Justia Idaho Supreme Court Opinion Summaries

Travis Forbush and Gretchen Hymas, individually and as natural parents of McQuen Forbush and Breanna Halowell (Appellants), appealed the grant of summary judgment to Respondents Sagecrest Multifamily Property Owners’ Association, Inc., and its President, Jon Kalsbeek. Forbush and Halowell were overnight guests of a tenant who leased a unit at the Sagecrest Apartment Complex (Sagecrest). During the night, hazardous levels of carbon monoxide filled the unit, killing Forbush and injuring Halowell. Appellants brought tort claims against Respondents after the incident. Appellants contended the district court erred by granting summary judgment to the POA because triable issues of fact surrounded whether the POA: (1) owed a premises liability-based duty of care; (2) owed a duty of care it acquired as a result of voluntary undertakings; and (3) was vicariously liable for First Rate Property Management's (FRPM - the POA's contract maintenance) conduct. The Idaho Supreme Court affirmed in part and reversed in part the district court’s summary judgment order. The Court affirmed that summary judgment was proper as to whether the POA owed a premises liability-based duty of care. However, summary judgment was improper as to whether the POA and Kalsbeek acquired a duty of care as a result of voluntary undertakings, and whether the POA was vicariously liable for FRPM’s conduct. View "Forbush & Hymas v. Sagecrest POA" on Justia Law

The Idaho Supreme Court determined the district court did not err when it found that the Church did not have a special relationship with Henrie such that it had an affirmative duty to control or protect him, nor was there any issue of fact as to whether the Church had a general duty to prevent Henrie's injury. This case arose out of injuries suffered by Bryan Henrie while he was participating in a community service event organized by the Mormon Helping Hands (“Helping Hands”), a priesthood-directed program run by the Church of Jesus Christ of Latter-day Saints (the “Church”). Henrie argued on appeal that the district court erred when it dismissed his tort claim on summary judgment. Henrie was assigned to work with a crew felling burned trees and rolling or throwing the wood down an embankment on the property to be hauled away later. Later that day, Henrie was attempting to throw a tree stump down the embankment when it caught on his smock. He was pulled down the embankment by the stump, severely injuring his right knee in the process. Henrie asserted that “[a]t the very least, Defendant had a duty not to supply Plaintiff with gear or clothing that would put him or his bodily safety in danger or ultimately harm him . . . Defendant breached this duty of care.” He further asserted that “Defendant owed a duty to Plaintiff to use reasonable care in nominating, training, and supervising any and all of the clean-up organizers and volunteers, including those who spoke with and directed Plaintiff.” The Supreme Court affirmed the district court's grant of summary judgment in favor of the Church. View "Henrie v. Church of Latter-Day Saints" on Justia Law

Steven Andrews filed for workers’ compensation benefits after he fell from a ladder in 2009 while working for the Corporation of the Church of Jesus Christ of Latter Day Saints (LDS Church). Andrews sought to establish that the Idaho Industrial Special Indemnity Fund (ISIF) was liable pursuant to Idaho Code section 72- 332. The referee concluded that Andrews failed to show that ISIF was liable because the evidence showed that any pre-existing physical impairments did not constitute a subjective hindrance and that Andrews failed to show that his pre-existing impairments combined with the industrial accident to cause his total and permanent disability. The Commission adopted the recommendation. Andrews timely appealed, arguing that the Commission’s order was not supported by substantial and competent evidence. Not persuaded by Andrews’ arguments, the Idaho Supreme Court affirmed. View "Andrews v. Idaho Industrial Special Indemnity Fund" on Justia Law

Leticia Salinas injured her back while working for Bridgeview Estates (“Employer”). After receiving medical treatment for roughly six weeks, her workers’ compensation benefits were temporarily denied by Old Republic Insurance Company. Nearly two years later, Salinas filed a claim for reimbursement for medical costs and all future medical care. The Idaho Industrial Commission concluded that Salinas failed to prove that she was entitled to payment of compensation. Notwithstanding that conclusion, the Commission awarded Salinas attorney’s fees. The Employer appealed the award. The Supreme Court concluded the Commission erred in awarding attorney’s fees, and vacated the judgment. View "Salinas v. Bridgeview Estates" on Justia Law

Enrique Lopez appeals an order of the Idaho Industrial Commission (“Industrial Commission”) declining to award him additional workman’s compensation income benefits for binaural hearing loss he sustained as a result of a workplace accident. Lopez was injured by a bull while working on a dairy. Lopez complained to the Industrial Commission that he was entitled to additional income benefits based on his interpretation of the statutory schedule for permanent impairments in Idaho Code section 72-428. The Industrial Commission disagreed, holding that Lopez was only entitled to the 8% impairment benefits previously paid. Lopez timely appealed. Finding no error in the Commission’s calculation of Lopez’ income benefits for his partial binaural hearing loss, the Supreme Court affirmed. View "Lopez v. Vanbeek Herd Partnership" on Justia Law

In 2014, seventeen-year-old plaintiff Seth Griffith was seriously injured when he attempted a triple front flip into a pit filled with foam blocks at an indoor trampoline park owned and operated by JumpTime Meridian, LLC (“JumpTime”). Plaintiff’s girlfriend and her sister were near the large foam pit. Plaintiff jumped into the large foam pit a few times. He spent about 45 minutes “kind of horsing around on both the runway trampoline and the foam pit and the twin trampolines.” After he did a double front flip into the small foam pit, the monitor came up to him and asked if he had ever done a double before. He answered that he had. As he continued performing double front flips into the small foam pit, he decided to try a triple front flip. When he attempted it, he did not rotate far enough and landed on his head and neck, suffering a cervical dislocation and fracture, which required a fusion of his C6 and C7 vertebrae. Plaintiff filed this action alleging that JumpTime negligently caused his injury. He contended that because he was under the age of eighteen, JumpTime had a duty to supervise him. He had been intentionally landing the double front flips on his back in the pit. He testified that he did so “because you don’t want to land on your feet because you can bash your head against your knees.” JumpTime’s written policy manual instructed its employees with respect to the foam pit to “[f]ollow the rules outlined on the wall and continuously enforce it.” There were signs on the walls near the two pits that instructed customers to land on their feet. JumpTime moved for summary judgment alleging that there was no negligence, based upon the opinion of an expert that industry standards permitted landing a front flip into a foam pit on one’s feet, buttocks, or back, and that there was no evidence of causation. In response, Plaintiff contended that the signs on the wall stating how to land in the foam pit established the standard of care and that because of the attendant’s failure to admonish him for landing incorrectly, he was not discouraged from attempting a more difficult maneuver like a triple front flip. The district court granted JumpTime’s motion for summary judgment, holding that Plaintiff had failed to produce evidence of negligence and causation. Plaintiff then timely appealed. Finding that Plaintiff’s testimony did not support an inference that JumpTime was in any way responsible for his decision to try the triple front flip, the district court did not err in granting summary judgment to JumpTime based upon the lack of evidence regarding causation. View "Griffith v. JumpTime Meridian, LLC" on Justia Law

This appeal arose from an Industrial Commission (the Commission) order denying medical care benefits to Channel Rish. Rish worked as a cashier at Home Depot. While working on October 30, 2005, Rish slipped on a floor mat and injured her right knee. The injury ultimately required Rish to undergo three knee surgeries, which Dr. Casey Huntsman performed in 2005, 2006, and 2007. Roughly three months after Rish’s third surgery, Dr. Huntsman concluded Rish had achieved maximum medical improvement (MMI). Dr. Huntsman, however, further noted that Rish “definitely needs . . . continued pain management” with Dr. Holly Zoe. To that end, Rish visited Dr. Zoe for pain management treatment. Respondents remained skeptical as to Rish’s continued medical care with Dr. Zoe. Rish filed a worker’s compensation complaint to seek past and future disability benefits and medical care. Respondents answered and conceded Rish was entitled to the already-paid disability benefits and medical care, but Respondents disputed whether she was entitled to additional disability benefits and medical care. After a hearing, the Commission held in Respondents’ favor. The Commission noted that Rish did not timely raise the issue of disability benefits, but concluded Rish was nevertheless entitled to no additional disability benefits. Further, the Commission concluded Rish was entitled to no additional medical care benefits because the medical care Rish received after August 9, 2007 (the date when Dr. Huntsman deemed her at MMI) was unreasonable. Rish appealed. After review, the Supreme Court concluded the Commission erred in holding that the medical care Rish received after August 9, 2007 was unreasonable. As such, the Court vacated the Commission’s denial of medical care benefits and remanded for further proceedings. View "Rish v. Home Depot" on Justia Law

Claimant Gary Davis, employer Hammack Management, Inc., surety the Idaho State Insurance Fund, and the Idaho Industrial Special Indemnity Fund (“ISIF”) entered into a compensation agreement (“Stipulation”). The parties agreed that Claimant became totally and permanently disabled based on the combined effects of preexisting impairments and a workplace injury that occurred in 2004. The Stipulation outlined each party’s financial obligations to Claimant, including a credit to Employer for permanent partial impairment benefits previously paid. The Idaho Industrial Commission (“Commission”) approved the Stipulation. Subsequently, the Idaho Supreme Court issued its decision in “Corgatelli v. Steel West, Inc.,” (335 P.3d 1150 (2014)), prohibiting such a credit. Claimant then sought a declaratory ruling that the credit in the Stipulation was void. The Commission issued an order stating that the Stipulation was binding as written and subsequently denied Claimant’s motion for reconsideration. Claimant appealed. The Supreme Court concluded the credit in the Stipulation was invalid and the Commission’s order approving the Stipulation was void. The Court affirmed the Industrial Commission’s holding that it had subject matter jurisdiction over the Claimant’s petition for declaratory ruling but reversed its order upholding the Stipulation and the credit. View "Davis v. Hammack Mgmt." on Justia Law

Appellants, Consolidated Farms LLC, dba Elk Mountain Farms (“Employer”), and Indemnity Insurance Company of North America, appealed an Idaho Industrial Commission’s finding that Respondent Rodrigo Rodriguez was totally and permanently disabled under the odd-lot doctrine. In addition to his work for the Employer’s farm in irrigation, Rodriguez also helped operate and maintain the machinery used in the harvesting process. Rodriguez, who was right handed, was attempting to clear dirt and other debris from a conveyor belt using a cutting hook. As Rodriguez reached into the machine, the conveyor belt sped up, catching his arm. The machine crushed Rodriguez’s right hand and forearm, breaking numerous bones and causing extensive damage to his nerves and tendons. Following his injury, Rodriguez underwent six surgeries and extensive physical therapy in order to regain limited use of his arm. Rodriguez’s employment was seasonal. Each year he was required to sign a waiver acknowledging that his employment was “Temporary” rather than “Permanent” and that his employment would end at the conclusion of the growing season. For 21 years Rodriguez was rehired by Employer at the beginning of each season. For many of these seasons he was part of the “Core Group” of employees. Rodriguez filed a disability/medical benefits workers compensation complaint with the Idaho Industrial Commission. The Commission issued its findings of fact, conclusions of law, and order. It concluded that Rodriguez had suffered a disability of 57% whole person and was permanently disabled under the futility prong of the odd-lot doctrine. The Employer appealed. Finding no reversible error in the Commission’s decision, the Supreme Court affirmed. View "Rodriguez v. Consolidated Farms, LLC" on Justia Law

Geralyn Gallagher appealed when her lawsuit against the Best Western Cottontree Inn (the Hotel) and Snake River Peterson Properties LLC (Snake River) was dismissed. The district court held that the amended complaint did not relate back to the date of the original filing and that the statute of limitations was not tolled by Snake River’s failure to file a certificate of assumed business name. Gallagher argued that the amended complaint should relate back to the date that she filed the original complaint. Gallagher argued that because complaints can be amended at any time, and because the original complaint was filed within the statute of limitations, the amended complaint related back to that time. The district court found that because Gallagher was amending her complaint to name a new defendant, Idaho Rule of Civil Procedure 15(c) applied. Snake River did not have notice of the suit within the statute of limitations, the district court held that the amended complaint could not relate back. The Supreme Court concluded the district court’s conclusion was correct. Gallagher also argued the statute of limitations should have been tolled because Snake River failed to file a certificate of assumed business name with the Secretary of State. The district court found that because Gallagher’s only search was of the Secretary of State’s database, Gallagher did not exercise reasonable diligence in ascertaining the proper party. The district court therefore declined to toll the statute of limitations. Although the Supreme Court found that the district court correctly dismissed Gallagher’s personal injury action due to the expiration of the statute of limitations, the Court remanded this case in order to give the district court the opportunity to entertain a motion to amend the complaint to assert a cause of action against Snake River under Idaho Code section 53-509(2). View "Gallagher v. Best Wester Cottontree" on Justia Law