Justia Idaho Supreme Court Opinion Summaries

Stafford and Woodruff Smith (Woody) were brothers. Their father established Smith Chevrolet, and over the years the brothers have co-owned several auto dealerships, other businesses, and parcels of real property. The brothers each owned 50% of Staffwood, an entity that owned properties and other assets. In 2010, a dispute arose between the brothers involving their business dealings, and in 2010, the brothers entered into a settlement agreement (the 2010 Agreement) that gave ownership of Smith Chevrolet to Stafford. The 2010 Agreement also identified four parcels of land that either brother could purchase through a bid process. Between 2010 and 2012, various transactions occurred between Smith Chevrolet, Woody, Stafford, and Staffwood which culminated in another dispute between the brothers and another settlement agreement (the 2012 Agreement). The 2012 Agreement provided that each brother had the right to initiate a bid process to purchase the properties owned by Staffwood. In 2013, Woody sent a letter to the management of Staffwood in which he asserted that he had won the bidding process and asked Stafford to clear the title to the Smith Chevrolet Property. Woody appealed the district court’s grant of judgment on the pleadings and award of attorney fees to Stafford in his subsequent suit seeking specific performance of his winning bid. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Smith v. Smith" on Justia Law

In 2011, Medical Recovery Services, LLC (“the Collection Agency”), filed this action against defendants Allison and Nathan Olsen to recover on two entities’ unpaid medical bills. In 2012, the parties stipulated that the Collection Agency could recover a judgment against defendants and that it would forbear executing on the judgment if the defendants paid $100 per month between the 25th and 30th of each month until the judgment was paid. The court entered a judgment providing that the Collection Agency could recover from the Defendants the sum of $4,973.46. Defendants failed to make any payment on the judgment, and the Collection Agency attempted to execute on the judgment. The Collection Agency sought to execute on defendants’ bank account, but the account had been closed. The Collection Agency then sought a continuing garnishment to obtain Mr. Olsen’s disposable earnings from Petersen, Moss, Hall & Olsen, but that garnishment was returned unsatisfied because “Defendant is a partner in the firm, not an employee.” The Collection Agency also sought to execute on Mr. Olsen’s partnership interest, but the writ was returned unsatisfied because Mr. Olsen’s equity in the partnership was stated to be zero. The Collection Agency then sought to depose Stephen Hall, the partner in the law firm who had signed the responses to the writs of garnishment. The Collection Agency agreed to forgo taking his deposition if Hall would make $250 bi-monthly payments until the judgment was paid in full. Hall made those payments, but the Collection Agency would not accept final payment endorsed "payment in full" because it wanted to seek post-judgment attorney fees. Defendants filed a motion seeking to compel the Collection Agency to record a satisfaction of judgment in every county in which it had recorded the original judgment. The Agency responded by filing for an award of post-judgment fees it incurred trying to collect on its judgment. The Agency's motion was denied, and the Agency estopped from further collection of fees, citing the agreement reached in satisfying the judgment. The district court upheld the magistrate court's judgment. Finding that Hall only agreed to satisfy the judgment, the Supreme Court concluded the district court erred in affirming the magistrate. The case was remanded for further proceedings. View "Medical Recovery Svcs. v. Olsen" on Justia Law

Donna Simono attended a meeting hosted by Treasure Valley Area of Narcotics Anonymous (“TVNA”) at the Turner House in Mountain Home. When leaving the meeting, she fell down the stairs and injured her ankles. Simono brought a negligence action against Turner House, Larry Rodgers, and Cheryl Baker (collectively “Turner House”). Turner House filed a third-party complaint against TVNA, alleging that TVNA was responsible for maintaining the area where Simono fell. Turner House also sought indemnification for Simono’s claims. The jury returned a verdict finding neither Turner House nor TVNA negligent, and the district court entered judgment dismissing Simono’s complaint and Turner House’s third-party complaint. TVNA filed a motion seeking attorney fees against Turner House under Idaho Code section 12-120(3). The district court denied the motion for fees, concluding that the lawsuit was not based on a commercial transaction. TVNA appealed the district court’s denial of its motion for fees. Both TVNA and Turner House sought attorney fees on appeal. Finding that the district court erred in concluding that TVNA was not entitled to attorney fees, the Supreme Court reversed. Fees and costs on appeal were awarded to TVNA. View "Turner House v. Treasure Valley Area of Narcotics Anonymous" on Justia Law

At issue in this case was a decision of the Industrial Commission (the Commission) finding that Edward Jordan failed to prove entitlement to additional benefits for accidents that occurred during his employment. Jordan served over twenty-one years in the Navy, retiring in 2003. While in the Navy, Jordan was never assessed with a service-related disability involving his cervical area.1 After retiring from the Navy, Jordan and his wife moved to Boise, and he started working for Dean Foods as a milk delivery driver. On May 16, 2006, Jordan suffered an injury while trying to move a stack of milk containers (the 2006 accident). Jordan testified he experienced a sudden onset of pain in his neck and shoulders along with numbness extending down his arms. He notified a supervisor after he dropped a gallon of milk due to the numbness. Jordan sought treatment for neck, cervical, and radiculopathy symptoms. Jordan would document complaints about his neck to his employer over the next five years. Jordan underwent surgery in 2012. Jordan recovered from the surgery without complication, but Dr. Doerr imposed lifting restrictions. As a result of the restrictions, Dean Foods terminated Jordan’s employment after it determined that it was unable to make reasonable accommodations which would allow Jordan to accomplish his essential job functions. The Commission chose not to adopt the referee’s recommendation although it also decided Jordan’s claims in favor of Employer/Surety. The Commission’s decision differed from the referee’s recommendation because the Commission decided to address the merits of Jordan’s claim related to the 2006 accident rather than holding that he abandoned those claims. After review of the Commission record, the Supreme Court concluded there was no reversible error and affirmed. View "Jordan v. Dean Foods" on Justia Law

Chelsea Reed obtained a divorce from Zane Reed on the ground of adultery, terminating their five-year marriage. They had twin daughters who were about three years of age. Chelsea was awarded primary physical custody of the twins, and Zane was awarded visitation. Years later, Zane moved to modify the divorce decree when Chelsea petitioned to move out of state to Montana and take the children with her. The trial court found it was in the children's best interests if they remained with their mother and move to Montana. Zane was allowed three days each month, a week during Christmas vacation, and two weeks in the summer months as visitation. Zane appealed. Finding no reversible error, the Supreme Court affirmed. View "Reed v. Reed" on Justia Law

This appeal arises from a magistrate court’s judgment terminating the parent-child relationship between Appellant Jane Doe (Doe) and her child, M.R. Doe turned eighteen while in foster care, aging out of the system. Doe gave birth to M.R. in 2011 and began living with M.R. in a separate residence on her parents’ property. In August of 2012, Doe was arrested for aggravated assault. M.R. was sixteen months old at the time of Doe’s arrest. Upon her incarceration, Doe “signed over temporary guardianship” of M.R. to her parents. Doe was eventually sentenced to serve five years, with two years fixed, and the court retained jurisdiction. Doe was unsuccessful on her rider, and in June of 2014 the district court relinquished jurisdiction because of Doe’s “aggressive behavior” while in prison. Doe testified that the earliest date that she might be released was May of 2017. At that time, M.R. would be six years old. He had not been in Doe’s care since her arrest. In October of 2014, M.R. came into the care of the Department of Health and Welfare because of physical abuse of another child in Doe’s parents’ home. On November 12, 2015, the Department filed a Petition for Termination of the Parent-Child Relationship. Following a hearing on March 21, 2016, the magistrate court found that the Department had met its burden of proving, by clear and convincing evidence, two grounds upon which termination could be granted: (1) neglect, due to Doe’s failure to comply with her case plan; and (2) Doe’s incarceration for a substantial portion of M.R.’s minority. The magistrate court further found, again by clear and convincing evidence, that termination of Doe’s parental rights was in M.R.’s best interests. Doe timely appealed. The Supreme Court found that substantial and competent evidence supported the magistrate court’s finding that termination was in M.R.’s best interests. However, the Court found that the magistrate court’s decision that Doe had been and was likely to be incarcerated for a substantial period of M.R.’s minority applied an erroneous legal standard. The judgment terminating Doe's parental rights was vacated and the case remanded for further proceedings. View "Dept. of Health & Welfare v. Jane Doe (2016-14)" on Justia Law

Defendant-appellant Kirk Charlson appealed after he was convicted for felony driving under the influence. Before the trial, Charlson filed a motion to suppress the results of an evidentiary blood draw that was conducted without a warrant. The district court denied the motion, and Charlson was convicted. On appeal of the denial of his motion to suppress the results of the evidentiary blood draw, Charlson argued the draw violated his Fourth Amendment rights. When the totality of the circumstances in this case were considered, the Supreme Court concluded the State established voluntary consent to evidentiary testing sufficient to obviate the need for a warrant to draw Charlson’s blood. Although the district court did not have the benefit of the Supreme Court’s recent relevant opinions, it nonetheless reached the correct result. Therefore, its order denying Charlson’s motion to suppress the evidence against him was affirmed. View "Idaho v. Charlson" on Justia Law

Charles Ballard filed suit for wrongful death and medical malpractice against Silk Touch Laser, LLP (“Silk Touch”) and its owner Dr. Brian Kerr. In 2010, Charles’ wife Krystal Ballard underwent a liposuction and fat transfer procedure at Silk Touch in Eagle. Krystal died less than a week later from septic shock caused by unknown bacteria in her right buttock. Charles’ suit alleged that the bacteria that caused Krystal’s death were introduced into her body during the procedure at Silk Touch because certain reusable medical equipment was not properly disinfected and sterilized. The first trial ended in mistrial. Upon retrial, a jury returned a verdict in favor of Ballard. Silk Touch raises twenty-one issues on appeal, challenging several of the district court’s evidentiary rulings, the sufficiency of the evidence supporting the verdict, several of the jury instructions, and the district court’s award of costs and attorney fees. Silk Touch also alleged that the jury verdict should be overturned because the district court permitted the jurors to submit questions to witnesses and the district court made improper comments on the evidence during trial. The Supreme Court affirmed the district court except for the award of fees, which was vacated and the issue remanded for reconsideration. View "Ballard v. Kerr, M.D." on Justia Law

A wildfire destroyed David and Kristina Parks’ house, which was insured by Safeco Insurance Company (“Safeco”). The Parks purchased an existing house, and Safeco paid the Parks a total of $255,000, the cost of the replacement house less the value of the land. The Parks filed a complaint against Safeco alleging: (1) they were entitled to $440,195.55 under the policy; and (2) Safeco committed bad faith in handling the claim. Safeco filed a Motion for Summary Judgment asserting that the policy was not breached and its conduct did not constitute bad faith. The Parks filed a Cross-Motion for Summary Judgment asserting that Safeco misrepresented the policy. Additionally, the Parks moved to amend their complaint to include a claim for punitive damages. The district court held that: (1) there was no breach of contract because the policy was unambiguous and the Parks received the amount due under the clear language of the policy; (2) Safeco did not commit bad faith in handling the claim because it complied with the terms of the policy and paid the Parks the amount owed; and (3) the Parks had not established a reasonable likelihood of proving facts at trial sufficient to support an award of punitive damages. The Parks appealed, but finding no reversible error, the Idaho Supreme Court affirmed. View "Parks v. Safeco Ins Co of Illinois" on Justia Law

Douglas and Brenda Lawrence (“the Lawrences”) challenged a district court judgment enjoining them from interfering with, impeding, or preventing Spectra Site Communications, Inc. (“Spectra”) from using or maintaining Blossom Mountain Road, which crossed the Lawrences’ property. Spectra leased property owned by Robert and Mark Hall (the “Halls”) located east of the Lawrence property. After a six-day bench trial, the district court held that Spectra had proven that the Halls have an easement implied by prior use and an easement implied by necessity. Accordingly, the district court found that Spectra, as a lessee of the Halls, was entitled to use and maintain Blossom Mountain Road. The district court also awarded Spectra costs and attorney fees. The Lawrences appealed, arguing, inter alia, that the district court erred in finding that the Halls had an easement upon which Spectra’s injunctive relief is based. Finding no reversible error, the Idaho Supreme Court affirmed. View "Spectra Site Communications v. Lawrence" on Justia Law