered with the McVicarses’ enjoyment of their property and was therefore a private nuisance. Furthermore, the court found that there was no evidence to support the McVicarses’ claim of public nuisance or the Christensens’ unclean hands defense. The Christensens appealed. Upon careful consideration, the Supreme Court held that the district court erred to the extent that it considered the building’s size and proximity to the McVicarses’ property to constitute a nuisance. Because the building’s size and proximity do not in and of themselves constitute a nuisance, the district court erred in requiring the McVicarses to move the building from its current location. Therefore, the case was remanded for analysis of whether the cumulative effects of the activities on the property constituted a nuisance in fact. View "McVicars v. Christensen" on Justia Law

Appellants Robby and Kim Mowrey appealed the dismissal of their negligence action against Respondent Chevron Pipe Line Co. The district court ruled that because the Mowreys failed to disclose this claim as an asset in their Chapter 7 bankruptcy proceeding, they were judicially estopped from pursuing it against Chevron. In the alternative, the district court ruled that the Mowreys lacked standing as the real party in interest to prosecute their claim because it belonged to the bankruptcy trustee as an asset of the bankruptcy estate. The Mowreys argued on appeal that the district court erred in granting summary judgment. Finding no reversible error, the Supreme Court affirmed. View "Robby Mowrey v. Chevron Pipeline Co." on Justia Law

Defendant-Respondent Russell Griffeth, a licensed physical therapist, operated a clinic in Idaho Falls. He received no training as a contractor and was never licensed as a contractor. He did, however, act as a general contractor in the construction of his two homes. He organized and supervised various subcontractors. In early 2009, Griffeth decided to remodel his physical therapy clinic by constructing an addition to the existing building. Griffeth intended to be the general contractor for the project, but the city required a licensed commercial contractor. Consequently, Griffeth hired Bryan Robinson, a friend with construction experience, to serve as the general contractor. Robinson obtained a commercial contractor license for the project. Near the end of the project, Robinson hired Claimant Geff Stringer as a carpenter. As the clinic project neared completion, the construction workers used a hoist attached to the roof to move heavy beams into position in the attic. Unfortunately, on or near the last day of the project, the ceiling collapsed, and a beam fell on Stringer. The impact from the beam fractured Stringer's left ankle. At the time of the accident, Robinson did not have worker's compensation coverage. Stringer filed worker's compensation complaints against both Robinson and Griffeth. Following an evidentiary hearing, the Commission held that Robinson was Stringer's direct employer and that Griffeth was his category one statutory employer. Because Robinson did not pay worker's compensation benefits to Stringer, Griffeth, as the statutory employer, normally would be liable for such benefits. However, the Commission held that Griffeth was exempt from worker's compensation liability because Stringer's employment with Griffeth was "casual" under I.C. 72-212(2). Stringer appealed to the Supreme Court. Finding no reversible error, the Supreme Court affirmed the Commission's decision. View "Stringer v. Robinson" on Justia Law

Claimant-Appellant Dallas Clark appealed an Industrial Commission order that denied her workers' compensation benefits. Claimant worked for Shari's Management Corporation as an experienced server. During a graveyard shift, she suffered a herniated disc in her back while lifting a heavy tray onto a high shelf. She would later be diagnosed with sciatica attributed to the lifting injury from work. Shari's completed a Report of Injury, interviewing Claimant in the process. The investigator testified that Claimant attributed the injury as "standing wrong" at a salad bar, which left her unable to lift the tray. The Commission concluded after a hearing that Claimant was unable to prove an industrial accident had occurred. The Supreme Court agreed with the Commission and affirmed its order. View "Clark v. Shari's Management Corp" on Justia Law

This appeal stemmed from litigation involving a motor vehicle accident. Passenger Trevor Taft was injured when driver Derek Gummersall, the son of Clay Gummersall, lost control of his vehicle. At the time of the accident, Clay was an employee of Jumbo Foods, Inc., in whose name the vehicle was titled. David, Wendy, and Trevor Taft sued Jumbo Foods under theories of negligent entrustment and imputed negligence, arguing that Jumbo Foods owned the vehicle, and thus had a right to control it. Jumbo Foods countered that it sold the vehicle to Clay Gummersall before the accident occurred, and thus could not be held liable. The district court granted summary judgment in favor of Jumbo Foods and the Tafts appealed. The Supreme Court concluded the district court erred in granting summary judgment on the issue of imputed liability, an reversed with respect to that issue. The Court affirmed in all other respects, and remanded the case for further proceedings. View "Taft v. Jumbo Foods, Inc.," on Justia Law

Liberty Northwest Insurance filed a product liability action against Spudnik Equipment Company to recover workers' compensation benefits paid to an employee of its insured, Grand 4-D Farms, who was injured while working on a potato conveyor. The district court granted Spudnik summary judgment, finding Liberty failed to adequately identify the equipment involved in the accident. Liberty appealed to the Supreme Court. Finding no reversible error, the Supreme Court affirmed. View "Liberty Northwest Ins. Co., v. Spudnik Equip Co.," on Justia Law

Heidi Beers (a minor) was injured after jumping from a bridge into the Payette River. At the time, she was attending a campout organized by ward members of her church. Her parents, Gregory and Caralee Beers, brought negligence claims individually and on behalf of their daughter against the Corporation of the President of the Church of Jesus Christ of Latter-day Saints and a number of individual ward members. The district court granted the defendants' motions for summary judgment in part, dismissing all negligence claims, but denied the motion for summary judgment as to the statutory claim against four ward members. The Beerses appealed and the four ward members cross-appealed. Upon review, the Supreme Court concluded the district court propertly granted summary judgment as to the Beerses' negligence claims, but erred by denying the ward members' motion for summary judgment as to the Beerses' claim based on tort child abuse. Accordingly, the Supreme Court affirmed in part, reversed in part, and remanded the case for entry of judgment dismissing the Beerses' complaint. View "Beers v. Corporation of the President of the Church of Jesus Christ of Latter-Day Saints" on Justia Law

At issue in this case was a medical malpractice claim brought against a physician's assistant, two supervising physicians and Rocky Mountain Emergency Physicians, LLC. Plaintiff-Appellant Heather Hall went to the emergency room complaining of headache, blurred vision and sensitivity to light. The assistant examined her, and in the process, plaintiff alleged the assistant touched her inappropriately while trying to listen to plaintiff's heartbeat through a stethoscope. Plaintiff's medical expert opined that this conduct fell below the standard of care for a physician's assistant working in an emergency room in Pocatello. Rocky Mountain moved for summary judgment, arguing that the expert lacked proper foundation. The district court granted Rocky Mountain's motion and dismissed the suit. Finding no error in the district court judgment, the Supreme Court affirmed. View "Hall v. Rocky Mtn Emergency Physicians" on Justia Law

Claimant Rubio Izaguirre settled with a third-party tortfeasor following a work-related automobile accident. His employer and surety asserted a right of subrogation against the entirety of that settlement. On appeal, claimant argued that subrogation rights should have extended only to damages that workers’ compensation typically insures and not to pain and suffering. The Commission found in favor of the employer and surety, holding that all of the settlement proceeds were subject to subrogation. Finding no error, the Supreme Court affirmed. View "Izaguirre v. R&L Carriers" on Justia Law