Justia Idaho Supreme Court Opinion Summaries

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

In 2014, Thomas Kralovec was arrested by Boise City Officer Tad Miller for public intoxication and resisting and obstructing arrest. While he was being transported to jail, Kralovec was antagonistic. He cursed, insulted, and threatened Officer Miller. Upon arrival at the jail, Kralovec was met by four deputies. Kralovec remained combative and non-compliant during the intake process. The four deputies took turns restraining Kralovec to search him and remove his handcuffs so that he could be left alone in the cell. The deputies placed Kralovec on a concrete bench in the cell in a prone position with his legs in a “figure four leg trap” with his face to the wall. At some point during the search, Kralovec’s right leg came free and kicked out, knocking a microphone loose from the clip on one deputy’s shirt and allegedly striking another in the shoulder. The incident was recorded by a camera in the holding cell. The State filed an information charging Kralovec with one count of battery on a peace officer, later amending it to charge Kralovec with battery on a correctional officer. State filed notice of its intent to introduce audio evidence of Kralovec’s arrest and transport to jail to show Kralovec’s knowledge and intent pursuant to Idaho Rule of Evidence 404(b). Kralovec objected, arguing that the evidence was either not relevant, or its probative value was substantially outweighed by its prejudicial effect. The district court concluded that the evidence was res gestae evidence temporally connected with the alleged battery and had a tendency to explain Kralovec’s alleged misbehavior during the booking process. The district court further concluded that the evidence was admissible under Idaho Rule of Evidence 404(b) as it was relevant to Kralovec’s intent. Kralovec was ultimately convicted on one count of battery on a correctional officer. On appeal, Kralovec argued: (1) the State failed to present constitutionally sufficient evidence upon which a reasonable trier of fact could have found that the State sustained its burden of proving the essential elements of the crime beyond a reasonable doubt; (2) the district court abused its discretion when it admitted audio evidence of Kralovec’s encounter with Officer Miller as res gestae and under Idaho Rule of Evidence 404(b); and (3) the sentencing judge abused his discretion by refusing to review the trial transcripts and exhibits prior to sentencing. Finding no error in the district court’s judgment of conviction, the Supreme Court affirmed. View "Idaho v. Kralovec" on Justia Law

Jeremy and Jessica Litster appealed a district court dismissal on summary judgment. The case concerned the enforceability of three promissory notes, which were prepared and issued by Jeremy to Jason Lee , Scott McNab, and a non-party, Rick Lee. In February 2009, Jeremy learned of an "investment opportunity" that required a minimum buy-in of $500,000. Jeremy and Jason solicited close friends and family to "invest" by transferring money to them, which would later be transferred to Jeremy's relative, Marc Jenson. Ultimately, the "investment" failed, and Plaintiffs and other "investors" looked to Jeremy for repayment. Jeremy made payments on these promissory notes. However, in July 2011, Jeremy stopped making payments because he learned that the Idaho Department of Finance had been notified regarding his investment solicitation activity. Plaintiffs filed a complaint against the Litsters in 2014, alleging three counts of breach of contract for failure to pay the amounts due according to the promissory notes. The Litsters answered asserting, inter alia, the affirmative defense that the notes were issued under duress. Plaintiffs filed a motion for summary judgment of the issues of breach of contract and duress. The district court granted Plaintiffs' motion. On the issue of duress, the district court found in Plaintiffs' favor under two different legal theories: (1) the Litsters failed to provide sufficient evidence of their claim for duress to create a genuine issue of material fact; and (2) the district court noted that the undisputed evidence demonstrated that Jeremy ratified the promissory notes by making payments thereon. It concluded that, in addition to the absence of a genuine issue of material fact, the Litsters' "claim for duress fails because [Jeremy ] ratified the contracts by making payments on the [n]otes." The Supreme Court affirmed summary judgment, finding that the Litsters failed to contest the alternate grounds upon which the summary judgment was granted. View "Lee v. Litster" 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

The question before the Supreme Court in this matter was whether exigent circumstances existed to justify a warrantless blood draw. Defendant-appellant Daniel Chenobieff argued the blood draw violated his constitutional protection against unreasonable searches and seizures and, consequently, that the district court erred in affirming the magistrate court’s denial of his motion to suppress the evidence obtained in the blood draw. The district court specifically pointed to the prosecutor’s attempt to obtain a warrant through the on-call magistrate who could not be reached. The district court also made reference to the delay resulting from Chernobieff's refusal to perform field sobriety tests, but in doing so the court erred. Any delay caused by Chernobieff's exercise of his Constitutional rights may not be considered. The court concluded that the magistrate considered the totality of circumstances and that the magistrate’s findings were supported by substantial evidence. The Supreme Court concurred with the district court. "Even excluding the delay related to the field sobriety tests, there was substantial evidence to support the magistrate’s findings. Therefore, we find that the district court did not err in affirming the denial of the motion to suppress the results of the blood draw." View "Idaho v. Chernobieff" on Justia Law

Appellants Duane Kemmer, Karen Kemmer, and Tim Dolph appealed the district court’s decision that Respondents Bob Newman, Phyllis Miller, and Ruth Smith were properly elected as directors of New Life Missions, Inc. church (NLM) at a special membership meeting. On appeal, Appellants argued the district court erred in reaching its decision because the special meeting was improperly called in violation of the Idaho Nonprofit Corporation Act. After review of the matter, the Supreme Court agreed with that contention and reversed. View "Kemmer v. Newman" on Justia Law

Joseph Maravilla and J.R. Simplot Company both appealed the Industrial Commission’s (Commission) Order on Petition for Declaratory Ruling. Maravilla was injured in an industrial accident while working for Simplot, and Simplot paid Maravilla’s worker’s compensation benefits for that injury. In a separate action, Maravilla brought suit against Idaho Industrial Contractors, Inc. (IIC), the contractor performing repairs on the area where Maravilla was injured. Maravilla and IIC settled the claim for $75,000 and Simplot claimed subrogation against Maravilla. In its order, the Commission ruled that Maravilla could have argued that Simplot was partly at fault for Maravilla’s industrial accident and that Simplot’s negligence, if proved, was not a bar to Simplot being reimbursed for worker’s compensation payments it had paid Maravilla. Simplot appealed the Commission’s decision that Maravilla’s settlement with IIC does not preclude Maravilla from attempting to prove Simplot’s negligence. Maravilla appealed the Commission’s ruling that Simplot was entitled to reimbursement even if Simplot’s negligence contributed to Maravilla’s injury. The Supreme Court, after its review, affirmed in part and reversed in part, finding that the Commission erred in its interpretation of the controlling case law in this matter: “The adoption of comparative negligence and the abrogation of joint and several liability do not affect the rationale behind the Liberty Mutual rule, let alone require its abandonment.” The Court affirmed in all other respects. View "Maravilla v. J. R. Simplot Co." on Justia Law