Justia Idaho Supreme Court Opinion Summaries

A wildfire destroyed David and Kristina Parks’ house, which was insured by Safeco Insurance Company (“Safeco”). The Parks purchased an existing house, and Safeco paid the Parks a total of $255,000, the cost of the replacement house less the value of the land. The Parks filed a complaint against Safeco alleging: (1) they were entitled to $440,195.55 under the policy; and (2) Safeco committed bad faith in handling the claim. Safeco filed a Motion for Summary Judgment asserting that the policy was not breached and its conduct did not constitute bad faith. The Parks filed a Cross-Motion for Summary Judgment asserting that Safeco misrepresented the policy. Additionally, the Parks moved to amend their complaint to include a claim for punitive damages. The district court held that: (1) there was no breach of contract because the policy was unambiguous and the Parks received the amount due under the clear language of the policy; (2) Safeco did not commit bad faith in handling the claim because it complied with the terms of the policy and paid the Parks the amount owed; and (3) the Parks had not established a reasonable likelihood of proving facts at trial sufficient to support an award of punitive damages. The Parks appealed, but finding no reversible error, the Idaho Supreme Court affirmed. View "Parks v. Safeco Ins Co of Illinois" on Justia Law

In early 2011, Trent Gearheart was severely injured in an automobile accident caused by an underinsured motorist (“UIM”). After the accident, Trent’s parents, Ronald Gearhart and Brandi L. McMahon, who were divorced, each attempted to collect on their separately held auto insurance policies with Enumclaw. Each of those policies provided maximum coverage of $300,000 for accidents caused by underinsured motorists. Enumclaw contended that because of anti-stacking language in the policies, the total UIM benefit under the combined policies was limited to $300,000. The district court held on summary judgment that the UIM anti-stacking provision in each policy was invalid and, therefore, ruled that Enumclaw was obligated for the full $300,000 policy limit on both policies. Enumclaw appealed. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgment. View "Gearhart v. Mutual of Enumclaw Ins Co" 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

In 2012, a fire destroyed three buildings and related equipment that were owned by Jackson Hop, LLC, and were used to dry hops, to process and bale hops, and to store hop bales. The buildings were insured by Farm Bureau Mutual Insurance Company of Idaho for the actual cash value of the buildings and equipment, not to exceed the policy limit. Farm Bureau’s appraisers determined that the actual cash value of the buildings was $295,000 and the value of the equipment was $85,909. Farm Bureau paid Jackson Hop $380,909. Jackson Hop disagreed with that figure, and it hired its own appraiser, who concluded that the actual cash value of the buildings and equipment totaled $1,410,000. Farm Bureau retained another appraiser to review the report of Jackson Hop’s appraiser, and that appraiser concluded that the value of $1,410,000 was unrealistically high. Jackson Hop filed this action to recover the balance of what it contended was owing under the insurance policy, plus prejudgment interest. The parties agreed to submit the matter to arbitration as provided in the policy. During that process, Jackson Hop presented additional opinions regarding the actual cash values, ranging from $800,000 to $1,167,000 for the buildings and $379,108 to $399,000 for the equipment. Farm Bureau’s experts revised their opinions upward, although only from $295,000 to $333,239 for the buildings and from $85,909 to $133,000 for the equipment. Before completion of the arbitration, Farm Bureau paid an additional sum of $85,330. Arbitrators determined that the actual cash value of the buildings and the equipment was $740,000 and $315,000, respectively, for a total of $1,055,000. Within seven days of the arbitrators’ decision, Farm Bureau paid Jackson Hop $588,761, which was the amount of the arbitrators’ award less the prior payments. Jackson Hop filed a motion asking the district court to confirm the arbitrators’ award and to award Jackson Hop prejudgment interest, court costs, and attorney fees. Farm Bureau filed an objection to the request for court costs, attorney fees, and prejudgment interest. The court awarded Jackson Hop attorney fees, but denied the request for court costs because the parties’ arbitration agreement stated that both parties would pay their own costs, and the court denied the request for prejudgment interest because the amount of damages was unliquidated and unascertainable by a mathematical process until the arbitrators’ award. Jackson Hop then appealed. Finding no reversible error in the trial court's judgment, the Supreme Court affirmed. View "Jackson Hop v. Farm Bureau Insurance" on Justia Law

This appeal stems from an arbitration decision regarding Peggy Cedillo's underinsured motorist insurance policy with Farmers Insurance Company of Idaho, and damages for injuries she suffered in a motorcycle accident. After the arbitrator issued his final award, Farmers provided the arbitrator evidence that Farmers had already paid Cedillo the total amount of remaining damages. The arbitrator adjusted the award by subtracting Farmers' payment from the prejudgment interest Farmers owed Cedillo. The district court confirmed the arbitrator's amended award and awarded Cedillo attorney fees. On appeal, Farmers argued the district court should have modified the award because the arbitrator miscalculated prejudgment interest by applying Farmers' payment to the interest award. Farmers also argued numerous grounds that Cedillo was not entitled to attorney fees. Finding no reversible error, the Supreme Court affirmed. View "Cedillo v. Farmers Insurance Co of Idaho" on Justia Law

LuAnn Shubert fell and injured her lower back while working at a Macy’s store. She appealed the Idaho Industrial Commission’s order holding that she was: (1) medically stable on November 21, 2007; (2) not entitled to medical benefits beyond that date; (3) not entitled to temporary disability benefits; (4) entitled to a permanent partial impairment rating of 5% of the whole person; and (5) entitled to a 10% permanent partial disability rating. Shubert argued that she was entitled to ongoing medical care, temporary disability benefits, and total permanent disability benefits over 10%. Macy’s West (Macy’s) and Liberty Insurance Corporation argued that Shubert was rearguing the facts. Finding no reversible error in the Commission's decision, the Idaho Supreme Court affirmed. View "Shubert v. Macy's West, Inc." on Justia Law

Claimant-appellant Trudy Deon brought worker compensation claims against her employer, H&J, Inc., and its surety, Liberty Northwest, (Employer/Surety) and the Idaho Special Indemnity Fund (ISIF). Deon eventually settled with ISIF but the claim against Employer/Surety went to a hearing that resulted in the Idaho Industrial Commission finding Employer/Surety 100% liable for her total and permanent disability (TPD). The Commission decided sua sponte to reconsider its decision and invited the parties to brief the issue of whether Deon was estopped from arguing Employer/Surety was 100% liable, given her settlement with ISIF. In an order on reconsideration, the Commission held that Deon was so estopped and apportioned 23.92% of her TPD to Employer/Surety. Deon appealed. Upon review, the Supreme Court determined the Commission erred by sua sponte raising the issue of collateral estoppel. The Commission and Employer/Surety knew about the ISIF settlement agreement for months before a decision was rendered and never raised the estoppel issue. Deon filed complaints against both her Employer/Surety and the ISIF. As a result of mediation, she reached a tentative settlement agreement with ISIF on October 5, 2012. The agreement was reduced to writing, signed by the parties on October 19, 2012, and approved by the Commission on November 8, 2012. When the Commission issued its Decision, it determined that Deon was totally and permanently disabled and that Employer/Surety was 100% liable under the odd-lot doctrine as Deon had argued. After considering all the hearing evidence and the parties’ briefing, the Commission found apportionment between the ISIF and Employer/Surety “is not appropriate” because “[t]he record does not establish that Claimant’s pre-existing leg condition combined with her 2008 industrial accident to render her totally and permanently disabled. However, on the same day the Commission issued its Decision, it also issued a notice of reconsideration pursuant to Idaho Code section 72-718, which raised for the first time the collateral estoppel. Specifically, the Commission wanted to know whether Deon’s stipulation to ISIF’s partial liability for her TPD estopped her from then arguing that Employer/Surety was 100% liable. After the parties briefed the issue, the Commission issued a new order holding that Deon was estopped from asserting a position inconsistent with her stipulation that ISIF was partially liable for her TPD. It then apportioned TPD liability according to the "Carey" formula, changing Employer/Surety’s liability from 100% to 23.92%. The Supreme Court concluded the revised findings were hinged solely on the Commission’s erroneous view of the law, and were without any support in the hearing record. Therefore, the Court reversed the Order on Reconsideration. Because the Commission did, in fact, hear Deon’s claim against Employer/Surety on the merits and determined Employer/Surety was 100% liable, Deon was entitled to 100% of her benefits from Employer/Surety. View "Deon v. H &J, Inc." on Justia Law

Gary Corgatelli sought worker's compensation benefits from his employer Steel West and the State of Idaho's Industrial Special Indemnity Fund (ISIF) for a 2005 back injury that he incurred as a result of his employment. The Idaho Industrial Commission concluded that Corgatelli had a permanent physical impairment of 15% of the whole person, attributing 5% to an earlier injury in 1994 and 10% to the 2005 injury, and that Corgatelli was totally and permanently disabled. The Commission further concluded that ISIF was liable for disability benefits because the effects of Corgatelli's preexisting impairment from the 1994 injury combined with his 2005 injury to cause total and permanent disability. The Commission subsequently issued an order to clarify that Steel West was entitled to credit on the disability award for permanent physical impairment benefits Steel West previously paid to Corgatelli for his 2005 injury. Corgatelli appealed the Commission's order to credit Steel West. ISIF cross-appealed the Commission's determination of ISIF liability. Upon review, the Supreme Court concluded the Commission erred when it allowed Steel West to offset its liability for total and permanent disability benefits with permanent physical impairment benefits previously paid to Corgatelli. Furthermore, the Court found no substantial evidence to support the Commission's finding that ISIF was liable to Corgatelli for benefit payment. The Commission's award to Steel West of a credit for permanent physical impairment benefits previously paid to Corgatelli in 2006 and 2007 for his 2005 back injury was vacated. The Commission's finding of ISIF liability was reversed. And this case was remanded for further proceedings. View "Corgatelli v. Steel West, Inc." on Justia Law

DAFCO LLC sought recovery against Stewart Title Guaranty Co. on a lender's title insurance policy and against AmeriTitle, Inc., the closing agent for the lending transaction, claiming that it sustained injury as a result of a defective deed of trust. The district court granted summary judgment in favor of Stewart and AmeriTitle, resulting in this appeal by DAFCO. Finding no reversible error, the Supreme Court affirmed. View "DAFCO v. Stewart Title Guaranty Co" on Justia Law

In 2010, Idaho Power entered into two Firm Energy Sales Agreements, one with New Energy Two, LLC, and the other with New Energy Three, LLC, under which Idaho Power agreed to purchase electricity from them that was to be generated by the use of biogas. The agreement with New Energy Two stated that the project would be operational on October 1, 2012, and the agreement with New Energy Three stated that the project would be operational on December 1, 2012. Both contracts were submitted for approval to the Idaho Public Utilities Commission, and were both approved on July 1, 2010. Each of the agreements contained a force majeure clause. By written notice, New Energy Two and New Energy Three informed Idaho Power that they were claiming the occurrence of a force majeure event, which was ongoing proceedings before the Public Utilities Commission. New Energy asserted that until those proceedings were finally resolved "the entire circumstance of continued viability of all renewable energy projects in Idaho is undecided"and that as a consequence "renewable energy project lenders are unwilling to lend in Idaho pending the outcome of these proceedings."Idaho Power filed petitions with the Commission against New Energy Two and New Energy Three seeking declaratory judgments that no force majeure event, as that term was defined in the agreements, had occurred and that Idaho Power could terminate both agreements for the failure of the projects to be operational by the specified dates. New Energy filed a motion to dismiss both petitions on the ground that the Commission lacked subject matter jurisdiction to interpret or enforce contracts. After briefing from both parties, the Commission denied New Energy's motion to dismiss. The Commission's order was an interlocutory order that is not appealable as a matter of right. New Energy filed a motion with the Supreme Court requesting a permissive appeal pursuant to Idaho Appellate Rule 12, and the Court granted the motion. New Energy then appealed. Finding no reversible error, the Supreme Court affirmed the Commission's order. View "Idaho Power v. New Energy Two" on Justia Law