Justia Idaho Supreme Court Opinion Summaries

The State appealed a district court judgment denying the its motion to vacate portions of a Stipulated Partial Settlement and Award entered by an arbitration panel. This case arose from the 1998 Tobacco Master Settlement Agreement, wherein certain cigarette manufacturers entered into an agreement with the State to pay damages for the cost of treating smoking-related illnesses. A dispute arose between the parties as to the amount owed in 2003 and the district court entered an order compelling arbitration. The arbitration panel entered a Stipulated Partial Settlement and Award in March of 2013. In June of 2013, the State moved the district court to vacate, modify, or correct the award. The district court concluded the State did not have standing to move to vacate or modify the award. The State appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Idaho v. Philip Morris" on Justia Law

This appeal arose out of a district court’s decision to affirm a magistrate court’s order granting Michelle Campbell relief on her breach of contract claim. This case stemmed from an employment offer Parkway Surgery Center, LLC made to Campbell. The offer included assurances that Parkway would “take care of” a loan Campbell had with her previous employer, Bingham Memorial Hospital (BMH). When Parkway refused to pay the obligation as promised, Campbell filed suit for a breach of contract. Following a bench trial, the magistrate court ruled in favor of Campbell and awarded her damages in the amount of the loan plus interest. Parkway appealed to the district court, which affirmed the magistrate’s order, but remanded to the magistrate court to reform the judgment to grant Campbell specific performance. Parkway appealed to the Idaho Supreme Court. On appeal, Parkway raised several arguments, including that the district court erred when it: (1) affirmed the magistrate court’s order; (2) determined Campbell was entitled to specific performance; (3) determined the statute of frauds did not apply in this case; and (4) awarded attorney fees to Campbell. Upon review, the Supreme Court concluded the trial court erred in reforming the magistrate court's judgment to grant Campbell specific performance. The court affirmed the district court in all other respects. The case was remanded for further proceedings. View "Campbell v. Parkway Surgery" on Justia Law

Appellant Monica Garner, and respondent Christopher Garner had two children prior to their divorce in 2010. They were both represented by counsel in that action and entered into a stipulation addressing the terms of their divorce, including child custody and child support. Under the terms of that stipulation, Appellant was awarded primary physical custody of the children, and Respondent agreed to pay a total of $50 a month in child support. The magistrate court did not hold a hearing regarding the stipulation. The magistrate entered a judgment granting Appellant and Respondent a divorce under the terms of the stipulation. Neither party objected, moved for clarification or reconsideration, or appealed the judgment. In 2012, Appellant filed a motion to modify the judgment, seeking an increase in the monthly child support payment to $608.71, to conform with the Idaho Child Support Guidelines. Respondent moved to dismiss the motion on the grounds that there had not been a substantial and material change in circumstances warranting a modification. The magistrate court heard oral argument on Respondent’s motion to dismiss, noting that both parties were currently represented by counsel and had been represented by counsel when the parties divorced. Ruling that there was no material change in circumstances, the magistrate dismissed Appellant’s motion and awarded Respondent attorney’s fees. Appellant appealed to the district court, which affirmed the magistrate court’s decision in all respects. The district court also awarded Respondent attorney’s fees and costs for the appeal. Appellant timely filed a notice of appeal from the district court’s ruling. After review, the Supreme Court reversed and remanded. The fact that the parties were represented by counsel when they entered into the agreement did not change the fact that the judgment originally entered in this case called for a significant, unsubstantiated deviation from the statutory child support guidelines: "This was a virtual forfeiture of child support. There is no explanation for this deviation except in hindsight during this litigation rather than the proper findings and conclusions called for in statute and rule. Neither the original judgment nor the district court’s ruling on the motion to modify support protects the welfare of the children. No facts were ever elicited in this case to rebut the statutory or Guidelines presumption. The required procedure was not followed, and no reasons were given as to why the Guidelines were not followed. There seemed to be no inquiry here as to why such a drastic deviation from the Guidelines was justified." View "Garner v. Garner" on Justia Law

Appellant Mike Von Jones arranged to hunt big game in Zimbabwe, Africa, with HHK Safaris (Pvt) Ltd. Jones went on the hunt and received an invoice for $26,040.00 from Respondent Safaris Unlimited LLC. Jones refused to pay Safaris Unlimited for the hunt. Safaris Unlimited filed a suit for breach of contract. Jones responded that he arranged and engaged in the hunt with HHK, not Safaris Unlimited, and therefore he had no contractual relationship with Safaris Unlimited for payment. He further alleged that he was entitled to offset any amount owed for the hunt with the value of certain trophy items from the hunt and an earlier hunt. Safaris Unlimited moved for summary judgment. The district court granted its motion and entered judgment in favor of Safaris Unlimited. Jones appealed. Upon review, the Supreme Court found that Safaris Unlimited operated as a broker or booking agent for HHK. Other than the actual hunting services provided by HHK, Safaris Unlimited coordinated and assisted on all details of the hunt, such as accommodations, transportation, and permits. The Court concluded that it was improper for the trial court to have granted summary judgment in favor of Safaris Unlimited because whether there was a contract at the heart of this matter was a genuine issue of material fact. The Court therefore vacated and remanded for further proceedings. View "Safaris Unlimited v. Jones" on Justia Law

In 2012, a fire destroyed three buildings and related equipment that were owned by Jackson Hop, LLC, and were used to dry hops, to process and bale hops, and to store hop bales. The buildings were insured by Farm Bureau Mutual Insurance Company of Idaho for the actual cash value of the buildings and equipment, not to exceed the policy limit. Farm Bureau’s appraisers determined that the actual cash value of the buildings was $295,000 and the value of the equipment was $85,909. Farm Bureau paid Jackson Hop $380,909. Jackson Hop disagreed with that figure, and it hired its own appraiser, who concluded that the actual cash value of the buildings and equipment totaled $1,410,000. Farm Bureau retained another appraiser to review the report of Jackson Hop’s appraiser, and that appraiser concluded that the value of $1,410,000 was unrealistically high. Jackson Hop filed this action to recover the balance of what it contended was owing under the insurance policy, plus prejudgment interest. The parties agreed to submit the matter to arbitration as provided in the policy. During that process, Jackson Hop presented additional opinions regarding the actual cash values, ranging from $800,000 to $1,167,000 for the buildings and $379,108 to $399,000 for the equipment. Farm Bureau’s experts revised their opinions upward, although only from $295,000 to $333,239 for the buildings and from $85,909 to $133,000 for the equipment. Before completion of the arbitration, Farm Bureau paid an additional sum of $85,330. Arbitrators determined that the actual cash value of the buildings and the equipment was $740,000 and $315,000, respectively, for a total of $1,055,000. Within seven days of the arbitrators’ decision, Farm Bureau paid Jackson Hop $588,761, which was the amount of the arbitrators’ award less the prior payments. Jackson Hop filed a motion asking the district court to confirm the arbitrators’ award and to award Jackson Hop prejudgment interest, court costs, and attorney fees. Farm Bureau filed an objection to the request for court costs, attorney fees, and prejudgment interest. The court awarded Jackson Hop attorney fees, but denied the request for court costs because the parties’ arbitration agreement stated that both parties would pay their own costs, and the court denied the request for prejudgment interest because the amount of damages was unliquidated and unascertainable by a mathematical process until the arbitrators’ award. Jackson Hop then appealed. Finding no reversible error in the trial court's judgment, the Supreme Court affirmed. View "Jackson Hop v. Farm Bureau Insurance" on Justia Law

Appellant, Stilwyn, Inc., brought suit against the Respondents stating nine claims for relief arising out of a failed transaction to purchase an interest in a loan. The district court dismissed those claims, holding that they were barred by prior federal litigation involving Stilwyn, two of the Respondents, and the same failed transaction. It held the claims were barred by claim preclusion and because the claims were compulsory counterclaims in the federal litigation that were not asserted there. Stilwyn argued on appeal to the Idaho Supreme Court that the district court erred in both respects. Respondents cross-appealed to argue that the district court erred in failing to grant their requests for attorney fees. Respondents also requested attorney fees on appeal. Upon review, the Supreme Court concluded: (1) the district court erred in its conclusion that Stilwyn's claims were barred by claim preclusion; (2) the district court erred in concluding that Stilwyn's claims were compulsory in the federal litigation; and (3) the district court did not err in refusing to grant attorney fees. View "Stilwyn, Inc. v. Rokan Corporation" on Justia Law

Mark Colafranceschi brought this action for defamation and professional malpractice against Shawn Briley and Ashley Robinson after a magistrate court appointed Robinson to perform child custody evaluations in two separate cases in which Colafranceschi was a party. Colafranceschi was the plaintiff in two actions against the mothers of his children. Robinson was a licensed masters social worker. Briley was a licensed clinical social worker and was Robinson’s supervisor. In both reports in the two cases, Robinson's evaluations (as Colafranceschi's claim suggested) "did not cast him in a positive light." The district court dismissed the action, finding that quasi-judicial immunity barred Colafranceschi’s claims. Finding no reversible error, the Supreme Court affirmed. View "Colafranceschi v. Briley" on Justia Law

This case consolidated two appeals from district court. The first case arose from the Idaho Outfitters and Guides Licensing Board’s decision to terminate A.T. “Sandy” Podsaid’s guide license in late 2008, under the terms of a settlement agreement between Podsaid and the Board. The second case arose from the Board’s decision to treat Podsaid’s 2009 guide license renewal application as a new license application. Podsaid appealed both of the Board’s decisions to the district court, which affirmed both decisions, remanding the second case back to the Board. In the first appeal, the district court entered an order affirming the Board’s decision to terminate Podsaid’s 2008 license on December 31, 2008. In the second appeal, the district court determined that the Board properly treated Podsaid’s application as a new license application but remanded the case to the Board because the Board had not yet issued a final decision. Podsaid appealed both district court’s decisions to the Supreme Court. After review, the Court dismissed the first case as moot. As to the second case, it affirmed the district court’s decision that the Board properly treated the 2009–10 license application as a new application and remanded the case back to the Board for final agency action. View "Podsaid v. Idaho Outfitters & Guides Licensing" on Justia Law

This was a case of misappropriation of trade secrets case arising out of a dispute between two competing businesses providing spa and salon services in Pocatello: La Bella Vita, LLC (La Bella Vita) and Eikova Salon and Spa, LLC (Eikova). In February 2011, a number of employees left their employment at La Bella Vita to open Eikova, a new salon nearby. La Bella Vita brought suit alleging that these employees took its confidential client information to create and promote Eikova. After conducting discovery, La Bella Vita voluntarily dismissed all of the defendants except Amanda Shuler and Eikova, as well as all of the claims except the violation of the Idaho Trade Secrets Act and breach of the confidentiality agreement. On motion by the remaining defendants, the district court granted summary judgment against La Bella Vita on these remaining issues. La Bella Vita appealed the district court’s decision to strike a supplemental brief offered in opposition to summary judgment, and also argued that disputed issues of material fact should have precluded the entry of summary judgment. Upon careful consideration of the specific facts of this case, the Supreme Court concluded the district court improperly granted summary judgment in favor of Eikova and Shuler, and remanded the case for further proceedings. View "La Bella Vita v. Shuler" on Justia Law

Appellant Kevin Stokes employed Respondent Sohar Chavez as a part-time irrigator on Stokes's farm. During the course of his employment, Chavez was injured when his finger slipped into the chain of a motor on an irrigation line. Chavez's finger could not be reattached, and a physician amputated it. A few days after the injury, Life Flight billed Chavez $21,201.00 for transport from the farm to the hospital. Chavez then filed a claim for worker's compensation. Stokes, as the employer of Chavez, was uninsured for purposes of worker's compensation law, but paid all medical expenses related to the injury except the Life Flight bill, which he has disputed, contending that the transport was unreasonable. The Idaho Industrial Commission determined that the Life Flight transport was reasonable under Idaho Code section 72-432(1). Stokes appealed the Commission's judgment. Finding no reversible error, the Supreme Court affirmed. View "Chavez v. Stokes" on Justia Law