Justia Idaho Supreme Court Opinion Summaries

This was the fourth time this case has been up to the Idaho Supreme Court. Following the last remand, the district court conducted a six-day bench trial, after which it entered its Memorandum Decision and Order granting Capstar Radio Operating Company an easement over the disputed road on Douglas and Brenda Lawrence's property. The Lawrences appealed, arguing, among other things, that the district court’s determinations regarding the easement claims were not supported by substantial and competent evidence. Finding no reversible error, the Supreme Court affirmed. View "Capstar Radio v. Lawrence" on Justia Law

Vint Hughes and H-D Transport, an Idaho partnership, appealed the grant of summary judgment in favor of Michael Pogue and Lawson & Laski, PLLC (collectively Pogue) in a legal malpractice action. Hughes and H-D Transport brought suit against Pogue claiming that at various points starting in October 2011, until present, Pogue had an attorney-client relationship with both Hughes and H-D Transport. In August of 2011, Hughes and Andrew Diges entered into a 50-50 partnership, under the name H-D Transport, to haul hydraulic fracturing fluid. Disagreements arose between the partners concerning the operation and finances of the partnership. On October 21, 2011, Diges hired Pogue to draft a formal partnership agreement. Diges told Hughes that he had hired an attorney to prepare a partnership agreement, and about a month later Pogue, Hughes and Diane Barker, the partnership bookkeeper, participated in a conference call regarding the partnership. Despite the efforts to create a partnership agreement, Pogue, on behalf of Diges, sent Hughes a letter “regarding the problems and irregularities concerning the operation of H-D Transport, and to propose a wind-up of the business.” Pogue filed a complaint requesting declaratory relief, an accounting, and a dissolution of the partnership (the Dissolution Action). In the complaint, Pogue named H-D Transport and Diges as the plaintiffs and Hughes as the defendant. Following trial of the Dissolution Action, the district court entered findings of fact and conclusions of law which largely decided issues in Hughes’ favor. Diges was ordered to repay H-D transport more than $50,000, including $1,500 in partnership funds for legal fees paid to Pogue. Following trial, but prior to the district court’s decision in the Dissolution Action, Hughes and H-D Transport filed the present action naming Pogue and his firm as defendants, alleging two counts of professional negligence and breach of fiduciary duty and two counts of unreasonable restraint of trade under the Idaho Competition Act. The district court granted Pogue’s motion for summary judgment on all claims, concluding Hughes and H-D Transport failed to establish that an attorney-client relationship existed with Pogue. The Supreme Court found that it was unreasonable, under the facts of this case, for Hughes to believe he had an attorney-client relationship with Pogue. The Court therefore affirmed the district court judgment. View "H-D Transport v. Pogue" on Justia Law

John Kugler appealed the grant of summary judgment in his suit against Ron Nelson, David Powers, Steven Kenison, William Armstrong, and Powers Candy Co., Inc. (collectively “the Defendants”). Until mid-2010, Kugler, Nelson, Powers, Kenison, and Armstrong were all shareholders of H & M Distributing, Inc. (H & M), a wholesale distributor of beverages, cigarettes, and other miscellaneous items. In his complaint, Kugler alleged breach of various agreements and wrongful actions taken by the Defendants all in relation to Nelson's departure from H & M. The district court dismissed all of Kugler’s claims because it found that the claims were derivative and Kugler failed to comply with derivative action requirements. Finding no reversible error, the Supreme Court affirmed. View "Kugler v. Nelson" on Justia Law

In February 2003, Glen and Rachel Knapp entered into a written lease agreement with Lockridge Outdoor Advertising Agency to place a billboard sign on their property in exchange for annual rental payments. The lease was for a period of ten years, beginning May 1, 2003, with a five-year renewal provision after the original term expired. Lockridge assigned the lease to Canyon Outdoor shortly after it was executed. The lease agreement contained a provision that allowed Knapps to sell an easement to Canyon Outdoor for a lump sum. In May 2003, Canyon Outdoor paid a $12,000 lump sum, and the parties signed an easement agreement. Canyon Outdoor completed construction of the sign in May 2003. Neither the lease nor the easement agreement contained a legal description of the property. Neither document was recorded. In 2006, Knapps sold their property to Tiller and issued to Tiller a warranty deed with no restrictions. Tiller had discussions with Knapps about the lease agreement and reviewed the lease document prior to purchasing the property. Tiller also had a title policy issued that, due to the non-recording, did not disclose the easement. Tiller asserted that he was unaware of the easement until May 2013 when Canyon Outdoor faxed him a copy of the easement. Thus, Tiller argued that he was a bona fide purchaser under Idaho Code sections 55-606 and 55-812. Canyon Outdoor argued that Tiller, at minimum, had constructive notice of the easement and therefore did not qualify as a bona fide purchaser. The parties stipulated to have the district court decide the case on cross-motions for summary judgment. Finding that Tiller did not have actual or constructive notice of the easement and that Tiller conducted a reasonable investigation of the property, the district court ruled in favor of Tiller and found that the easement agreement executed by Knapps and Canyon Outdoor was unenforceable against Tiller. Canyon Outdoor appealed. Finding no reversible error, the Supreme Court affirmed. View "Tiller White, LLC v. Canyon Outdoor Media, LLC" on Justia Law

At the heart of this appeal was a dispute about the duration of an administrative suspension of an Idaho driver’s license. Respondent Susan Warner was convicted in Idaho of driving under the influence of alcohol (DUI). Two years later, she was convicted in Montana on another DUI charge. Upon receiving notice of the Montana conviction, the Idaho Department of Transportation administratively suspended Warner’s driver’s license for a period of one year. Warner challenged the duration of the suspension, arguing that because the Montana conviction was not for a “second DUI” the maximum allowed suspension was thirty days. The Department rejected Warner’s challenge, but on judicial review, the district court reduced the suspension from one year to thirty days. The Department appealed. Finding that the district court erred in reducing the suspension; "it was not error for the Department to apply Idaho Code section 18-8005(4)(e) to impose an administrative suspension for one year based on the Montana DUI being a second rather than a first DUI conviction." The Court vacated the district court's decision and remanded for further proceedings. View "Warner v. Idaho Transportation Dept" on Justia Law

Appellant Bryan Trucking, Inc., sued Respondent Terry Gier for fraud, based on statements and representations Gier allegedly made to Bryan Trucking that induced Bryan Trucking to purchase a used commercial truck from a third party. Gier was a member of Gier Jammer’s Diesel Repair, LLC. Gier Jammer’s serviced long-haul trucks for Bryan Trucking starting in 2009. In August 2012, Gier Jammer’s overhauled the motor in a 2005 Kenworth truck owned by Niel Ring Trucking, Inc. (“Ring Trucking”). Niel Ring (“Ring”) notified Gier that Ring Trucking wanted to sell the truck, and Gier arranged the deal. The district court dismissed the claim by stipulation of the parties. Bryan Trucking appealed the district court’s subsequent award of costs and attorney fees to Gier. Finding no reversible error in the district court's decision, the Supreme Court affirmed. View "Bryan Trucking v. Gier" on Justia Law

Kentsler Jones appealed his conviction for driving while under the influence of alcohol (DUI), and felony excessive alcohol concentration. On appeal, Jones argued that the district court erred when it excluded evidence regarding the measurement of uncertainty in Jones’s alcohol concentration test result. Specifically, Jones argues that the Idaho Supreme Court’s holding in "Elias-Cruz v. Idaho Dep’t of Transp.," (280 P.3d 703 (2012)), was manifestly wrong and should have been overturned. The Supreme Court declined to overturn "Elias-Cruz" and affirmed Jones' conviction. View "Idaho v. Jones" on Justia Law

On July 12, 2014, around 5:00 A.M., Ben Savage appeared at the Custer County Sheriff’s Office and reported that defendant-respondent Jon Huffaker had pointed a loaded rifle and threatened to kill him. At approximately 6:00 A.M. Sergeant Shawn Kramer located Huffaker walking his dog in a nearby field. Sgt. Kramer did not activate his lights or siren and did not otherwise make contact with Huffaker. Huffaker noticed Sgt. Kramer’s vehicle and approached it. Sgt. Kramer then informed Huffaker of Savage’s allegations against him. At that time, Sgt. Kramer noticed that Huffaker appeared intoxicated. Sgt. Kramer offered to give Huffaker a ride to the Sheriff’s Office so he could give Deputy Levi Maydole his side of the story. Huffaker agreed, and Sgt. Kramer drove Huffaker and his dog to the Sheriff’s Office. During the ride to the Sheriff’s Office, Huffaker rode in the passenger seat of Sgt. Kramer’s law enforcement vehicle while his dog rode in the back seat. In the course of his interaction with Sgt. Kramer, Huffaker was not frisked or handcuffed. He was not physically or verbally coerced by Sgt. Kramer into entering the law enforcement vehicle. He was never told that he was being arrested, detained, or otherwise deprived of his freedom. After a roughly five minute interview, Deputy Maydole informed Huffaker that he was under arrest. Roughly three hours after having been arrested, Huffaker requested and was provided with a “Voluntary Statement” form, on which he wrote down an account of the events from that morning, which contained incriminating statements similar to those he had made during his interview with Deputy Maydole. Prior to trial, the district court suppressed both Huffaker’s interview and his written statement under Miranda. The district court reasoned that Huffaker was “in custody” during the interview because: (1) “Defendant has no way of returning home because he was intoxicated and Kramer had given him a ride to the station”; (2) “Defendant was questioned as the sole suspect by a law enforcement officer”; (3) “[h]e was not told he was free to leave”; and (4) “[a] normal person in Defendant’s circumstances would not have believed they could end the interview and freely leave the police station.” Following entry of the order granting Huffaker’s motion to suppress, the State appealed to the Court of Appeals. The Court of Appeals affirmed the order as to Huffaker’s written statement, but reversed as to his oral statements, concluding that he was not in custody when those statements were made. The Supreme Court vacated the district court's order suppressing both Huffaker's written and oral statements, finding that Huffaker was not in custody when his statements were made, and that the written statement was not drafted in response to interrogation. View "Idaho v. Huffaker" on Justia Law

Defendant-appellant Lance Taylor appealed a district court order denying him credit for time served as a condition of probation. Specifically, the credit he sought was for periods of incarceration during his drug court program. Taylor argued the district court erred: (1) for not giving retroactive effect to the Credit Statutes, Idaho Code 18-309 and 19-2603; and (2) misinterpreting the conditions of his probation, in the event that he was not entitled to credit for his incarceration during the drug court program. After review, the Idaho Supreme Court affirmed the district court's order insofar as it awarded credit for time served for certain periods of Taylor's drug court incarceration. However, the Court reversed the order insofar as it denied credit for certain other periods. The case was remanded for determination of the total number of days to be applied against Taylor's sentence. View "Idaho v. Taylor" on Justia Law

Respondents Jane Doe I (“Intended Mother”) and John Doe I (“Intended Father,” collectively with Intended Mother, “Intended Parents”) were a married couple living in Alaska. In May, 2014, Intended Parents contracted with Jane Doe (“Gestational Carrier”) living in Idaho, to carry an embryo made from Intended Father’s sperm and a donor egg. After the baby was born, Gestational Carrier and her husband, John Doe (“Husband”), moved for a declaratory judgment that Intended Parents are the parents of the resulting child (“Child”). The district court refused. It reasoned that declaratory judgment was not available to determine the parentage of Child because Idaho law already provides a statutory means by which parties can become parents when using a gestational surrogate: the termination of that gestational surrogate’s parental rights and the adoption of the child. The district court also found that the surrogacy agreement entered into between the parties was void as against public policy to the extent that it sought to contractually assign parentage. Finding that the district court did not err in refusing to grant declaratory relief, the Idaho Supreme Court did not address whether the underlying surrogacy contract was in violation of public policy. View "In The Matter of The Declaration of Parentage" on Justia Law