Justia Idaho Supreme Court Opinion Summaries

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

Washington resident and appellant Douglas Meyer appealed his felony conviction for possession of over three ounces of marijuana. Meyer argued the district court erred when it denied his request for a jury instruction on the necessity defense. Meyer had a prescription for medical marijuana and was the designated medical marijuana provider for Tammy Rose. He was arrested while driving through Idaho on his way to California with over three ounces of marijuana in his vehicle. He argued that the district court was required to provide a necessity defense jury instruction because he had made a prima facie showing of each of the elements of that defense. The Supreme Court concluded that the district court erred in its reasoning for the denial, but not in its conclusion. “Without a prima facie showing that Meyer did not have any legal alternative to manage his pain for a short period of time, including through the procurement of medications which [were] legal in the State of Idaho, Meyer cannot show that the district court erred in refusing to instruct the jury as to necessity.” View "Idaho v. Meyer" on Justia Law

In 2015, the Plaintiffs filed this action seeking to quiet title in a strip of land that was 34.56 feet wide and 314.70 feet long. They alleged that they had satisfied the requirements for acquiring title to the property by adverse possession, which were set forth in Idaho Code section 5-210. At the time that the Plaintiffs went into possession of the strip of property, the required time for occupying adversely possessed property was five years. In 2006, an amendment to Idaho Code section 5-210 increased the statutory time period for adverse possession to twenty years. When that amendment became effective, the Plaintiffs had possessed the strip of land for four years and eight months. Guild Mortgage Company held a promissory note that was secured by a deed of trust in the strip of land; Mortgage Electronic Systems, Inc., was the trustee on the deed of trust; and Terry Lankford was the owner of the strip of land (collectively, Defendants). Defendants moved to dismiss the complaint on the ground that the 2006 amendment to Idaho Code section 5-210 applied, so the Plaintiffs had not possessed the property for the required statutory period. The district court agreed, and entered a judgment dismissing the complaint. Plaintiffs timely appealed. Finding no reversible error in the district court's dismissal, the Supreme Court affirmed. View "Schoorl v. Guild Mortgage Co" on Justia Law

Defendant-appellant Laura Smith appealed her conviction for aiding and abetting the delivery of psilocybin mushrooms to an undercover detective. She contended the district court erred in overruling an objection to an out-of-court statement made by the person from whom they purchased the mushrooms about his supplier on the grounds that it was hearsay and violated the Defendant’s right to cross-examine the declarant. Defendant also challenged the sufficiency of the evidence to sustain the conviction. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Smith" on Justia Law

North Idaho Resorts (NIR) appealed the district court’s grant of summary judgment in favor of Union Bank, N.A. (Union Bank) in a mortgage priority dispute. The district court held that NIR did not possess a vendor’s lien because NIR was not the owner of record and that any lien NIR might have possessed had no value. The district court further held that if NIR possessed a valid lien, NIR released any such lien as part of a recorded agreement and that Union Bank was a good faith encumbrancer with no actual or constructive knowledge of the lien. On appeal, NIR argued: (1) the district court misconstrued Idaho Code section 45-801 and that the statute did not require the seller to be the owner of record; (2) the remaining conditional purchase price constituted an unpaid and unsecured value; (3) Union Bank knew NIR was still owed money under the contract; and (4) Union Bank did not qualify as a good faith encumbrancer. Finding no reversible error, the Supreme Court affirmed the district court’s judgment. View "Union Bank, N.A. v. North Idaho Resorts" on Justia Law

JV, LLC (JV) appealed the district court’s grant of summary judgment in favor of Union Bank, N.A. (Union Bank) in a mortgage priority dispute. Union Bank sought to foreclose a mortgage on a property known as “Trestle Creek.” JV claimed priority to the Trestle Creek property through a mortgage recorded June 19, 2006. Union Bank’s mortgage was recorded March 25, 2008. Union Bank moved for summary judgment, arguing that JV had subordinated its lien to that of Union Bank. The district court agreed and granted the motion. Finding no reversible error, the Supreme Court affirmed the district court’s judgment. View "Union Bank, N.A. v. JV L.L.C" on Justia Law

Appellant Michael Molen appealed the district court’s summary judgment dismissal of his legal malpractice action. The malpractice action stems from respondent Ronald Christian’s representation of Molen in a criminal case. The crux of this appeal was whether the statute of limitations on Molen’s malpractice cause of action accrued upon Molen’s initial criminal conviction or when Molen was later exonerated. After review, the Supreme Court held: (1) the statute of limitations for a legal malpractice action does not begin to run until the plaintiff has been exonerated of the underlying criminal conviction; and (2) actual innocence is not an element of a criminal malpractice cause of action. The Court vacated the district court’s summary judgment order and remanded the case for further proceedings. View "Molen v. Christian" on Justia Law

Eric and Kathryn Bowen purchased property in Caldwell through a tax deed sale conducted by the Caldwell Irrigation Lateral District (CILD). G. Lance Salladay brought suit arguing that the sale was void because the property was part of the Estate of Roger Troutner (the Estate), and Salladay, as personal representative of the Estate, was entitled to notice of the sale and never received such notice. The district court ruled that Salladay was entitled to notice and since he had not received notice of the sale there was no final decision regarding issuance of the deed as required by Idaho Code section 43-719(2). The district court then remanded the case to CILD. On appeal, Bowens argued the district court erred in its determination that Salladay was entitled to notice and that even if Salladay was entitled to notice, his petition to the district court was untimely. The Supreme Court found that the district court erred in remanding the case back to CILD. The Court concluded CILD failed to provide written notice to the record owner of the property, so the tax deed was void ab initio. View "Salladay v. Bowen" on Justia Law

Dwight Randy Green, Kathy Lefor, and Gary Green (collectively, “Siblings”), appealed the district court’s grant of summary judgment and dismissal of their lawsuit against James Green (“James”). Siblings brought this action to challenge the Sixth Amendment to the Ralph Maurice and Jeanne Green Revocable Inter Vivos Trust (“the Trust”), alleging it was the product of undue influence. The Trust was amended from an equal distribution between all of Ralph and Jeanne Green’s children to a 100% distribution to James to the exclusion of the Siblings. The district court granted summary judgment after determining that Siblings had failed to show a genuine issue of material fact which would support a finding of undue influence. Finding no reversible error in the district court’s judgment, the Supreme Court affirmed. View "Green v. Green" on Justia Law