Justia Idaho Supreme Court Opinion Summaries

In prior proceedings, the Idaho Supreme Court reversed the district court’s judgment in favor of The Golf Club at Black Rock (Golf Club) and its award of costs and attorney fees. This case was an appeal of the district court’s denial, upon remand, of Appellant’s Memorandum of Attorney Fees and Costs. Appellant argued that the district court erred in ruling that the court did not have jurisdiction to award fees and costs on remand. The Supreme Court agreed with appellant and reversed. View "Sky Canyon Properties v. The Golf Club at Black Rock, LLC" on Justia Law

On September 17, 2011, Martin Hayes was seriously injured after stumbling on uneven ground hidden by grass while attending his grandson’s Pop Warner football game at the Plummer School Park, which was owned by the City of Plummer. Hayes did not pay any fee or admission to enter the Park. Hayes filed a premises liability claim against the City for his injuries. In turn, the City filed a motion for summary judgment on the basis that the City was entitled to a limit on liability under Idaho’s Recreational Use Statute. The district court granted the City’s motion. Hayes appealed. After review, the Supreme Court agreed with the district court's analysis that the Recreational Use Statute provided limited liability protection because the City did not receive "compensation" or "charge" for use of the land upon which Hayes was injured. View "Hayes v. City of Plummer" on Justia Law

Father appealed a magistrate court's judgment terminating his parental rights to Child. Mother brought a petition for termination of Father’s parental rights. Following trial, the court granted Mother’s petition, finding that termination was justified based on Father’s prolonged incarceration and inability to discharge his parental responsibilities and was in Child’s best interest. Father appealed, challenging the sufficiency of the evidence to support the magistrate court’s determination of the issues. Finding the evidence sufficient to support the magistrate court's determination, the Supreme Court affirmed. View "Jane Doe (2015-03) v. John Doe" on Justia Law

Defendant Dennis Sallaz and Defendants-counterclaimants Glenn Trefren and Tradesman Contractors and Construction, LLC, (collectively “Appellants”) appealed the district court’s holding they could not recover breach of contract damages or obtain equitable relief for the failure of Plaintiff-counterdefendant Real Properties, LLC, to pay the full purchase price under an agreement for the sale and purchase of Real Homes, LLC. Although the district court found that the contract between Sallaz and Trefren, as sellers, and Real Properties, as buyer, was valid, it held that Real Properties’ performance of the contract was excused because of a material breach by the sellers. The district court held that equitable relief was not available because of the existence of the contract. Upon review, the Supreme Court concluded that the district court erred in dismissing the counterclaimants' claim for breach of contract. The district court's dismissal of count 3 of the counterclaim was vacated and remanded pending the outcome of reconsideration of count 1. View "Rice v. Sallaz" on Justia Law

On August 13, 2013, the Idaho Department of Labor (IDOL) mailed two Determinations of Overpayment and an Eligibility Determination to Mitchell Kennedy at the address he had provided when filing for unemployment benefits. The Determinations informed Kennedy that he had the right to appeal, or protest, the Determinations and that the last day to do so was August 27, 2013. On August 21, 2013, Kennedy moved to a new residence. He changed his address with the U.S. Postal Service. Kennedy received the Determinations on August 24, 2013, three days before the deadline. He did not read them until either August 26 or 27. The Industrial Commission made no specific finding as to when Kennedy read the letters but did find that “Claimant did not closely review the Determination to realize the applicable appeal dates due to work and other personal priorities.” Kennedy faxed his protest to IDOL on August 29, 2013, two days after the deadline. In the transmission of that protest, Kennedy informed IDOL of his new address. The appeals examiner found that Kennedy’s request for an appeals hearing was not timely and therefore the examiner had no jurisdiction to hear Kennedy’s appeal. Kennedy appealed, and the Commission affirmed the examiner’s decision. Kennedy then requested reconsideration from the Commission. Finding that Kennedy had not presented any further argument on the relevant issues, the Commission denied the motion. Kennedy timely filed this appeal under Idaho Code section 72-1368(9) and Idaho Appellate Rules 11(d) and 14(b). But finding no reversible error in the Commission's decision, the Supreme Court affirmed. View "Kennedy v. Hagadone Hospitality Co." on Justia Law

This appeal from arose from proposed repairs and improvements to the City of Challis’ water distribution system. In 2013, the City initiated a judicial confirmation proceeding seeking approval to incur $3.2 million in debt without a public vote. The Consent of the Governed Caucus challenged the constitutionality of the City’s request based upon Article VIII, section 3 of the Idaho Constitution. The district court granted the City’s request and the Caucus appealed. Finding that the district court erred by failing to apply the legal standard for what constitutes a "necessary" expense under the Idaho Constitution, the Supreme Court reversed the district court's decision and remanded for further proceedings. View "City of Challis v. Consent of the Governed Caucus" on Justia Law

The Payette County Board of Commissioners approved a conditional rezone of a parcel of land from agricultural to industrial, subject to a development agreement, in connection with a project to build a nuclear power plant. Various parties appealed the approval to the district court. The district court upheld the Commissioners’ actions. H-Hook, LLC, a neighboring landowner, appealed the district court’s decision. Finding no reversible error, the Supreme Court affirmed. View "Burlile v. Bd of Co Commissioners, Payette" on Justia Law

This case was an appeal of a district court order awarding attorney fees to Ascorp, Inc. d/b/a Debco Construction (Debco) against the Idaho Transportation Department (ITD) in a declaratory judgment action filed by ITD to determine rights of the parties with respect to a contract for highway construction services on a project in Twin Falls. The district court dismissed the action upon Debco’s motion under Idaho Rule of Civil Procedure 12(b)(6) and awarded attorney fees to Debco under Idaho Code section 12-120(3). On appeal ITD argued that the district court erred in determining that the declaratory judgment action qualified as a dispute involving a commercial transaction required for the application of Idaho Code section 12-120(3). Finding no reversible error, the Supreme Court affirmed the district court's order. View "Idaho Transportation v. Ascorp, Inc." on Justia Law

This lawsuit arose out of a fatal helicopter crash that occurred on August 31, 2010, in Kamiah, Idaho. The Idaho Department of Fish and Game had contracted with Leading Edge Aviation, LLC, to fly two Department employees from Clarkston, Washington, to the Selway River in Idaho in order to collect data on salmon spawning. The pilot of the helicopter was Perry J. Krinitt, Jr., the son of the Plaintiff. The two Department employees were Larry Barrett and Danielle Schiff. Plaintiff filed this wrongful death action contending that the accident was caused by the negligence of the Department or its employees. Defendants moved for summary judgment, and, after briefing and argument, the district court granted the motion. Plaintiff then appealed. Because there were genuine issues of material fact regarding the liability of the Defendants, the Supreme Court vacated the judgment and reversed the order granting the motion for summary judgment. View "Krinitt v. Dept of Fish and Game" on Justia Law

In 2004 when he was sixteen years old, claimant Terence Fairchild worked for Kentucky Fried Chicken as a cook. While carrying garbage to a dumpster, he slipped on ice and fell onto a concrete barrier, striking his knees. The impact caused his knees to bleed. He went inside the building, bandaged his knees, and informed his supervisor of the accident. Claimant sought medical care. The physician diagnosed his condition as patellofemoral pain following bilateral patella contusions and prescribed knee braces, stretching exercises, Naprosyn, and ice. He saw the physician one week later and continued to suffer pain in both knees. The physician prescribed physical therapy, which failed to alleviate Claimant’s symptoms. The physician ordered an MRI of Claimant’s left knee a few weeks later. The MRI did not reveal any abnormality. After reviewing the results of the MRI with an orthopedist, the physician continued Claimant on physical therapy and anti-inflammatory medication. Approximately one month following the accident, Claimant filed a complaint seeking benefits under the Worker’s Compensation Law. Claimant sought a second, third and fourth opinions, including one from an orthopedic surgeon. These opinions spanned approximately seven years following the initial fall. In 2007, the orthopedic surgeon suspected claimant suffered a partial posterior cruciate ligament injury to his right knee and concluded that Claimant was entitled to a permanent partial impairment of 3%. In 2011, an examining physician agreed Claimant suffered a partial posterior cruciate ligament injury, but estimated the permanent partial impairment of 7%. In a 2012 hearing, the Industrial Commission found Claimant was not a credible witness based upon its observation of him during the hearing and the differences between his hearing testimony and his prior statements in depositions, interviews, and appointments with medical providers. The Commission concluded that it regarded Claimant’s testimony as suspect where it was not supported by other evidence in the record. The Commission found that Claimant had suffered a right posterior cruciate ligament injury in the accident and that as a result of that injury he had a permanent partial impairment rating of 3%. Finally, the Commission found that Claimant had failed to prove that he had a disability in excess of his impairment. Claimant filed a motion for reconsideration, which the Commission denied. Claimant then appealed. Finding no reversible error, the Supreme Court affirmed the Commission's judgment. View "Fairchild v. Kentucky Fried Chicken" on Justia Law