Justia Idaho Supreme Court Opinion Summaries

Justin S. Reynolds, Kristine Reynolds, and their construction company, Sunrise Development, LLC (Reynolds) brought a malpractice action against their law firm, Trout Jones Gledhill Fuhrman, P.A., and its attorney-employee, David T. Krueck. Reynolds alleged professional negligence in both the drafting of a real estate agreement between Reynolds and Quasar Development, LLC, and in the subsequent handling of the litigation regarding that agreement. The district court granted summary judgment in favor of Trout Jones, holding that the two-year statute of limitations found in Idaho Code section 5-219(4) applied to bar the action and Reynolds timely appealed. Upon review of the matter, the Supreme Court affirmed. View "Reynolds v. Trout, Jones, Gledhill, Fuhrman, P.A." on Justia Law

The United States District Court for the District of Idaho certified a question of law to the State Supreme Court: whether a legal malpractice claim that is transferred to an assignee in a commercial transaction (along with other business assets and liabilities) is assignable under law. The issue stemmed from St. Luke's Magic Valley Regional Medical Center's purchase of Magic Valley Medical Center. Thomas Luciani and his law firm Stamper, Rubens, Stocker & Smith, P.S. represented Magic Valley in defending a wrongful termination and False Claims Act action brought by former hospital employees. After the sale of the medical center closed, Magic Valley no longer existed. The operation and management of the center was taken over by St. Luke's. St. Luke's then sued its former lawyer and law firm. The District Court noted that the assignability of a legal malpractice claim in the factual context presented had not yet been squarely addressed by the Idaho Supreme Court. Upon review, the Idaho Supreme Court answered the district court's question in the affirmative: although legal malpractice claims are generally not assignable in Idaho, where the legal malpractice claim is transferred to an assignee in a commercial transaction, along with other business assets and liabilities, such a claim is assignable. View "In re: St. Lukes Magic Valley RMC v. Luciani, et al." on Justia Law

A jury returned a special verdict that: (a) awarded damages against an attorney and his girlfriend based upon the jury's finding that they had breached their fiduciary duties to a former client of the attorney by purchasing half of his stock in a closely held corporation for less than its fair market value; and (b) cancelled debts owing by the corporation to the attorney and his girlfriend based upon the jury's finding that they had breached their fiduciary duties to a shareholder, the former client's widow, by making loans to the corporation. The district court granted a new trial on the ground that there was insufficient evidence to justify the verdict, and this appeal followed. Finding sufficient evidence to support the jury's verdict, the Supreme Court affirmed the grant of a new trial. View "Berry v. McFarland" on Justia Law

Patricia Shelton filed suit alleging breach of contract a legal malpractice against her former attorneys Defendants-Appellants R. Bruce Owens, Jeffrey Crandall, and Owens and Crandall, PLLC (Owens). During the pendency of her action, Ms. Shelton passed away. Plaintiff-Appellee Lois Bishop sought to assert Ms. Shelton's claims as her personal representative. Owens unsuccessfully argued that the legal malpractice claim abated upon Ms. Shelton's death, and that her breach of contract claim did not state a claim. Owens appealed. Because Patricia Shelton’s legal malpractice claim sounds in tort and abated upon her death, and her breach of contract claim fails to state a claim, the Supreme Court concluded the district court erred in denying Owens’s motion for summary judgment and in granting Bishop’s motion to substitute as plaintiff. View "Owen v. Bishop" on Justia Law