Justia Idaho Supreme Court Opinion Summaries

At issue in this case was a worker’s compensation claim stemming from an accident at an onion processing plant. Petitioner James Clark was injured when his right forearm was caught in a roller machine which resulted in significant soft-tissue damage. The Industrial Commission determined that Clark suffered a compensable injury and that he was entitled to medical treatment for approximately one year. The Commission also found that Clark had a permanent partial impairment (PPI) of 10% of the whole person and a permanent partial disability rated at 25% of the whole person. Clark appealed that determination pro se, arguing the Commission relied on fraudulent evidence because his medical records were fraudulently obtained. Finding no error, the Supreme Court affirmed. View "Clark v. State Ins Fund" on Justia Law

A bank hired a contractor to perform janitorial and snow removal services. The written contract between the parties lapsed, but they orally renewed their agreement according to the same terms. One morning, a bank employee arrived at work and parked in the parking lot. She stepped out of her car, slipped on black ice, and was injured. The employee sued the contractor, claiming that it had negligently failed to spread ice melt on the parking lot. The district court granted the contractor's motion for summary judgment, holding that the contractor owed no duty to spread ice melt on the parking lot on any day in which less than two inches of snow had fallen. The employee then appealed to the Supreme Court. Finding no genuine issue of material fact remaining regarding whether the contractor owed a duty to spread ice melt on the parking lot, the Supreme Court concluded the trial court properly granted summary judgment in favor of the contractor. View "Gagnon v. Western Building Maintenance, Inc." on Justia Law

The Supreme Court affirmed the district court’s order granting a new trial on plaintiffs' claim for breach of the implied warranty of habitability and its denial of defendants' request for attorney fees at trial. Plaintiffs Shawn and Shellee Goodspeed purchased a home from Robert and Jorja Shippen via warranty deed. After the basement of the home flooded, the Goodspeeds filed suit against the Shippens, alleging breach of the implied warranty of habitability. The district court denied a request for a jury instruction on the requirements for disclaiming the implied warranty of habitability and the case went to trial. The jury returned a verdict in favor of the Shippens, and the Goodspeeds moved for judgment notwithstanding the verdict or, alternatively, for a new trial, arguing the disclaimer of the implied warranty of habitability in the purchase and sale agreement was ineffective because it was not conspicuous. The district court granted a new trial after determining it had excluded the disclaimer instruction based upon its incorrect belief that the Goodspeeds had actual knowledge of the disclaimer. View "Goodspeed v. Shippen" on Justia Law

The State Board of Dentistry fined Plaintiff-Appellant Lon Peckham, DMD for failing to adequately inform a patient prior to performing a procedure, and for publishing misleading material on his website. The district court affirmed the Board's decision. On appeal, Plaintiff challenged the district court's affirming of the Board's final Order. Upon review of the matter, the Supreme Court found insufficient evidence to support findings that Plaintiff failed to inform a patient prior to performing a procedure or for publishing misleading material. Accordingly, the Supreme Court reversed the district court. View "Peckham, DMD v. State Bd of Dentistry" on Justia Law

Katherine Harris sought workers' compensation benefits after falling and injuring herself at work in January of 2008. Following a hearing, the Idaho Industrial Commission decided that Harris was not entitled to disability or medical benefits after February 19, 2008. Harris appealed to the Supreme Court. Upon review of the Commission record, the Supreme Court concluded that the Commission did not err in its conclusion that Harris was only entitled to benefits provided up to February 19, 2008. View "Harris v. Ind School Dist No 1" on Justia Law

This appeal arose from an action filed against the City of Lewiston by Tim Thompson, Janet Thompson, and Thompson's Auto Sales (collectively, Thompson). Thompson filed a claim under the Idaho Tort Claims Act (ITCA), alleging the City negligently designed and installed a storm water drain system on a city street adjacent to Thompson's property, which caused storm water runoff to flow onto Thompson's property and damage it. After suit was filed, Thompson entered bankruptcy proceedings and the bankruptcy trustee, C. Barry Zimmerman, was substituted as Plaintiff in the action. The City moved for summary judgment on the grounds of discretionary immunity and design immunity. The district court denied the motion as to design immunity, but granted the motion on the ground of discretionary immunity. Zimmerman appealed, arguing that the discretionary immunity exception to liability under the ITCA does not grant immunity from liability for damage caused by negligent design and, alternatively, that even if discretionary immunity was considered, it was inapplicable in this case because the City's actions were not discretionary within the meaning of the exception. Upon review, the Supreme Court reversed, finding that the City was not entitled to immunity from liability under any exception to the ITCA. View "Zimmerman v. City of Lewiston" on Justia Law

Plaintiff Thomas R. Taylor filed this action seeking to recover damages for alleged medical malpractice. Pursuant to Idaho Code section 6-1001, he then filed a request for a prelitigation screening panel four days later. The panel appointed regarding the alleged malpractice in this case conducted its proceedings and then issued its report on April 19, 2011. Although Plaintiff filed this action on January 20, 2011, he did not attempt to serve the summons and complaint upon any of the Defendants within six months after filing the complaint as mandated by Rule 4(a)(2) of the Idaho Rules of Civil Procedure. On August 16, 2011, defendant Eastern Idaho Health Services, Inc. filed a motion to dismiss this action as to it for the failure of Plaintiff to serve the summons and complaint upon it within the six-month period. Plaintiff filed a motion asking the district court to stay this lawsuit "nunc pro tunc from January 24, 2011, to April 19, 2011, or, alternatively, to extend [Plaintiff's] deadline for serving all Defendants to this lawsuit from July 19, 2011, to October 12, 2011." The district court entered an order denying Plaintiff's motions and granting the motions to dismiss filed by defendants. Plaintiff filed a notice of appeal. Because the partial judgment was not yet final due to the fact that there was no judgment resolving the claims against the remaining defendants, the Supreme Court then issued a notice that the appeal would be dismissed. Plaintiff then filed an amended notice of appeal timely appealing both the initial judgment and the amended judgment. The Supreme Court affirmed the district court: if there is not good cause for the failure to serve a defendant with the summons and complaint within six months after the complaint was filed, Rule 4(a)(2) states that "the action shall be dismissed as to the defendant without prejudice." Had Plaintiff served the Defendants before the prelitigation screening panel had completed its work, the worst that could have happened is that the district court would have stayed the court proceedings until after the panel had completed its work and for thirty days thereafter. Even if Plaintiff had thought he should wait until thirty days after the panel issued its report before serving the Defendants with a summons and complaint, he had from May 19, 2011, until July 20, 2011 to do so, but did not even attempt service during that time. View "Taylor v. Chamberlain" on Justia Law

Benjamin Morris appealed an order of the Idaho Industrial Commission that denied his motion to set aside a lump sum settlement agreement he made with his employer's surety, Liberty Northwest Insurance. Morris initiated his workers' compensation action after he suffered injuries while working construction for his employer, Hap Taylor & Sons, Inc. Morris sustained a serious head injury on when a twenty-five pound rock thrown by a piece of heavy machinery struck him in the head. Morris initiated settlement discussions with Liberty Northwest Insurance, Hap Taylor & Sons' insurer. Liberty responded with a counter-offer—a single lump sum payment which Morris accepted "with the clear understanding this is a partial settlement and does not resolve the medical side." The parties executed a Stipulation and Agreement of Partial Lump Sum Discharge (LSSA) and submitted it to the Commission for approval. Approximately eighteen months later, on July 8, 2011, a Notice of Appearance was filed with the Commission whereby Morris substituted attorney Michael Walker with his then present counsel, attorney Starr Kelso. On the same day, Morris filed a motion to review the LSSA, accompanied by an affidavit signed by Kelso. Kelso's affidavit expressed concern that Morris may not have been "competent to testify" due to his injury—though, no credible evidence of incompetence was ever offered. Liberty filed an objection to Morris' motion to review. Ultimately, the Commission denied Morris' motion. Following the Commission's refusal to review the LSSA, Morris filed a Motion to Set Aside Lump Sum Settlement Agreement, seeking to void the LSSA on grounds of illegality and constructive fraud. The Commission issued an order denying Morris' motion to set the LSSA. Morris filed a timely appeal to the Supreme Court. After its review, the Supreme Court concluded that the Commission did not err in denying Morris' request for a hearing on his fraud claim. Furthermore, the Court affirmed the Commission's decision to deny Morris' motion to set the LSSA. View "Morris v. Hap Taylor & Sons" on Justia Law

This case arose from the water loss claims Appellant Roger Daniel Rizzo made under Respondent State Farm Fire and Casualty Company's homeowners insurance policy. All of Appellant's claims were for water damage to his home's basement. The district court granted summary judgment in favor of the insurance company, effectively dismissing all of Appellant's causes of action because his homeowner's policy did not cover his water damage claims. Appellant also appealed the district court's denial of his motion to amend his complaint to include various new causes of action and the district court's grant of State Farm's motion for protective order against certain overbroad discovery requests. Finding no error in the district court's grant of summary judgment in favor of State Farm, the Supreme Court affirmed the district court's decisions. View "Rizzo v. State Farm Insurance" on Justia Law

At issue before the Supreme Court in this case was appeal and cross-appeal of summary judgments dismissing claims against Defendants Ada County, Deputy Jeremy Wroblewski, Kate Pape, and James Johnson in a 42 U.S.C. 1983 civil rights action brought by Rita Hoagland on behalf of herself and the estate of her deceased son, Bradley Munroe ("Munroe"), claiming a violation of a Fourteenth Amendment right to medical care and safety while Munroe was detained at Ada County Jail where he committed suicide. Munroe had a history of incarceration at Ada County Jail ("ACJ"). During the evening of September 28, 2008, Munroe was arrested and charged with the armed robbery of a convenience store. Munroe was intoxicated and uncooperative. During booking, Munroe was screaming and being rowdy. Munroe took a string and wrapped it around his neck. Because of his bizarre behavior throughout the night, Munroe was placed in a holding cell for observation until he was sober. The next morning booking continued. At that time, Munroe requested protective custody. Munroe was placed in a cell by himself and a well-being check was scheduled to occur every thirty minutes. Later that evening during a well-being check, the performing deputy found Munroe hanging from his top bunk by a bed sheet. Munroe was pronounced dead later that evening. Among the issues on appeal were: whether the decedent's estate could assert a 42 U.S.C 1983 action for alleged violations of the decedent's constitutional rights; whether the parent had standing to assert a 42 U.S.C. 1983 action for the death of her adult child while incarcerated; and whether the district court erred in awarding costs to Defendants. Upon review, the Supreme Court concluded that the district court: (1) was affirmed in dismissing Hoagland's 1983 claim on behalf of Munroe's estate; (2) was reversed in finding that Hoagland had a 1983 cause of action for violations of her own constitutional rights; (3) was partially affirmed in its award of costs as a matter of right; (4) was reversed in its award of discretionary costs; and (5) was affirmed in denying attorney fees. The case was remanded for the reconsideration and entry of express findings regarding the district court's award of discretionary costs. View "Hoagland v. Ada County" on Justia Law