Justia Idaho Supreme Court Opinion Summaries

Because no final judgment dissolving the marriage and no judgment regarding custody had ever been entered in this divorce action during the four-year period after the divorce trial, the Supreme Court dismissed the appeal because it did not qualify for an appeal by permission. After the appeal was dismissed, the magistrate court entered a partial judgment purporting to retroactively divorce the parties four years earlier and a partial judgment regarding custody and the division of property and debts. The appellant then filed a motion seeking reconsideration of the order dismissing the appeal. The Supreme Court denied that motion, vacated the partial judgment retroactively terminating the parties’ marriage, and direct the magistrate court to enter a new partial judgment dissolving their marriage. View "Cook v. Arias" on Justia Law

Respondents Alan and Marilyn Golub obtained a judgment against appellants and recorded the judgment. Kirk-Hughes Development, LLC (KHD), owned a parcel of real property in the county and therefore the judgment constituted a lien against its property. KHD claimed to have executed a deed of trust on the property in favor of Kirk-Scott, Ltd. (KS), several years before Golubs acquired their lien. Golubs filed an action for declaratory judgment, seeking a ruling that their judgment lien had priority over KS’ unrecorded deed of trust. The district court granted summary judgment to Golubs, finding that their lien had priority. KHD and the other appellants appealed that decision. After review, the Supreme Court found no reversible error, and affirmed the district court's judgment. View "Golub v. Kirk-Hughes Development" on Justia Law

This appeal arose from three mechanic’s liens that Keith Sims, dba Kasco of Idaho, LLC (“Sims”) filed on property that Dan Jacobson, Sage Holdings, LLC, Steven G. Lazar, the Mitchell A. Martin and Karen C. Martin Family Trust, and Devon Chapman (collectively “the Jacobson group”) had an interest in. The district court granted summary judgment to the Jacobson group on Sims’s lien foreclosure and quantum meruit claims. The court also awarded the Jacobson group their attorney fees and costs. Sims appealed the district court’s (1) grant of summary judgment on the lien foreclosure; (2) denial of a continuance at the quantum meruit hearing; and (3) award of attorney fees. Sims later withdrew his appeal on the lien foreclosure and continuance issues, so the only issue remaining was the district court’s grant of attorney fees to the Jacobson group. Finding no reversible error with regard to the fees issue, the Supreme Court affirmed the district court’s award. View "Sims v. Jacobson" on Justia Law

The issue this case presented for the Supreme Court's review centered on a dispute between two creditors as to whose claim against their debtor's property has priority. Respondents Alan and Marilyn Golub recorded a judgment against their judgment debtor, Kirk-Hughes Development, LLC (KHD), giving Golubs a judgment lien on property owned by KHD in Kootenai County. KHD claimed to have executed a deed of trust on the property in question several years before Golubs acquired their lien. The beneficiary of the deed of trust was another defendant, Kirk-Scott, Ltd. (KS). The district court granted summary judgment to Golubs, finding that Golubs' duly recorded judgment lien had priority over KS' prior, unrecorded deed of trust. KS appealed. Finding not reversible error, the Supreme Court affirmed the district court in all respects. View "Alan Golub v. Kirk-Scott, LTD" on Justia Law

Defendant David Knutsen appealed a jury verdict finding him guilty of four counts of sexual abuse of a vulnerable adult. Defendant argued on appeal that the term of the grand jury that indicted him had already expired, that the statute defining the crimes was unconstitutional, that there was insufficient evidence to support the jury’s verdict, and that his conviction should be for only one count because his conduct constituted one continuous act. Finding no reversible error, the Supreme Court affirmed the district court. View "Idaho v. Knutsen" on Justia Law

In 2009, Mosell Equities filed this action against Berryhill & Company and Mr. and Mrs. Berryhill (collectively "Berryhill"). The complaint alleged that Mosell Equities had loaned money to Berryhill and that it had failed to repay the loans. The case was tried to a jury in September 2009. During the trial, Messrs. Mosell and Berryhill provided widely divergent testimony regarding their relationship, whether the checks were actually loans, and what had transpired. The jury returned a verdict in favor of Berryhill on the claims regarding the alleged loans. Mosell Equities filed a motion for a judgment notwithstanding the verdict or, in the alternative, for a new trial. The district court granted a judgment notwithstanding the verdict as to part of a claim for relief, and the Supreme Court reversed that order on appeal. On remand, the district court granted Mosell Equities a new trial, and Berryhill appealed. After review, the Supreme Court reversed: by granting the motion for a new trial in order to enable Mosell Equities to try the case on a theory it did not raise in the first trial, the district court abused its discretion by failing to act consistently with the applicable legal standards. The district court was directed to enter judgment consistent with the original jury verdict. View "Mosell Equities, LLC v. Berryhill & Co., Inc" on Justia Law

Jane Doe’s three-year-old son was found wandering in a truck stop parking lot, where trucks were entering and leaving. He had walked from a recreational vehicle 1.9 miles away, where Jane Doe and her boyfriend were living. When the police went to the recreational vehicle, they observed that there was insufficient food appropriate for a child. Jane Doe gave conflicting accounts as to why the child had been unsupervised. The police declared the child in imminent danger and took him into shelter care. The following day, proceedings involving the child were commenced under the Child Protective Act. The Department of Health and Welfare filed a case plan which set forth tasks to be accomplished by Jane Doe for the purpose of reuniting Jane Doe with her son. The attempt at reunification was not successful, and the Department filed a petition to terminate Jane Doe’s parental rights in her son. Finding that Jane Doe failed to show that the magistrate court erred in terminating her parental rights, the Supreme Court affirmed termination. View "Dept of Health & Welfare v. Jane Doe (2014-22)" on Justia Law

Husband and wife Walter and A.K. Lienhart Minnick sued the law firm Hawley Troxell Ennis and Hawley, LLP (Hawley Troxell), alleging negligence in rendering services in connection with a real estate development project. On motion of Hawley Troxell for summary judgment, the district court dismissed the action as time-barred under the applicable statute of limitations. On appeal, the Minnicks argued that the district court erred in calculating accrual of their action under the statute, Idaho Code section 5-219(4). After review, the Supreme Court agreed, reversed the trial court's judgment, and remanded the case for further proceedings. View "Minnick v. Hawley Troxell Ennis" on Justia Law

This appeal centered on the attempted foreclosure of two mechanic's liens on property encumbered by deeds of trust. In "ParkWest Homes, LLC v. Barnson," 302 P.3d 18 (2013) (ParkWest II), the Idaho Supreme Court held that an action to foreclose a mechanic's lien on property encumbered by a deed of trust must "name the trustee who holds legal title to the property" within the six-month statutory limitation to lien enforcement. Appellant ACI Northwest Inc. challenged the holding from ParkWest II after the district court determined that ACI lost its mechanic's liens for failing to name the trustees in its foreclosure action against Respondents Monument Heights LLC, Dan Jacobson, Sage Holdings LLC, Steven Lazar, the Mitchell Martin and Karen C. Martin Family Trust dated August 9, 2005, Devon Chapman, HLT Real Estate LLC, Anthony St. Louis, Andrea Stevens, and Lilly Properties Inc. (collectively "the Monuments Heights group"). Due to this determination, the district court granted summary judgment in favor of the Monuments Heights group. ACI appeals to this Court. Finding no reason to disturb the holding in ParkWest II, and finding no reversible error in the trial court's decision in this case, the Supreme Court affirmed. View "ACI Northwest, Inc. v. Monument Heights, LLC" on Justia Law

Claimant-appellant Terri Boyd-Davis filed for unemployment compensation on January 27, 2013, and began receiving benefits. IDOL claims to have mailed an "online review letter" to Boyd-Davis' listed address on March 6, 2013. The Online Review Letter indicated that Boyd-Davis had been selected to provide additional information concerning her unemployment insurance claim for the week of March 2, 2013. The Online Review Letter instructed Boyd-Davis that she would need to complete work search documentation online. The letter also indicated that failure to complete the online eligibility review by 5:00 p.m. on March 15, 2013, would result in the denial of her benefits. Boyd-Davis claimed she did not receive the Online Review Letter. When Boyd-Davis had not provided the requested information by the deadline, IDOL issued an Eligibility Determination on March 19, 2013, indicating that Boyd-Davis had failed to complete the online eligibility review and as a result was ineligible for benefits effective March 10, 2013. Boyd-Davis filed a protest. A telephonic hearing was scheduled for April 18, 2013. On April 1, 2013, Boyd-Davis provided the information IDOL had requested in the Online Review Letter. As soon as the requested information was provided, Boyd-Davis' benefits were reinstated for the week beginning March 31, 2013. However, benefits were not reinstated for the period of March 10 through March 30, 2013. Boyd-Davis proceeded with the April 18, 2013, hearing seeking restoration of her benefits for the period of March 10 through March 30, 2013. Following the hearing, an IDOL Appeals Examiner affirmed the original eligibility determination and concluded that Boyd-Davis' benefits had been properly denied. After review, the Supreme Court reversed and remanded the case for further proceedings, finding that Boyd-Davis presented evidence that "would permit reasonable minds to conclude that the Online Review Letter was not received." The Court concluded that the Commission erred in its application of the presumption of delivery articulated in Idaho Code section 72-1368(5) of the online letter. Furthermore, the Commission abused its discretion in determining that Boyd-Davis was ineligible for unemployment benefits for the period from March 10, 2013, through March 30, 2013. View "Boyd-Davis v. Macomber Law, PLLC" on Justia Law