Justia Idaho Supreme Court Opinion Summaries

This consolidated appeal arose from personal injuries Adrian Carillo Alcala (“Carillo”) suffered at a potato packaging plant, SunRiver of Idaho, Inc. (“SunRiver”), after his head and shoulders were crushed by a box palletizer designed, manufactured, delivered, and installed by a Dutch company, Verbruggen Emmeloord, B.V. (“VE”), along with its United States affiliate, Verbruggen Palletizing Solutions, Inc. (“VPS”). The box palletizer was one of seven machines SunRiver purchased in a transaction with Volm Companies, Inc. (“Volm”). Because this was a workplace injury, Carillo received worker’s compensation benefits through his employers, SunRiver, Employers Resource Management Company, and Employers Resource of America, Inc.—and the surety American Zurich Insurance Company (collectively “the SunRiver Plaintiffs”). Afterwards, the SunRiver Plaintiffs jointly with, and in the name of Carillo, sued Volm, VE, and VPS. Pursuant to a stipulation and compromise agreement, Volm was dismissed from this suit before this appeal. The district court granted summary judgment to Respondents and dismissed all claims after concluding that VE and VPS were Carillo’s statutory co-employees immune from common law liability under Richardson v. Z & H Construction, LLC, 470 P.3d 1154 (2020). On appeal, the SunRiver Plaintiffs and Carillo argued that the transaction between SunRiver and Volm did not make Carillo, VE, and VPS statutory co-employees because it was a “hybrid” transaction consisting of goods with incidental services under Kelly v. TRC Fabrication, LLC, 487 P.3d 723 (2021). VE and VPS cross-appealed the district court’s denial of attorney fees under Idaho Code section 12-120(3). The Idaho Supreme Court agreed with the SunRiver Plaintiffs and Carillo. VE and VPS were “third parties” and were not entitled to immunity from suit in tort under the Worker’s Compensation law. The district court’s judgment dismissing all claims was vacated, the grant of summary judgment to VE and VPS was reversed, and this case was remanded for further proceedings. The Supreme Court also rejected VE’s and VPS’s argument that the SunRiver Plaintiffs’ subrogation interest was barred at summary judgment. The Court found evidence in the record sufficient to create a disputed issue of material fact over whether the SunRiver Plaintiffs had any comparative fault for Carillo’s accident. As for the cross-appeal, the Court vacated the district court’s decision denying attorney fees under section 12-120(3) below because there was not yet a prevailing party. View "Alcala v. Verbruggen Palletizing Solutions, Inc." on Justia Law

The issue presented for review by the Idaho Supreme Court stemmed from an “unfortunate kitchen accident.” Mary Clare Griffin purchased a bottle of Italian wine, which broke in her hands as she attempted to open it, causing substantial injuries. Griffin and her son, a minor who witnessed the event, brought a product liability suit against Zignago Vetro S.P.A., the Italian manufacturer of the wine bottle; Marchesi Antinori SRL (Antinori), the Italian wine company that purchased the bottle from Zignago, filled it with wine, and exported it to the United States; Chateau Ste. Michelle Wine Estates, Ltd. (Ste. Michelle), the United States importer; S & C Importers and Distributors, Inc. (S&C), the Idaho distributor who purchased the bottle from Ste. Michelle; and, Albertson’s LLC (Albertson’s), the retailer that sold the bottle to Griffin. Zignago successfully moved the district court to dismiss Griffin’s complaint based on a lack of personal jurisdiction. Griffin appealed the district court’s decision, asking the Supreme Court to apply the personal jurisdiction framework established by the United States Supreme Court in World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980). Zignago claimed the district court did not err by applying the stricter test that the United States Supreme Court offered in Asahi Metal Indus. Co. v. Superior Court of California, Solano Cnty., 480 U.S. 102 (1987) (plurality). Griffin also appealed several adverse discovery rulings. The Supreme Court held that the correct test when determining personal jurisdictional issues remains the “stream of commerce” test adopted by the United States Supreme Court in World-Wide Volkswagen. Applying that test to the case here, the Court reversed the district court’s decision to grant Zignago’s motion to dismiss for lack of personal jurisdiction and remand the case for further proceedings. Furthermore, the Court affirmed the district court’s decision granting Antinori’s and Ste. Michelle’s motions for summary judgment and hold that it did not abuse its discretion in failing to grant Griffin’s motion to compel discovery against Antinori and Ste. Michelle. View "Griffin v. Ste. Michelle Wine Estates LTD." on Justia Law

Linda Black sustained second-degree burns on her back while undergoing electrotherapeutic treatment at Superior Physical Therapy (“SPT”). Black’s treatment was performed by Bart McDonald, a licensed physical therapist and the sole owner of SPT. Black brought a product liability claim against the manufacturer and seller of the self- adhesive carbon electrode pads used during her treatment. The manufacturer moved for summary judgment on the grounds that Black was unable to prove that the electrode pads were defective or that the injuries Black sustained were proximately caused by its negligence. The district court ruled that: (1) McDonald’s conclusory statements that the electrode pads were defective were inadmissible because he was not a qualified expert; (2) the doctrine of res ipsa loquitur did not apply to Black’s case; and (3) Black’s prima facie case failed because there was evidence of abnormal use of the electrode pads and other reasonable secondary causes that could have contributed to Black’s injury. The district court granted summary judgment in favor of the manufacturer. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s decision. View "Black v. DJO Global" on Justia Law

Mary Clare Griffin purchased a bottle of Italian wine, which broke in her hands as she attempted to open it, causing substantial injuries. Griffin and her son, a minor who witnessed the event, brought a product liability suit against Zignago Vetro S.P.A. (Zignago), the Italian manufacturer of the wine bottle; Marchesi Antinori SRL (Antinori), the Italian wine company that purchased the bottle from Zignago, filled it with wine, and exported it to the United States; Chateau Ste. Michelle Wine Estates, Ltd. (Ste. Michelle), the United States importer; S & C Importers and Distributors, Inc. (S&C), the Idaho distributor who purchased the bottle from Ste. Michelle; and, Albertson’s LLC (Albertson’s), the retailer that sold the bottle to Griffin. Zignago successfully moved the district court to dismiss Griffin’s complaint based on a lack of personal jurisdiction. Griffin appealed the district court’s decision, asking the Court of Appeal to apply the personal jurisdiction framework established by World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980). Griffin also appealed the district court’s order granting summary judgment to Antinori and Ste. Michelle on the grounds that Griffin failed to meet her burden to show a prima facie case for a product liability claim. Additionally, Griffin appealed several adverse discovery rulings. The Idaho Supreme Court found the correct test when determining personal jurisdictional issues remained the “stream of commerce” test adopted by the United States Supreme Court in World-Wide Volkswagen. Applying that test to the case here, the Court reversed the district court’s decision to grant Zignago’s motion to dismiss for lack of personal jurisdiction and remanded the case for further proceedings. The Court affirmed the district court’s decision granting Antinori’s and Ste. Michelle’s motions for summary judgment, finding it did not abuse its discretion in failing to grant Griffin’s motion to compel discovery against Antinori and Ste. Michelle. View "Griffin v. Ste. Michelle Wine Estates LTD." on Justia Law

Francisca Gomez died as the result of a horrific industrial accident that occurred while she was cleaning a seed sorting machine as part of her employment with the Crookham Company (“Crookham”). Her family (the Gomezes) received worker’s compensation benefits and also brought a wrongful death action. The Gomezes appealed a district court’s grant of summary judgment to Crookham on all claims relating to Mrs. Gomez’s death. The district court held that Mrs. Gomez was working within the scope of her employment at the time of the accident, that all of the Gomezes’ claims were barred by the exclusive remedy rule of Idaho worker’s compensation law, that the exception to the exclusive remedy rule provided by Idaho Code section 72-209(3) did not apply, and that the Gomezes’ product liability claims fail as a matter of law because Crookham is not a “manufacturer.” The Idaho Supreme Court determined that given the totality of the evidence in this case, which included prior OSHA violations for similar safety issues, the district court erred by failing to consider whether Crookham consciously disregarded information suggesting a significant risk to its employees working at or under the picking tables, which were neither locked nor tagged out, as they existed on the date of the accident. On this basis, the decision of the district court granting summary judgment to Crookham was reversed and the matter remanded for the trial court to apply the proper standard for proving an act of unprovoked physical aggression, and to determine whether there was a genuine issue of material fact as to whether Crookham consciously disregarded knowledge of a serious risk to Mrs. Gomez. View "Gomez v. Crookham" on Justia Law

Francisca Gomez died as the result of a horrific industrial accident while she was cleaning a seed sorting machine as part of her employment with the Crookham Company (“Crookham”). Her family (the Gomezes) received worker’s compensation benefits and also brought a wrongful death action. The Gomezes appealed the district court's decision to grant Crookham’s motion for summary judgment on all claims relating to Mrs. Gomez’s death. The district court held that Mrs. Gomez was working within the scope of her employment at the time of the accident, that all of the Gomezes’ claims were barred by the exclusive remedy rule of Idaho worker’s compensation law, that the exception to the exclusive remedy rule provided by Idaho Code section 72-209(3) did not apply, and that the Gomezes’ product liability claims failed as a matter of law because Crookham was not a “manufacturer.” In affirming in part and reversing in part, the Idaho Supreme Court determined the trial court erred when it failed to consider whether Crookham committed an act of unprovoked physical aggression upon Mrs. Gomez by consciously disregarding knowledge that an injury would result. As such, the matter was remanded to the district court for further proceedings. View "Gomez v. Crookham" on Justia Law

The family of Mrs. Francisca Gomez (the Gomezes) appealed a district court decision granting Crookham Company’s (Crookham) motion for summary judgment on all claims relating to Mrs. Gomez’s death. Crookham is a wholesale seed distributor located in Caldwell, Idaho. Mrs. Gomez was an employee of Crookham for more than thirty years before her death. In early 2015, Crookham decided that a new picking table was necessary to sort seeds more efficiently. A Crookham employee fabricated the new table and it was installed in the company’s “Scancore” room in late 2015. Although OSHA had previously cited Crookham for violating machine guard safety standards and lockout-tagout protocol with its former picking tables, the new picking table’s drive shaft was not fully guarded and Crookham did not perform the required lockout-tagout procedures while employees cleaned the table. While working in the Scanscore room, Mrs. Gomez was under the picking table attempting to clean it when the table’s exposed drive shaft caught her hair and pulled her into the machine. She died as a result of her injuries. OSHA subsequently investigated Crookham and issued “serious” violations to the company because it exposed its employees to the unguarded drive shaft without implementing lockout-tagout procedures. The district court held that Mrs. Gomez was working in the scope of her employment at the time of the accident, that all of the Gomezes’ claims were barred by the exclusive remedy rule of Idaho worker’s compensation law, that the exception to the exclusive remedy rule provided by Idaho Code section 72-209(3) did not apply, and that the Gomezes’ product liability claims fail as a matter of law because Crookham is not a “manufacturer.” Finding no reversible error in the district court's judgment, the Idaho Supreme Court affirmed. View "Gomez v. Crookham" on Justia Law

In early June of 2007, Karrin Massey consumed at least one, but perhaps several, poultry pot pies that were manufactured by ConAgra Food, Inc. and sold under the Banquet brand name. Soon after, Karrin, who was six months pregnant at the time, developed salmonellosis. After an outbreak of salmonella was linked to Banquet pot pies, it was discovered that Karrin's strain of salmonella matched the strain of salmonella found in the contaminated pot pies. Karrin, her husband, Mark Massey, and their daughter Emma filed suit against ConAgra, alleging claims of product liability, negligence, and breach of warranty. The district court eventually granted ConAgra's motion for summary judgment on the grounds that the Masseys had failed to establish the pot pies in question were defective. The Masseys filed a motion for reconsideration, which was denied. The Masseys then appealed to the Supreme Court. Upon review of the trial court record, the Supreme Court concluded the district court erred: (1) in determining that the Masseys failed to establish a genuine issue of material fact that the pot pies were defective; (2) in granting summary judgment on the issue of negligence; (3) in concluding the Masseys waived their right to challenge the district court's denial of their motion to reconsider; and (4) in finding that the Masseys' failure to warn claim was not adequately pleaded. The Court vacated the judgment and remanded the case for further proceedings. View "Massey v. Conagra Foods" on Justia Law

Plaintiff-Appellant Billie Jo Major sued Security Equipment Corporation (SEC) alleging that the company failed to provide adequate warning to her employer, the Idaho Department of Corrections (IDOC), on the risks of its oleoresin capsicum pepper spray. Plaintiff alleged that the use of the spray in a training exercise worsened existing bronchial difficulties and caused her permanent injury. The district court granted partial summary judgment to SEC on the grounds that plaintiff failed to create a material issue of fact on whether her injuries were a known or foreseeable risk prior to March 2008 (the date of sale to IDOC). In a motion to reconsider, plaintiff submitted a second affidavit from her expert which was declared a sham affidavit by the district court in its denial of the motion. The district court later granted summary judgment to SEC on the sole remaining issue, the viability of plaintiff's claim under the Federal Hazardous Substances Act (FHSA). Upon review, the Supreme Court disagreed with the district court, vacated its judgment, and remanded the case for further proceedings. View "Major v. Security Eq Corp" on Justia Law

This appeal arose from a products liability action brought by Jesus Hurtado and John Reitsma, d/b/a J & J Calf Ranch (J & J), against Land O'Lakes, Inc. (Land O'Lakes). J & J alleged that the Land O'Lakes milk replacer it used to feed its dairy calves was defective and caused the death of more than one hundred calves. A jury found in favor of J & J and awarded damages. Land O'Lakes appealed, arguing that the district court improperly admitted expert testimony and that J & J failed to prove both liability and damages. Land O'Lakes petitioned the Supreme Court to vacate the judgment of the district court and enter judgment in its favor or, alternatively, to vacate the judgment and order a new trial. J & J cross-appealed the district court's award of attorney fees, arguing that the court abused its discretion by excluding fees incurred before and during previous litigation in this matter. J & J petitioned the Supreme Court to vacate the award of attorney fees and remand with instructions to include attorney fees accrued in the first trial in its calculation of reasonable attorney fees. Upon review, the Supreme Court affirmed, holding that Land O'Lakes waived issues regarding expert testimony. The Court affirmed the jury verdict because it was supported by substantial competent evidence and affirmed the district court's award of attorney fees because it properly exercised its discretion. View "Jesus Hurtado v. Land O' Lakes, Inc." on Justia Law