Justia Idaho Supreme Court Opinion Summaries

This case arose out of a failed development project undertaken by BRN Development, Inc. in Coeur d’Alene. The project was for the development of a high-end 325-unit residential and golf course community on the west side of Lake Coeur d'Alene known as "Black Rock North." American Bank was the lender for this project. The Bank ultimately brought a foreclosure action against BRN. BRN brought a cross-claim against Taylor Engineering, Inc., alleging negligence for its role in the development. Taylor recorded a lien against the development. BRN defaulted on the loan, and the Bank named BRN, Taylor, and any other entity claiming an interest in the development. Taylor made a demand on BRN for payment for services rendered. The demand stated that Taylor would "complete the necessary documents" and request the necessary signatures from the local government entities involved in the final PUD approval. Taylor advised BRN that "if the final subdivision approval is not completed and recorded by May 29, 2009, the PUD and preliminary plat approval will expire, the PUD and plat will not vest in the recorded ownership to the real property involved, and the property will revert to its prior zoning and density." This statement was erroneous; it was undisputed that the final plat did not need to be recorded by May 29 in order to vest the PUD. In BRN's cross-claim against Taylor, it alleged professional negligence, negligent and intentional misrepresentation, and failure to disclose based on the erroneous statement Taylor made in its demand letter. The district court separated the claims between Taylor and BRN from the remainder of the American Bank litigation and ultimately held that Taylor was not liable to BRN. BRN appealed. The Supreme Court found no reversible error with the district court's judgment that BRN failed to meet its burden of proving its claims against Taylor, and affirmed that court's judgment. View "American Bank v. BRN Dev." on Justia Law

Defendant-appellant Felicity Haynes was arrested by a state trooper for driving while under the influence of alcohol. Defendant appealed a district court order affirming the orders of the magistrate court, arguing the magistrate court erred in: (1) granting a continuance to the State due to the unavailability of a witness; (2) refusing to appoint a separate judge to hear a request for funds for the defense; (3) denying a motion in limine to exclude the results of a breath test on the ground that procedures for administering the test had not been properly adopted by the Idaho State Police; and (4) finding defendant’s consent to the breath test was invalid because it was obtained by the threat of a monetary penalty and loss of her driver’s license for one year. Finding no reversible error, the Supreme Court affirmed the order. View "Idaho v. Haynes" on Justia Law

Defendant Bryann Lemmons was convicted by jury on two counts of trafficking in methamphetamine by delivering methamphetamine and two counts of trafficking in methamphetamine by conspiring to deliver methamphetamine. The charges arose from two instances in which Defendant, with the assistance of a co-conspirator, agreed to, and then delivered methamphetamine to a confidential informant. The actual weight of the methamphetamine delivered was less than 28 grams. However, the confidential informant testified that in each transaction Defendant represented that she was delivering an ounce of methamphetamine. In addition, the confidential informant testified that Defendant, through the co-conspirator, had agreed to sell one and one-half ounces of methamphetamine, but when the transaction occurred he was told that Defendant could only obtain one ounce and would provide the half ounce later. Before Defendant was sentenced, she moved for a judgment of acquittal on the counts relating to trafficking on the ground that there was insufficient evidence admitted during the trial to show that one ounce equaled 28 grams or more. After briefing and argument, the district court granted a new trial with respect to the jury questions of whether the person who sold or delivered the methamphetamine represented that it weighed 28 grams or more and with respect to the two charges of trafficking by conspiracy to deliver methamphetamine. The State then filed a notice of appeal. The following day, Defendant filed a motion for reconsideration, asking for judgments of acquittal rather than a new trial. After briefing and argument, the district court granted judgments of acquittal as to the charges of trafficking by conspiring to deliver methamphetamine and as to the issue of whether the person who sold or delivered the methamphetamine had represented that it weighed 28 grams or more. Defendant then filed a notice of cross-appeal. The Supreme Court, after review, concluded the district court's order granting the motion for reconsideration was void. Furthermore, the Court found that testimony that Defendant represented that the weight of the drug was one ounce was, as a matter of law, testimony that Defendant represented the weight was more than 28 grams (an ounce equals slightly more than 28 grams). "A witness need not testify in the wording of a criminal statute in order to prove a violation of that statute as long as the witness’s testimony shows a violation of the statute. It is the substance of the testimony, not the particular words used, that is material." The Court found the evidence presented at trial sufficient to support conviction on trafficking. The Court reversed the grant of a new trial and remanded this case for sentencing on all trafficking charges. View "Idaho v. Lemmons" on Justia Law

Defendant-appellant Joseph Herrera appealed his conviction of second-degree murder. At the time of the shooting, Herrera and his girlfriend Stefanie Cormack had been dating for three to four months and were living together in Herrera’s parents’ house. For some time leading up to the shooting, Herrera was in possession of two of his father’s handguns. On December 24, 2011, Herrera was out late and arrived home before dawn on Christmas morning, having used both methamphetamine and marijuana that morning. Herrera testified that when he arrived home he went to sleep for a few hours and woke up at roughly 10:00 a.m. When Herrera and Stefanie woke up Christmas morning, they began arguing about Facebook messages Stefanie had exchanged with other men and the fact that Herrera did not want to go to Stefanie’s mother’s house for Christmas. Herrera testified the gun that killed Stefanie was in the drawer of a nightstand next to his bed the morning of the shooting. He testified that during the course of their argument, Stefanie was packing her things to go to her mother’s house and that he was handling the gun. Herrera claimed that Stefanie was packing to go to her mother’s house only to celebrate Christmas, but the State’s theory was that she was packing to leave Herrera and end the relationship. He gave varying accounts of what exactly caused the gun to discharge. Although Herrera testified he did not remember the gun coming into contact with Stefanie’s forehead, testimony from the emergency room physician who first examined Stefanie and from the county medical examiner strongly evidenced that the gun was pressed against Stefanie’s forehead when it fired. By all accounts, Herrera was extremely upset after the fatal shot was fired. The jury was instructed on second-degree murder, voluntary manslaughter, and involuntary manslaughter. Herrera was convicted of second-degree murder and sentenced to life in prison with twenty-two years fixed. He timely appealed. Herrera argues (1) there was insufficient evidence to support a finding of malice, and (2) improper testimony from a number of witnesses unfairly prejudiced his case. Upon review of the trial court record, taking Herrera's second argument first, the Supreme Court concluded that indeed certain testimony offered at trial suggesting he was abusive was highly prejudicial in light of the other evidence offered. "Even more concerning is the rather transparent violation of the limitations imposed by the district court on the testimony of [certain] witnesses." As such, the Court vacated the judgment of conviction and remanded this case for further proceedings. View "Idaho v. Herrera" on Justia Law

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