Justia Idaho Supreme Court Opinion Summaries

Danielle Quemada, the daughter and personal representative of Richard Ortega (Decedent), initiated this action to set aside two quitclaim deeds. At the time of the Decedent's death, he had three children: Richard Ortega, Jr., Denise Mota, and Quemada. On January 12, 2012, Respondents, Efren Arizmendez and Gilbert Acosta filed a petition to adjudicate the intestacy of the Decedent and to be appointed as the personal representative of the Decedent's estate. The proceeding was assigned to the magistrate court. Thereafter, Quemada filed a petition for appointment as personal representative, which was granted. On April 20, 2010, Quemada filed a verified Petition, invoking the Trust and Estate Dispute Resolution Act (TEDRA) to set aside two of the deeds. She alleged that the deeds to the properties should have been set aside because the Decedent signed them based on Celia Ortega's fraudulent misrepresentations, undue influence, and design to intentionally interfere with inheritance. During a telephonic status conference, the district court granted Quemada leave to file an amended petition narrowing the issues in dispute, and the parties stipulated to waive a jury trial. Quemada filed an unverified Amended Petition which was identical to the original Petition, except that it left out the intentional interference with inheritance cause of action. The district court ruled in response to a Rule 12(b) motion of Respondents that Quemada could not pursue a claim for damages, nor any claim against Celia Ortega, having failed to allege either in the Amended Petition. The Respondents answered the Amended Petition and shortly thereafter moved for summary judgment. Subsequent to the hearing on the motion to dismiss, the district court issued its Memorandum Decision, finding that no genuine issues of material fact existed, and that Respondents were entitled to judgment as a matter of law. Quemada appealed to the Supreme Court. Finding no error, the Supreme Court affirmed. View "Quemada v. Arizmendez" on Justia Law

This appeal came before the Supreme Court from a declaratory judgment action brought by Farm Bureau Mutual Insurance Company of Idaho (Farm Bureau). Farm Bureau brought suit in response to a claim for insurance benefits filed by the personal representatives of the estate of a deceased policyholder (the Estate). Farm Bureau requested a judgment declaring that the Estate was not an "insured" under the decedent's insurance policy and was therefore not entitled to payment of wrongful death damages under the Policy's underinsured motorist coverage. The district court granted the Estate's motion for summary judgment, determining that Idaho's wrongful death statute, entitled the insured's Estate to recover damages for wrongful death and that the Policy provided coverage for those damages. Farm Bureau appealed. Upon review, the Supreme Court reversed: as to the Estate, the Court determined that under the plain language of the wrongful death statute, the Estate was not legally entitled to recover damages for itself, but only to bring an action on behalf of the heirs to recover their damages. "The Estate stepped into [the decedent's] shoes for those claims, and Farm Bureau made those payments to the Estate. Farm Bureau's payment of these legitimate claims under the insurance contract does not constitute a change of position or an admission that coverage exists for other claims. We hold that these payments do not prevent Farm Bureau from arguing that it is not required to pay the Estate for damages that [the decedent] was not legally entitled to recover." View "Farm Bureau v. Estate of Eisenman" on Justia Law

This appeal arose from a claim filed by the Idaho Department of Health and Welfare in the probate proceeding of George D. Perry, the deceased spouse of Medicaid recipient Martha J. Perry. The Department sought to recover funds under I.C. 56-218 from the sale of the couple’s home (their only significant asset) to recoup Medicaid benefits paid to Martha during her lifetime. The magistrate court disallowed the Department’s claim for recovery, finding that Martha had no interest in the real property because George, acting for Martha under a power of attorney, conveyed the property to himself before his death. That decision was upheld on appeal to the district court. The Department appealed to the Supreme Court. Upon review, the Court found that the district court erred in finding that federal law preempted the Department's ability to recover from George's estate what was once Martha's community property during the marriage. The Court reversed the district court and remanded the case for further proceedings. View "Id. Dept. of Health & Welfare v. McCormick" on Justia Law

This appeal arose from a dispute regarding the requirements for determining whether a claimed amount of attorney fees was reasonable. After extended litigation to settle his parents’ estate, Kim Bailey, the estate’s personal representative, asked the magistrate court for an award of attorney fees from estate funds. The magistrate court found that Bailey was entitled to reasonable fees to be determined under I.R.C.P. 54(e)(3) and ordered Bailey to provide an accounting of his attorney fees, including the time his attorney spent providing legal services. Bailey’s attorney notified the court that he was unable to comply with the order, explaining that he did not keep time records because the attorney-client contract expressly stated that the fee would not be based upon an hourly rate, but upon the attorney’s opinion of the reasonable worth of his services. The beneficiaries of the estate challenged the sufficiency of the accounting. The magistrate court denied Bailey’s request for fees and concluded that without time records it could not determine a reasonable fee amount in compliance with I.R.C.P. 54(e)(3)(A). The district court upheld the denial of fees, and Bailey timely appealed. Upon review, the Supreme Court agreed with the district court and affirmed. View "Bailey v. Bailey" on Justia Law

On remand, the district court granted Wayne Dawson's Motion for Relief from Judgment and issued its Second Amended Judgment, which in part quieted title to and in part took judicial notice of four undivided one-fourth interests in a forty-acre parcel of land located in Teton County. On appeal, John Bach contended, among other things, that Dawson lacked standing to file his Motion for Relief from Judgment and that the district court abused its discretion and lacked personal and subject matter jurisdiction when it granted the Motion for Relief from Judgment and entered the Second Amended Judgment. Because all of Bach's claims were either frivolous or waived, the Supreme Court affirmed the Second Amended Judgment. View "McLean v. Cheyovich Family Trust" on Justia Law

This case concerned an appeal of a magistrate court's Finding of Fact, Conclusions of Law and Order in denying Appellant Maureen Erickson's Motion for Partial Distribution of her mother's estate. The magistrate court found that the property Maureen sought to partially distribute was not part of the assets of her mother's estate. On appeal to the district court, the court affirmed the decision of the magistrate court and alternatively found that the matter was barred by the statute of limitations. Upon review, the Supreme Court affirmed the district court's decision that this case was barred by the statute of limitations. View "Erickson v. McKee" on Justia Law

This case concerned the ownership status of Coolwater Ridge Road in Idaho County. The predecessors in interest of appellant Paddison Scenic Properties, Family Trust, L.C. granted rights of way to the United States for a road which became Coolwater Ridge Road. In the district court, Paddison sought a declaratory judgment that the rights of way did not constitute a public road or highway under Idaho law. That court held that the rights of way were public because the criteria for common law dedication were met. Upon review, the Idaho Supreme Court vacated the district court's judgment because it concluded this case was not ripe for adjudication. View "Paddison Scenic Properties Family Trust v. Idaho County" on Justia Law

The issue before the Supreme Court in this was the denial of attorney fees under Idaho Code section 41-1839 on the ground that the insured's proof of loss was insufficient under the statute because it did not provide the insurer with the legal theory upon which coverage was later determined to exist. Upon review of the matter, the Supreme Court vacated the judgment because a proof of loss need not include an analysis of the proper theory of coverage under the insurance policy. View "Estate of Benjamin Holland v. Metropolitan Property & Casualty Ins." on Justia Law

This case was the third appeal to the Supreme Court arising from a 2002 real estate transaction between Thomas and Colleen Birch-Maile and the Theodore L. Johnson Revocable Trust. Attorney and Real Estate Broker Thomas Maile advised the Trust to reject an offer to sell certain trust property. Months later, Mr. Maile submitted an earnest money agreement for the same property. The prospective buyers, collectively the Taylors, sued the Mailes and Berkshire Investments, LLC (the company that the Mailes formed and to whom they assigned rights to the property) for professional malpractice and breach of fiduciary duties. The Mailes filed suit seeking to set aside a 2006 judgment against them, which the Court affirmed in the second appeal. The district court determined on summary judgment that the 2006 judgment was res judicata with regard to the issues raised in the Mailes' complaint. At trial the jury awarded damages against the Mailes on the Taylors' counterclaim. The Mailes appealed and the Supreme Court affirmed: the district court was correct in summarily dismissing the Mailes' lawsuit and denying their motion for JNOV. Further, the district court did not abuse its discretion in awarding attorney to two of the prospective buyers. View "Berkshire Investments, LLC v. Taylor" on Justia Law

Washington Trust Bank (WTB) was the trustee of the trust created by Althea Bowman's last will and testament. Althea's four surviving children were the trust beneficiaries. Three of these beneficiaries argued to the district court that the Trustee exceeded its authority by encumbering a commercial property held by the trust with a deed of trust, and advancing funds to a fourth beneficiary. In that transaction, separate divisions of WTB acted as trustee (Trustee) and as the beneficiary of the deed of trust. The district court granted summary judgment in favor of the Trustee. Two of the beneficiaries appealed. Upon review, the Supreme Court affirmed the district court's order of dismissal because the Court concluded the Bowmans lacked standing and they asserted claims that were not ripe. View "Blankenship v. Washington Trust Bank" on Justia Law