Justia Idaho Supreme Court Opinion Summaries

Gordon, Thomas, and Brent Arave appealed a district court’s decision to dismiss their motion to compel International Real Estate Solutions, Inc. to record a satisfaction of judgment. On a motion for reconsideration, the district court concluded that a final default judgment entered against the Araves in Utah for breach of a guaranty and fraud, which was domesticated in Idaho under Idaho Code section 10-1302, had not been satisfied by the foreclosure sale of property not owned by the Araves. The Araves argued on appeal to the Idaho Supreme Court that the judgment against them should have been offset by the value of the property that was foreclosed upon. Finding no reversible error in the district court's decision, the Supreme Court affirmed. View "Int'l Real Estate Solutions, Inc. v. Arave" on Justia Law

John and Jane Doe are the biological father and mother of two boys: B.D., born in 2008, and T.D., born in 2011. Doe and Jane Doe divorced in 2009. This appeal centered on the termination of John Doe’s parental rights. Beginning July 12, 2012, the Idaho Department of Health and Welfare began working with Doe to address continuing safety concerns for the children. These concerns included: lack of supervision, neglect, and physical abuse. There were times when Doe did not know the whereabouts of the children, could not provide the names of occupants of his residence, and appeared to be under the influence of drugs. A service provider, Northwest Neurobehavioral, reported that B.D. had been missing counseling and speech therapy appointments. Later that year, Doe tested positive for methamphetamine. The issues this case presented on appeal to the Supreme Court were: (1) whether there was substantial and competent evidence that Doe neglected his children; and (2) whether the magistrate court erred when it found termination of Doe’s parental rights to be in the best interest of Doe’s children. Finding no reversible error, the Supreme Court affirmed. View "In re Termination of Parental Rights of John Doe (2014-15)" on Justia Law

The issue this appeal presented for the Supreme Court's review was whether Jeff and Karen Owen's deed should have been reformed to grant an easement across their property for the benefit of Brent and Moura Regan. The Regans ownedof a 50.55-acre parcel of land in Kootenai County. The Owens owned an adjoining 10.7 acre parcel to the east of the Regans. The Owens’ property was acquired by two separate conveyances: they acquired a 10.3-acre parcel from David and Helen Hanna by a warranty deed in 2003 (Owen Parcel); and they acquired a 0.4-acre parcel from Kootenai County by a 2005 deed (Orphan Parcel). The Orphan Parcel adjoined the northern boundary of the Owen parcel. The Owens moved for summary judgment seeking a denial of the Regans’ claim for reformation. The district court granted the Regans’ motion and denied the Owens’ motion, holding that the Regans’ claim for reformation based upon a mutual mistake was not barred by the statute of limitations and that there was a mutual mistake between the Original Grantors and a predecessor-in-interest as to the northern boundary of the parcel that the the predecessor purchased. It also held that the Owens were on inquiry notice of that mistake when they purchased the Owen Parcel and later the Orphan Parcel. Finally, the court held that even if they did not have notice of the mistake, granting the Regans an easement across the Owens’ property would not prejudice them. The Owens appealed. The Supreme Court vacated and remanded for further proceedings: the trial court did not cite any authority holding that a court can relocate the easement to another portion of the Owens’ land merely because it did not believe that doing so would prejudice them. Furthermore, there was no finding by the district court that the alleged prescriptive easement across the Orphan Parcel increased its value. View "Regan v. Owen" on Justia Law

In 2009, Andy and Ronna Bond filed an action to be appointed guardians of two children who were at that time two and eight years of age. Mother Amber Round was initially represented by counsel, but counsel was permitted to withdraw and she did not file a timely notice of how she would proceed. Her default was entered on a few months later, and she filed a motion to set aside the default on the same day. The following day, she also filed a notice of appearance, informing the magistrate court that she would be representing herself. She claimed that she had moved and did not receive notice of her attorney’s withdrawal. The magistrate court held a hearing on Mother’s motion to set aside the default. The court found, considering the evidence presented and Mother’s credibility and demeanor, that service was properly made upon her. It therefore denied her motion to set aside the default. The magistrate court then appointed the Guardians on the ground that Mother and father Ty Round were unable to provide the children with a stable home environment. Father and Mother were later divorced. Mother appealed to the district court, and filed a petition to terminate the guardianship and a motion to allow for visitation. These motions were transferred to the magistrate division of the district court, where Mother's petition to terminate guardianship was denied, but she was allowed visitation. The Guardians appealed the grant of visitation and the magistrate court’s sua sponte denial of attorney fees to both parties without a hearing. The Supreme Court agreed that the magistrate court did not err in granting the mother visitation with her children, but on different grounds than asserted by the district court. The Court reversed the district court’s decision that the magistrate court did not err in denying an award of attorney fees sua sponte without the opportunity for a hearing. View "Re: Gurarianship: Bond v. Round" on Justia Law

Charles Bell was employed by Sears from September 25, 2012, to May 16, 2013. During that period, Bell regularly filed for unemployment benefits with the Idaho Department of Labor (DOL). He received benefits for each week beginning with the week ending on Sept. 29, 2012, through the week ending on March 23, 2013. On March 26, 2013, the DOL discovered discrepancies between the weekly gross wages reported by Bell in his unemployment filings and the gross wages reported to the DOL by Sears. Based on the information provided by Bell, the DOL determined that Bell willfully misstated his gross wages for nineteen weeks in which he received benefits and that he was ineligible for benefits for nine weeks in which he claimed to have worked part-time hours despite working at least forty hours. Bell was disqualified from receiving benefits for fifty-two weeks, ordered to repay benefits he received for the relevant periods, and ordered to pay penalties for willfully misrepresenting his gross wages and the hours he worked in particular weeks. Bell appealed the Idaho Industrial Commission's holding that he willfully made false statements or willfully failed to report material facts for the purpose of obtaining unemployment benefits. Because the Commission’s decision was supported by substantial and competent evidence, the Supreme Court affirmed. View "Charles Bell v. Idaho Dept. of Labor" on Justia Law

This appeal stemmed from a 1983 Ground Lease of property in Pocatello which Quail Ridge Medical Investors, LLC (Quail Ridge) leased from Pocatello Hospital, LLC d/b/a Portneuf Medical Centers, LLC (PMC). Previously, Quail Ridge appealed a declaratory judgment entered by the district court which found PMC was entitled to an adjustment in the annual rent owed by Quail Ridge from $9,562.50 annually to $148,500 annually, and that Quail Ridge was obligated to pay PMC $416,812.50 in rent for the period at issue. The Supreme Court affirmed the court’s declaratory judgment. While the first appeal was pending, PMC filed a new action seeking payment of the adjusted rents. In the second action, the district court found on summary judgment that Quail Ridge breached the Ground Lease by failing to pay the adjusted rents. Quail Ridge appealed, arguing the breach of contract and breach of guarantee claims are barred under res judicata. Finding no reversible error, the Supreme Court affirmed. View "Pocatello Hospital v. Quail Ridge Medical Investor" on Justia Law

This case arose out of a professional negligence claim relating to a life insurance policy. Bill Gailey purchased the life insurance policy from Kim Whiting in 2010. In August 2011, Gailey cashed in the life insurance policy after receiving advice from Whiting to that end. Gailey suffered negative tax consequences from cashing in the policy and subsequently filed a complaint against Whiting alleging Whiting was negligent when he advised Gailey to cash in his policy without warning him of the potential tax consequences. Whiting subsequently moved the court to dismiss the action for lack of personal jurisdiction because Whiting no longer lived in Idaho, Gailey was a resident of Oregon, and the alleged tort did not occur in Idaho. The district court granted Whiting’s motion and Gailey appealed to this Court. Finding no reversible error, the Supreme Court affirmed. View "Gailey v. Whiting" on Justia Law

In 2012, Idaho State Police stopped defendant-respondent Derek Arrotta for a traffic violation. At the end of the stop, defendant was issued a citation for misdemeanor driving while under the influence of alcohol. Defendant filed a motion to suppress “based on violations of the defendant’s right to be free from unreasonable search and seizure, right to remain silent, right to counsel, and related constitutional protections under the State of Idaho Constitution and the United States Constitution,” but the motion did not identify what evidence he wanted to suppress or how his rights were allegedly violated. The parties agreed to postpone the matter until the United States Supreme Court decided "Missouri v. McNeely." After the Supreme Court issued its opinion in McNeely, the magistrate court held an evidentiary hearing on the motion to suppress. The trooper testified to the events and stated that he did not recall telling Defendant that he did not have a right to refuse the blood test. However, he also testified that he told Defendant that if he refused the breath test, the trooper would get a blood draw. Defendant testified that he refused the breath test, but not the blood test. He testified that at the hospital he asked if he could refuse the blood test, “but they pretty much said no.” When asked if the trooper told Defendant he could not refuse the blood draw, Defendant answered, “Yeah, something to that extent.” The magistrate court did not resolve the factual dispute regarding whether Defendant was told that he could not refuse the blood draw. Rather, it held that statutory implied consent was insufficient by itself to constitute consent to a search in the form of a blood draw; that express consent was required. Based upon that holding, the court granted Defendant’s motion and issued an order suppressing the blood test results. The State appealed to the district court. The district court affirmed the suppression order, holding that statutory implied consent to a blood draw is revocable. Finding no reversible error, the Supreme Court affirmed the district court. View "Idaho v. Arrotta" on Justia Law

"Mother" Jane Doe appealed a magistrate court’s judgment that terminated her parental rights to three of her children. The magistrate court concluded that the Idaho Department of Health and Welfare (“IDHW”) proved by clear and convincing evidence that Mother and father John Doe neglected their children and that terminating parental rights was in the children’s best interests. Mother argued on appeal that IDHW did not show clear and convincing evidence, the court failed to properly consider her disability, and IDHW did not make reasonable efforts to help her comply with her case plan. Finding no reversible error, the Supreme Court affirmed the magistrate court’s judgment terminating Mother’s parental rights. View "Idaho Dept. of Health & Welfare v. Jane Doe (2014-17)" on Justia Law

This case centered on a proposed easement over a rough, relatively unimproved, single-vehicle dirt road that travels over property the City of Twin Falls owned in the Snake River Canyon, south of the Snake River. H.F.L.P., LLC owned three parcels in the Snake River Canyon, west of Rock Creek. At trial, H.F.L.P. claimed it had a prescriptive easement and an easement by necessity over the property, but the district court ultimately entered judgment in favor of the City. H.F.L.P. argued on appeal that the district court: (1) did not have subject matter jurisdiction over the case; (2) erred when it held that H.F.L.P. failed to prove a prescriptive easement and an easement by necessity; and (3) erred when it admitted photographic overlays over H.F.L.P.’s objections at trial. Finding no reversible error, the Supreme Court affirmed. View "H.F.L.P. v. City of Twin Falls" on Justia Law