Justia Idaho Supreme Court Opinion Summaries

William Weeks was employed as an equipment operator for Oneida County’s Road and Bridge Department in Idaho. In September 2021, during a period of high COVID-19 transmission, Mr. Weeks continued working as required for critical infrastructure employees. He attended daily morning meetings with coworkers in a break room and often visited local stores. After a coworker became ill and missed work, Mr. Weeks developed COVID-19 symptoms, tested positive, and later died from complications. His wife, JaLyn Weeks, filed a worker’s compensation claim, alleging he contracted COVID-19 at work.The employer denied the claim, and Mrs. Weeks brought her case before the Idaho Industrial Commission. At the hearing, both parties presented expert testimony regarding the likely source and timing of Mr. Weeks’ infection. The Commission found the employer’s expert more persuasive, concluding that it was not possible to determine, by a preponderance of the evidence, that Mr. Weeks contracted COVID-19 at work rather than from other possible sources, such as visits to stores or contact with individuals outside of work. The Commission denied the claim for medical and death benefits.On appeal, the Supreme Court of the State of Idaho reviewed whether the Commission applied the correct legal standard and whether its findings were supported by substantial and competent evidence. The Court held that the Commission properly applied the preponderance of the evidence standard and did not err by refusing to resolve doubts in favor of compensability in occupational disease cases. The Court affirmed the Commission’s decision, holding that Mrs. Weeks failed to prove that Mr. Weeks actually incurred COVID-19 from his employment. The Court did not reach the issue of whether COVID-19 is a compensable occupational disease under Idaho law. View "Weeks v. Oneida County" on Justia Law

An employee suffered a severe hand injury, including the amputation of a finger, while operating a table saw without a safety guard at work. After receiving some worker’s compensation benefits, the employee filed a civil tort action against the employer, alleging that the employer’s requirement to use the saw without a guard constituted “willful or unprovoked physical aggression,” which, under Idaho law, would allow a lawsuit outside the worker’s compensation system. The employer did not respond to the lawsuit, and the employee obtained a default judgment for damages.Several months later, the employer moved to set aside the default judgment, arguing that the district court lacked subject matter jurisdiction because the employee’s worker’s compensation claim had been filed first. The District Court of the Fourth Judicial District agreed, stayed enforcement of the default judgment, and directed the parties to seek a determination from the Idaho Industrial Commission on whether the “willful or unprovoked physical aggression” exception applied. The Commission concluded that the exception did not apply, and the district court then set aside the default judgment and dismissed the civil action.On appeal, the Supreme Court of the State of Idaho held that the district court erred by deferring to the Commission on the applicability of the statutory exception and by setting aside the default judgment. The Supreme Court clarified that district courts have concurrent subject matter jurisdiction to determine whether the exception to the exclusive remedy rule applies, even if a worker’s compensation claim was filed first, unless the Commission has already decided the issue. The Supreme Court reversed the district court’s decision, vacated the Commission’s findings, and remanded with instructions to reenter the default judgment in favor of the employee. View "Tyler v. Masterpiece Floors, Inc." on Justia Law

A meat cutter with a long career suffered multiple work-related injuries over the years, including injuries to his back, shoulder, knee, and wrist, but was able to return to full-time, heavy-duty work after each incident. In 2015, he experienced a severe workplace accident in which his dominant right hand was caught in a meat grinder, resulting in the loss of most of his hand and significant impairment. Despite extensive medical treatment, including surgeries and a spinal cord stimulator, he was left with chronic pain and severe functional limitations. He was ultimately found to be totally and permanently disabled and unable to work.After settling with his employer, the claimant sought additional workers’ compensation benefits from the State of Idaho’s Industrial Special Indemnity Fund (ISIF), arguing that his pre-existing impairments, particularly a left wrist injury, combined with the 2015 accident to cause his total disability. The Idaho Industrial Commission held a hearing, considered expert testimony, and found that while the claimant had several pre-existing impairments, only the left wrist injury was a subjective hindrance to employment. However, the Commission concluded that the 2015 meat grinder accident alone rendered him totally and permanently disabled, as his prior injuries had not prevented him from working full-time before that event. The Commission adopted the findings of its appointed Referee and denied ISIF liability.The Supreme Court of the State of Idaho reviewed the case, applying a standard that defers to the Commission’s factual findings if supported by substantial and competent evidence. The Court held that the Commission’s determination was supported by the record, particularly the expert testimony that the 2015 accident, by itself, caused the claimant’s total and permanent disability. The Court affirmed the Commission’s order, holding that ISIF was not liable for any portion of the claimant’s disability. Costs on appeal were awarded to ISIF. View "Westman v. Industrial Special Indemnity Fund" on Justia Law

Elanore Vaughan purchased a ticket and signed an online liability waiver to go tubing at Eagle Island State Park, operated by Gateway Parks, LLC. The next day, Vaughan was injured when her tube went over an embankment and crashed into a flatbed trailer housing snowmaking equipment. Vaughan sued Gateway, alleging negligence and premises liability, claiming Gateway failed to maintain the tubing hill safely and created a hazard by placing the trailer at the end of the tubing run.The District Court of the Fourth Judicial District of Idaho denied Gateway's motion to dismiss Vaughan's complaint. Gateway argued that Vaughan's claims were barred by the liability waiver she signed and the Responsibilities and Liabilities of Skiers and Ski Area Operators Act. The district court found that while the Act applied, there was a genuine issue of material fact regarding the placement of the snowmaking equipment. The court also concluded that the liability waiver did not preclude Vaughan's claims. Gateway then sought and was granted permission to appeal the denial of its motion for summary judgment.The Supreme Court of the State of Idaho reviewed the case and reversed the district court's decision. The court held that the electronic liability waiver Vaughan signed precluded her claims against Gateway. The waiver explicitly acknowledged the risks of tubing, including collisions with manmade obstacles such as snowmaking equipment. The court determined that the waiver's language was broad enough to encompass Vaughan's accident and injuries. Consequently, the court directed the district court to grant summary judgment in favor of Gateway and dismiss Vaughan's complaint. The court also denied Gateway's request for attorney fees on appeal, as the gravamen of Vaughan's lawsuit was a tort, not a commercial transaction. View "Vaughan v. Gateway Park, LLC" on Justia Law

Laura Milus, on behalf of herself and her minor son, D.L.J., filed a wrongful death action against Sun Valley Company after her husband died from colliding with snowmaking equipment while skiing at Sun Valley Ski Resort. Milus claimed that Sun Valley breached its duties under Idaho Code section 6-1103(2) and (6) by not properly marking the equipment and failing to post a notice about snowmaking operations.The District Court of the Fifth Judicial District of Idaho granted summary judgment in favor of Sun Valley, concluding that the company met its duty under section 6-1103(2) by placing yellow padding on the equipment and had no duty under section 6-1103(6) because the equipment was not actively discharging snow. The court did not address Sun Valley's argument that Milus' claims were barred by section 6-1106, which states that skiers assume the risk of injury from plainly visible or marked snowmaking equipment.The Supreme Court of Idaho reviewed the case and held that ski area operators are held to an ordinarily prudent person standard of care when performing duties under the Ski Area Liability Act. The court found that Milus failed to create a genuine issue of material fact regarding whether Sun Valley met this standard with the yellow padding. However, the court also held that there was a genuine issue of material fact about whether Sun Valley posted the required notice under section 6-1103(6).Despite this, the court affirmed the district court's decision, concluding that Milus' claims were barred by section 6-1106 because Mr. Milus assumed the risk of injury from the plainly marked snowmaking equipment. The court denied Sun Valley's request for attorney fees on appeal, as both parties prevailed on some arguments. View "Milus v. Sun Valley Company" on Justia Law

The plaintiffs, Kandi Terry-Smith and Roy A. Smith, Jr., filed a complaint against Mountain View Hospital (MVH) and Idaho Falls Community Hospital (IFCH) alleging medical malpractice after Kandi suffered an injury while a patient at MVH. The complaint was filed on March 11, 2022, and a second, identical complaint was filed on September 8, 2022. The first case was dismissed for inactivity, but the district court granted an extension for service of process. The process server, Tony Mares, filed an affidavit claiming he served MVH, but deficiencies were later found.In the district court, MVH moved to dismiss the second case as time-barred and the first case for insufficient service of process. The district court denied the Smiths' motion to consolidate the cases and dismissed the second case. The district court granted MVH’s motion to dismiss the first case for insufficient service of process, finding that the Smiths failed to properly serve MVH. The Smiths' subsequent motions for reconsideration, to amend the complaint, and for additional extensions were denied. The district court also denied the Smiths' I.R.C.P. 60(b) motion for relief from the order denying reconsideration and judgment.The Idaho Court of Appeals reviewed the case and affirmed the district court’s judgment. The court held that the Smiths failed to show good cause for the failure to timely serve MVH and did not exercise due diligence. The court also found no excusable neglect and determined that the Smiths' attorney's reliance on the process server’s affidavit was unreasonable. The court denied MVH’s request for attorney fees in the district court due to the lack of a cross-appeal but granted attorney fees and costs on appeal, finding the Smiths' appeal frivolous and without foundation. View "Smith v. Mountain View Hospital, LLC" on Justia Law

Jon and Shawna Hill, along with their children, filed a medical malpractice lawsuit against Dr. Stuart Clive and his employer, Emergency Medicine of Idaho, P.A. (EMI), alleging that Clive misdiagnosed Jon Hill with vertigo when he was actually suffering from a stroke. This misdiagnosis led to severe physical and cognitive impairments for Jon Hill. The Hills claimed negligence, gross negligence, reckless misconduct, and respondeat superior liability. The district court dismissed the children's claims, ruling that Idaho does not recognize a claim for loss of parental consortium. The jury found in favor of EMI and Clive, and the district court denied the Hills' motion for a new trial based on alleged juror misconduct.The Hills appealed the district court's dismissal of their children's claims, two evidentiary rulings, and the denial of their motion for a new trial. The Idaho Supreme Court affirmed the dismissal of the children's claims, agreeing that Idaho law does not recognize a claim for loss of parental consortium for non-fatal injuries. The court noted that creating such a cause of action involves significant policy considerations best left to the legislature.The Idaho Supreme Court reversed the district court's decision to allow expert testimony on "hindsight bias" by EMI's expert, Dr. Opeolu M. Adeoye, finding it irrelevant and prejudicial. The court held that this error affected the Hills' substantial rights, as the testimony improperly endorsed EMI's theme of hindsight bias, potentially influencing the jury's decision. Consequently, the judgment in favor of EMI and Clive was vacated, and the case was remanded for a new trial. The court did not address the Hills' other issues on appeal due to the remand. EMI's request for attorney fees on appeal was denied, as they were not the prevailing party. View "Hill v. Emergency Medicine of Idaho, P.A." on Justia Law

Julene and William Dodd sued their attorney, Rory Jones, for legal malpractice after he missed the statute of limitations deadline for filing their medical malpractice lawsuit. The Dodds needed to prove that their original medical malpractice case had merit and that they would have won if Jones had filed on time. However, the district court struck the testimony of the Dodds’ experts, which was key to establishing the viability of their medical malpractice claim. The court found that the disclosures were untimely and that the experts failed to properly establish knowledge of the local standard of care, a foundational requirement of Idaho law. As a result, the Dodds’ legal malpractice claim was dismissed, and the court granted summary judgment in favor of Jones.The Dodds appealed to the Supreme Court of Idaho, arguing that the district court erred by ruling that Jones was not judicially estopped from arguing that no medical malpractice occurred and by excluding their expert testimony. They also raised claims of judicial bias. The Supreme Court of Idaho found that Jones could not be judicially estopped from claiming that no medical malpractice occurred because he was not a party in the original medical malpractice case but was representing the Dodds. The court also upheld the district court’s exclusion of the Dodds’ expert testimony, finding that the experts did not demonstrate familiarity with the local standard of care in Nampa, Idaho, at the time of the alleged malpractice.The Supreme Court of Idaho affirmed the district court’s judgment, concluding that the Dodds failed to establish an essential element of their legal malpractice case. The court also awarded attorney fees to Jones under Idaho Appellate Rule 11.2, finding that the appeal was pursued frivolously and without foundation, and sanctioned the Dodds’ attorney, Angelo Rosa, for his conduct during the appeal. View "Dodd v. Jones" on Justia Law

In 2019, Colby James Bray died while in the custody of the Idaho Department of Juvenile Corrections (IDJC). His parents, Jeffrey and Michelle Bray, acting as personal representatives of his estate, filed a wrongful death suit in federal court one day before the two-year statute of limitations expired. They later voluntarily dismissed the federal case and refiled in state court nearly three years after Colby's death. The defendants moved for summary judgment, arguing the claims were time-barred by the two-year statute of limitations. The district court granted the motions and dismissed the complaint with prejudice.The Brays appealed, arguing that Idaho Code section 5-234 and 28 U.S.C. section 1367(d) tolled the statute of limitations. The district court had concluded that section 5-234 did not toll the time for filing the state complaint and that section 1367(d) did not apply to IDJC due to Eleventh Amendment immunity. The court also awarded costs and attorney fees to the defendants.The Supreme Court of Idaho affirmed the district court's ruling that section 5-234 did not toll the statute of limitations. It also agreed that the claims against Meacham and the Individual Defendants were time-barred under section 1367(d) because the Brays did not file within 30 days after the federal court dismissed those claims. However, the court found that section 1367(d) did toll the time for filing the complaint against IDJC, but IDJC was immune from the claims under Idaho Code section 6-904B(5). The court upheld the district court's award of attorney fees and costs to the defendants and awarded attorney fees and costs on appeal to the respondents. View "Bray v. ID Dept of Juvenile Corrections" on Justia Law

Dustin Clover sustained injuries while removing irrigation drip tape from a seed field while working for Crookham Company in 2018. Clover filed a complaint against Crookham, alleging that his injuries fell within an exception to the exclusive remedy rule under the Worker’s Compensation statutes, which allows for a separate civil action if the employer commits an act of “willful or unprovoked physical aggression.” Crookham moved for summary judgment, arguing that Clover failed to provide evidence supporting his claim. The district court agreed and granted summary judgment in favor of Crookham. Clover’s motion for reconsideration was also denied, leading to this appeal.The district court of the Third Judicial District of Idaho found that Clover’s injuries occurred during the course of his employment and were covered by worker’s compensation. The court concluded that Clover did not present sufficient evidence to show that Crookham’s actions fell under the “willful or unprovoked physical aggression” exception to the exclusive remedy rule. The court noted that there were no prior incidents or complaints about the drip tape lifter’s safety and that Crookham had used the equipment for nine seasons without injury.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The court held that Clover failed to demonstrate that Crookham consciously disregarded knowledge that the drip tape lifter was unsafe. The court also found that the district court did not abuse its discretion in excluding certain evidence and denying Clover’s motion for reconsideration. The court concluded that Clover did not present new facts sufficient to raise a genuine dispute of material fact. Consequently, the district court’s grant of summary judgment and denial of the motion for reconsideration were affirmed. Crookham was awarded costs as the prevailing party on appeal. View "Clover v. Crookham Company" on Justia Law