Justia Idaho Supreme Court Opinion Summaries

This appeal arose out of an agent contract dispute between Bret Kunz (“Bret”) and Nield, Inc. (“N.I.”) authorizing Bret to sell insurance on behalf of N.I. N.I. is owned by two brothers, Bryan Nield (“Bryan”) and Benjamin Nield. A dispute arose concerning the method and type of compensation available to Bret under the Contract. Bret filed a complaint seeking, inter alia, a declaratory judgment interpreting the Contract. The district court held the 2009 Contract did not provide for profit sharing as Bret claimed. Bret and his wife, Marti, (collectively, the “Kunzes”) appealed. Finding no reversible errors with respect to how the district court interpreted the Contract, the Idaho Supreme Court affirmed. View "Kunz v. Nield, Inc." on Justia Law

Claimant-appellant Penny Weymiller, a former employee of Lockheed Idaho Technologies (“Lockheed”), appealed the Idaho Industrial Commission’s order that she was not entitled to additional medical care in relation to her bilateral carpal tunnel syndrome (“CTS”). The Idaho Supreme Court determined the Commission erred in holding that Weymiller failed to prove her entitlement to additional care because the Court determined the decision was not supported by substantial and competent evidence. “[T]he Commission’s failure to consider palliative care in the form of wrist braces as treatment is contrary to our holding in Rish [v. Home Depot, Inc., 390 P.3d 428 (2017)]. The Commission misapplied the law and there was sufficient uncontradicted evidence to support Weymiller’s claim for replacement braces.” View "Weymiller v. Lockheed Idaho Technologies" on Justia Law

Chandler’s-Boise, LLC (“Chandlers”), challenges a district court’s grant of summary judgment upholding the Idaho State Tax Commission’s (the “Commission”) deficiency determination. Chandlers owned and operated a restaurant in downtown Boise, Idaho. The Commission, through its Sales, Use, and Miscellaneous Tax Audit Bureau (the “Bureau”), conducted a comprehensive sales audit of Chandlers for the period of May 1, 2007, through May 31, 2010 (the “Audit Period”), to determine sales tax law compliance. After its audit, the Bureau found errors in sales, fixed asset additions, ordinary purchases, and meals given to employees and guests. The only error relevant to this appeal was Chandlers’ failure to pay sales tax on automatically added gratuities that were added to banquet meals, room service meals, and restaurant dining services for groups having six or more persons (the “Charges”). The bills that Chandlers gave its customers during the Audit Period did not contain a written statement indicating that the Charges could be declined as required by the Pre-2011 Rule. Chandlers did not retain the Charges in question; rather, the employees involved in preparing or providing the meals, including the server, busser, and bartender, kept the Charges. The Bureau issued a Notice of Deficiency Determination to Chandlers wherein it determined that Chandlers owed $91,243 for sales and use tax plus penalty and interest. After review, the Idaho Supreme Court determined the district court did not err in rejecting Chandlers’ arguments with respect to non-payment of the Charges, and affirmed that court’s judgment. View "Chandlers-Boise v. Idaho Tax Commission" on Justia Law

Defendant-appellant Darol Anderson appealed his convictions for felony domestic battery and misdemeanor domestic battery. Anderson argued the district court erred when it admitted the preliminary hearing testimony of his alleged victim, Erica Messerly, after finding that she was unavailable to testify at his trial due to mental illness. Anderson also argued that the district court abused its discretion when it allowed Officer Spencer Mortensen to testify that the injuries that he had observed on Messerly’s person were consistent with her allegations against Anderson; he argued this testimony constituted impermissible vouching for Messerly’s truthfulness. Unavailability due to mental illness was an issue of first impression for the Idaho Supreme Court. The Court determined two experts’ testimony were not sufficient evidence to establish that Messerly’s mental illness made her unavailable to testify, so the district court erred when it granted the motion in limine to allow her prehearing testimony to be read at trial. The district court did not abuse its discretion, however, by admitting Officer Mortensen’s testimony. Therefore, the district court’s judgment was vacated in part and affirmed in part. View "Idaho v. Anderson" on Justia Law

The district court igranted a motion to suppress statements made by defendant-respondent Tyrell McNeely to Detective Zane Jensen after finding that the Miranda warnings given to McNeely did not adequately advise him of his rights. On appeal, the State argued the district court erred when it followed case law from the Ninth Circuit Court of Appeals requiring police to advise suspects of their right to have an attorney present during interrogation. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. McNeely" on Justia Law

Marty and Cindy Frantz executed a series of commercial guaranties so that Idaho Independent Bank (“Bank”) would lend money to Eagle Ridge on Twin Lakes, Inc. (“Eagle Ridge”), a closely held corporation in which the Frantzes held a majority interest. Bank filed this action against the Frantzes to recover on their commercial guaranties. The Frantzes filed an answer in which they admitted the material allegations in the complaint, but asserted affirmative defenses and counterclaims against Bank. They later amended their answer to include a third-party claim against Eagle Ridge. The Frantzes initially filed a petition under chapter 11 of the bankruptcy code the day before Mr. Frantz’s deposition was to occur; the Frantzes’ bankruptcy was converted to a liquidation case under chapter 7, and a trustee was duly appointed for the estate. Less than two weeks before the trial on Bank’s adversary proceeding in the bankruptcy case, the Frantzes filed a voluntary waiver of discharge, and the bankruptcy court approved the waiver. As a result, the bankruptcy court was deprived of jurisdiction to hear the adversary proceeding, and it dismissed it without prejudice. However, the court did award sanctions in the sum of $49,477.46 against the Frantzes and their attorney, jointly and severally, for their conduct during the course of the adversary proceeding. The court found that their conduct constituted misuse of litigation tactics to cause economic injury to an opponent and its counsel in the form of increased litigation costs. Bank filed a notice in this case that because of the waiver of discharge, the automatic stay from the bankruptcy court was terminated. Bank then moved for summary judgment. The district court entered a judgment against the Frantzes “in the amount of $9,193,546.50, plus pre-judgment interest at the rate of $2,475.02 per diem from September 16, 2015, until the date this Judgment is entered.” Because the Frantzes' third-party claim against Eagle Ridge that was yet unresolved, the court certified the judgment as final pursuant to Rule 54(b) of the Idaho Rules of Civil Procedure. The Frantzes filed a motion for reconsideration, and the court denied that motion. They then timely appealed, arguing the district court erred in denying them affirmative defenses based upon an alleged breach of contract. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho Independent Bank v. Frantz" on Justia Law

Mark Henry Lankford (Lankford) appealed after he was convicted by jury on two counts of felony murder. Lankford and his brother, Bryan Lankford (Bryan), were both convicted and sentenced to death for the 1983 murders of Robert and Cheryl Bravence, who were brutally murdered while camping in the Sheep Creek area of Idaho County. Lankford argued that the district court erred in multiple ways and that he is entitled to a new trial. The State argued Lankford failed to prove that reversible error was committed by the district court and that Lankford’s convictions should be affirmed. After review, the Idaho Supreme Court found that a witness' false testimony about his motive for testifying could have influenced the judgment of the jury. Furthermore, the Court found that the prosecutor's failure to disclose the full details of the agreement for the witness to testify undermined "[its] confidence in the outcome of the trial such that we cannot be sure the defendant 'received a fair trial, understood as a trial resulting in a verdict worthy of confidence.'" Therefore, the Court held Lankford's right to a fair trial was violated and he was entitled to a new one. View "Idaho v. Lankford" on Justia Law

Appellants Ronald and Margaret Swafford challenged a district court’s grant of summary judgment in favor of Respondent Huntsman Springs, Inc. The action stemmed from the Swaffords’ claim that Huntsman Springs essentially cut off their property from the development by building a park and planting trees between their lot and the nearby street and development, and in doing so: (1) breached a contract; (2) breached an express warranty; (3) breached their duty of good faith and fair dealing; (4) violated the Idaho Consumer Protection Act; and (5) made false representations. The district court granted summary judgment in favor of Huntsman Springs after concluding that all of the Swaffords’ claims were barred by the applicable statutes of limitation. The crux of the Swaffords’ action is that Huntsman Springs breached the Contract by failing to develop the surrounding area in conformance with the Master Plan of the development, i.e., by constructing the park that separated their property from the rest of the development. The Idaho Supreme Court determined the Master Plan was not incorporated or referenced by the Swaffords' Contract; therefore, it did not contractually obligate Huntsman Springs. Accordingly, the Court affirmed the district court's judgment in favor of Huntsman Springs. View "Swafford v. Huntsman Springs" on Justia Law

Mark Lankford and his brother Bryan were both convicted and sentenced to death for the 1983 murders of Robert and Cheryl Bravence, who were brutally murdered while camping in the Sheep Creek area of Idaho County. Lankford (Lankford) appealed his judgment of conviction, arguing the district court erred in multiple ways and that he was entitled to a new trial. The State argued that Lankford failed to prove that reversible error was committed by the district court and that Lankford’s convictions should have been affirmed. After careful consideration of the evidence presented at trial, the Idaho Supreme Court concluded Lankford was entitled to a new trial based on a finding of prosecutorial misconduct: the prosecutor's failure to disclose the full details of an agreement with a key corroborating witness' testimony “'undermines our confidence in the outcome of the trial,' such that we cannot be sure the defendant 'received a fair trial, understood as a trial resulting in a verdict worthy of confidence.'” View "Idaho v. Lankford" on Justia Law

Ashley Palmer (Palmer) and Stephen Palmer appealed a district court’s order granting Lisa Ellefson’s motion for a new trial under Idaho Rule of Civil Procedure 59(a)(6). Ellefson was involved in an automobile accident caused by Palmer. A jury found that Ellefson was not injured in the accident. However, the district court determined that the jury verdict of “no injury” was against the clear weight of evidence and granted a new trial subject to an additur in the amount of $50,000. On appeal, Palmer argued that the district court abused its discretion in granting the new trial and in setting additur at $50,000. Finding no such error, the Idaho Supreme Court affirmed. View "Ellefson v. Palmer" on Justia Law