Justia Idaho Supreme Court Opinion Summaries

John Doe was involved in a fight with his sixteen-year-old daughter, C.G., resulting in C.G. sustaining a concussion and cervical strain. The magistrate court entered a civil protection order., which it subsequently modified. John Doe appealed, arguing that the magistrate court erred when it determined that there was an “immediate and present danger of domestic violence” warranting issuance of the protection order and that the court abused its discretion when it specified that the protection order would be in effect for a year. Finding no reversible error, the Supreme Court affirmed. View "Jane Doe (2016-01) v. John Doe" on Justia Law

Jane Doe (“Mother”) appealed a magistrate court’s judgment terminating her parental rights as to her children, D.M., A.M., J.S., A.L., and R.L. She argued that the State failed to produce clear and convincing evidence sufficient to overcome the presumption that she could parent her children. Specifically, Mother argued that: (1) the last eight months of her participation in the case plan contravene a finding of neglect; and (2) the Idaho Department of Health and Welfare (“IDHW”) failed to help reunify the family. Finding no reversible error, the Supreme Court affirmed. View "H&W v. Jane Doe (2016-11)" on Justia Law

Appellant John Thornton, represented by his wife Val Thornton, sued sisters Mary Pandrea and Kari Clark to quiet title to an easement reserved in their names on real property he owned that was adjacent to real property that was jointly owned by the sisters. Clark counterclaimed against John Thornton, seeking declaratory relief establishing her rights in the easement and damages for interference with her easement rights. While this case was pending, the real property jointly owned by Pandrea and Clark was judicially partitioned in a separate proceeding; Pandrea remained as the sole owner of the property adjacent to the easement in question and Clark owned nearby non-adjacent property. The district court granted Clark’s motion for summary judgment on all of John Thornton’s claims against her and on all her counterclaims except her claim for damages. The court denied John Thornton’s motion for summary judgment and subsequent motion for reconsideration. By stipulation, the court dismissed John Thornton’s claims against Pandrea and Clark’s damages claim against him. After all claims were adjudicated, the district court awarded attorney fees to Clark against John Thornton under Idaho Code section 12-121 and against both Mr. Thornton and Ms. Thornton jointly and severally as Rule 11 sanctions. John Thornton appealed several decisions of the district court. Val Thornton, as intervenor, appealed the district court’s imposition of sanctions. After entry of judgment, Kenneth Barrett and Deanna Barrett (“the Barretts”) purchased Clark’s property and substituted in the stead of Clark in the underlying action and in this appeal. John Thornton moved for a stay of execution and waiver of supersedeas bond, which the district court denied. The court granted the Barretts’ motion for sanctions against Mr. Thornton and Ms. Thornton based on the motion for stay. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Thornton v. Pandrea" on Justia Law

Kurt Aikele worked as a firefighter for the City of Blackfoot for twenty-six years. In December 2008, Aikele was diagnosed with adenocarcinoma of the lung, which caused his death four years later. Before his death, Aikele filed a workers’ compensation claim (later amended to include death benefits), arguing that as a lifelong non-smoker with no known genetic predisposition for lung cancer, his disease was likely caused by on-the-job exposure to carcinogens. The Estate appealed when his claim was denied, and when the Idaho Industrial Commission affirmed. The IC determined Aikele was not entitled to workers’ compensation benefits because he failed to prove that his occupation caused him to develop lung cancer. Finding no reversible error with that decision, the Supreme Court affirmed the Industrial Commission’s order. View "Estate of Kurt Aikele v. City of Blackfoot" on Justia Law

The issues in this appeal related to a Property Settlement Agreement (PSA) and judgment of divorce that were both signed in April 2012. This dispute was initiated in the magistrate division of the district court in October of 2013, when Sondra Kantor filed a motion to incorporate the parties’ PSA into the parties’ judgment of divorce. Rejecting Robert Kantor’s argument that it lacked jurisdiction to merge the PSA and judgment of divorce, the magistrate court entered a supplemental decree of divorce that incorporated the terms of the parties’ PSA. Sondra then initiated contempt proceedings against Robert. After Robert unsuccessfully moved to dismiss the contempt charges for lack of subject matter jurisdiction, the parties reached a stipulated resolution of the contempt proceedings which resulted in a judgment that Robert was in contempt. The stipulation permitted Robert to appeal the denial of his motion to dismiss. Robert appealed and the district court affirmed the judgment of contempt. The Supreme Court reversed. "The district court’s decision is less understandable. Although the original decree of divorce explicitly stated that the PSA was a 'separate agreement,' the district court inexplicably found this provision to be 'inherently ambiguous as to the question of merger.' The district court did not identify the source of this 'inherent' ambiguity, and we can find nothing in the judgment that renders it ambiguous as to whether the PSA was merged." The Court concluded the Supplemental Decree was void because the magistrate court lacked subject matter jurisdiction to merge the PSA into its earlier judgment. Therefore, the district court erred by affirming the magistrate court’s order denying Robert’s motion to dismiss. Therefore, the Court reversed the decision of the district court and remand with instructions to vacate the magistrate court’s contempt judgment. View "Kantor v. Kantor" on Justia Law

This was an appeal of the district court’s dismissal of Sondra Kantor's claim that Robert Kantor breached a Property Settlement Agreement (PSA) as a sanction, its grant of summary judgment against her, and its award of attorney fees to Robert. This case initially related to the parties’ efforts to sell the community residence which was the subject of Section 5 of the PSA (the property). In late September of 2012, the parties contracted to sell the property in a short sale for $2.4 million in a cash transaction scheduled to close within 30 days, contingent upon Bank of America’s approval of the short sale. The parties were asked to sign a document that extended the period for the contingency to be satisfied to October 5, 2012. Sondra evidently perceived this as an opportunity to apply leverage to secure Robert’s compliance with other terms of the PSA, and she sent him an email indicating that she would not extend the contingency until a number of demands were satisfied. In March, Robert moved for partial summary judgment, seeking a declaration that Sondra had breached the PSA by failing to timely sign the extension document and dismissal of Sondra’s counterclaims for breach of contract and fraud. Robert’s motion was heard on June 24, 2013. The district court granted summary judgment dismissing Sondra’s breach of contract (Count I) and fraud (Count III) counterclaims and held that Sondra was obligated to sign the short sale extension document. Robert had argued that the attorney fees he had incurred were damages resulting from Sondra’s failure to sign the short sale extension. This action then morphed into a dispute over Robert’s efforts to obtain a loan modification from Bank of America. Months later, Robert moved that Sondra be declared in contempt for her actions frustrating his ability to secure the modification. The district court recognized that it had issued an order of "dubious legality" that could not be enforced by way of contempt, yet insisted that if it were not honored the district court would sanction Sondra without notice or an opportunity to be heard. Appeals of the various district court orders followed. The Supreme Court reversed and remanded. First, the Court determined the district court erred by re-writing the parties' agreements when it required Sondra to convey her interest in the property to Robert. Furthermore, the Court concluded the district court abused its discretion by dismissing Sondra's case as a sanction. Sondra did not show the district court erred in its grant of summary judgment. The Supreme Court did not reach either party's arguments regarding attorney fees. On remand, a new judge was assigned to preside over further proceedings, and no costs or fees were awarded. View "Kantor v. Kantor" on Justia Law

Kenneth and Sally Eyer and Idaho Forest Group, LLC (IFG) entered into a Log Purchase Agreement in which IFG agreed to purchase timber harvested from the Eyers’ land. Before logging, IFG sent an agent to the Eyers’ property to assist them in locating property lines. When the logging occurred, the loggers mistakenly cut timber located on neighboring land. The neighbors sued the Eyers for timber trespass and the Eyers brought a third-party action against IFG for breach of an assumed duty to properly mark the property lines. A jury found in favor of IFG, finding that IFG had not assumed a duty to the Eyers. The district court then awarded IFG $95,608 in attorney fees. On appeal, the Eyers argued the district court erred in awarding fees under Idaho Code section 12-120(3), contending: (1) the gravamen of the Eyers’ complaint was not a commercial transaction; and (2) the Eyers did not sell timber for a “commercial purpose” since they used the proceeds of the sale to pay medical bills. Finding no reversible error, the Supreme Court affirmed. View "Eyer v. Idaho Forest Group" on Justia Law

Jane Doe I (Mother) and John Doe I (Father) each appealed the magistrate court’s judgment terminating their parental rights as to their two minor children, L.W. and J.W. Mother argued the magistrate court erred in several respects, including that it wrongfully terminated her parental rights because the State’s petition for termination was not filed in accordance with Idaho law and because the children had not been in Idaho Department of Health and Welfare (IDHW) custody for a mandatory period of fifteen months before the petition was filed. Mother also argued that the magistrate erred in finding that the children were neglected; that it was in the Mother’s best interests to have her parental rights terminated; and that Mother was unable to discharge her parental responsibilities. Father incorporated Mother’s arguments on appeal into his own appeal, and added that the court erred in determining that Father was unable to discharge his parental responsibilities. Finding no reversible error, the Supreme Court affirmed. View "Dept. of Health & Welfare v. Jane Doe / John Doe" on Justia Law

Northern Title Company of Idaho, Inc. (Northern Title) appealed the award of pre-appeal damages and attorney fees in favor of Steven Cummings (as the prevailing party). The Supreme Court reversed the underlying judgment. Northern Title then brought an I.R.C.P. 60(b) motion to vacate the judgments for damages and attorney fees that the district court had entered against it before the appeal. Cummings objected, arguing that Northern Title’s Rule 60(b) motion was untimely and without good cause. The district court disagreed and granted Northern Title’s motion. Cummings timely appealed. But finding no reversible error in granting Northern Title's motion, the Supreme Court affirmed. View "Cummings v. No Title Co of Idaho" on Justia Law

The issue presented for the Supreme Court's review stems from a quiet title action filed by Appellants Andrew and Kimberly Kirk against Ann Wescott. The Kirks bought a plot of land in Blaine County, referred to as Lot 7 of Block 1 of the Glassford Heights Subdivision (“Lot 7”). After purchasing Lot 7, the Kirks found out that Lot 8 of the subdivision had been granted an easement of access across the southeast corner of Lot 7. Wescott owned Lot 8. In 2012, the Kirks brought this action to quiet title, asking the court to terminate the easement encumbering their property. Both parties moved for summary judgment, asking the court to interpret the deed granting the easement. The district court granted partial summary judgment to Wescott, concluding that the easement was created and none of the events that would trigger its termination had occurred. The Kirks then filed two motions to amend the complaint, both of which the district court denied. After a bench trial, the district court dismissed the Kirks’ action for quiet title. Wescott sought an award of attorney fees, which the district court also denied. On appeal, the Kirks challenged the district court’s grant of partial summary judgment to Wescott and the court’s denial of their motions to amend the complaint. Wescott cross-appealed, challenging the district court’s denial of her motion for attorney fees. Wescott also sought an award of attorney fees on appeal. After review, the Supreme Court concluded the district court erred in its interpretation of the easement on summary judgment. The district court judgment in favor of Wescott was reversed and the case remanded to the district court to enter judgment in favor of the Kirks. Costs were awarded to the Kirks on appeal. View "Kirk v. Wescott" on Justia Law