Justia Idaho Supreme Court Opinion Summaries

Joan Thrall appealed an Idaho Industrial Commission decision denying her unemployment benefits. The Commission concluded that Thrall was not entitled to benefits because she voluntarily resigned from St. Luke's Regional Medical Center without good cause. Thrall timely appealed, arguing that she was discharged and that St. Luke's failed to show the discharge was for misconduct. The Supreme Court reversed and remanded this case for further proceedings. Because the Commission's factual findings demonstrate that Thrall satisfied her burden to show that she was discharged, Thrall was entitled to benefits unless the discharge was for misconduct in connection with her employment, with St. Luke's carrying the burden to show the discharge was for misconduct. When the Commission mistakenly concluded that Thrall voluntarily resigned, it improperly placed the burden on Thrall to show that she was not discharged for misconduct. "Though the Commission's order includes a variety of statements regarding misconduct and Thrall's errors in the performance of her job duties, it is unclear to what extent those statements were a consequence of its misallocation of the burden of proof." View "Thrall v. St. Luke's Regional Med Cntr" on Justia Law

This case stemmed from the Board of County Commissioners for Fremont County's efforts to prepare an official county road map that complied with Idaho Code section 40-202. The Board adopted an Official Fremont County Road Map. The Map depicted the North Road as a county road. Property owners along the North Road petitioned for judicial review. The district court determined the Board lacked substantial and competent evidence to designate the North Road as a county road and vacated the Board's decision. The Board appealed. Finding no reversible error in the district court's decision, the Supreme Court affirmed. View "Flying "A" Ranch v. County Commissioners of Fremont County" on Justia Law

This case concerned three small, adjacent parcels of land in Bear Lake County which lined up in a north to south direction and are bordered by State Highway 89 on the west and Bear Lake on the east. In 1998, the northern parcel was owned by Peggy and David Everton; the middle parcel was owned by Annette and Sterling Wallentine; and the southern parcel was owned by Jeanne Macvicar. Historically, Macvicar had accessed her property by a driveway that went through the Everton and Wallentine properties. The driveway left State Highway 89 at the northwestern edge of the Everton parcel, traveled along the western edge of the Everton and Wallentine parcels, and terminated at Macvicar's property. in 1998, Macvicar filed a complaint against the Evertons and Wallentines, requesting that the district court declare an easement existed along the western edge of their parcels. In 2000, the parties filed a Stipulation for Settlement. The district court accepted the stipulation and entered its Judgment and Decree of Quiet Title (the 2000 Judgment). The Evertons, the Wallentines, and Macvicar subsequently sold their parcels to the parties to this appeal. Macvicar sold her property to Jim and Maryann Plane, who transferred the property to the Jim and Maryann Plane Family Trust (the Trust). The Planes had actual knowledge of the 2000 Judgment and the Stipulation when they purchased Macvicar's property. Jason and Janae Skinner purchased the parcels owned by the Evertons and Wallentines. This controversy arose after September 27, 2012, when the Idaho Transportation Department (ITD) wrote the Skinners a letter demanding that the Skinners remove their "illegal" driveway. However, the letter also enclosed a permit application for the Skinners to submit which would "allow for the continued use of this currently illegal access." On April 1, 2013, the Trust filed a motion, pursuant to I.R.C.P. 60(b)(4), requesting that the district court void three sentences of the 2000 Judgment. The Trust argued these provisions were void because the district court lacked personal and subject matter jurisdiction to address the State's right-of-way because the State was not a party to the litigation. The effect of eliminating these three sentences would be to expand the width of the easement over the Skinners' parcels from a maximum of five feet to ten feet. On April 18, 2013, the Skinners filed an application with ITD, seeking permission to continue to access the State right-of-way for purposes of a driveway. ITD issued a permit authorizing the Skinners and the Planes to use up to five feet of the State right-of-way. The district court denied the Trust's motion, and the Trust appealed. Finding no reversible error in the district court's decision, the Supreme Court affirmed it. View "Plane Family Trust v. Skinner" on Justia Law

Jane Doe appealed an order terminating her parental rights to her son, TSD. Because TSD was an "Indian child" as defined by the Indian Child Welfare Act, the magistrate court was required to make findings in addition to those required by Idaho law. Among other findings, the Department of Health and Welfare (DHW) was required to satisfy the court that it made "active efforts" to "prevent the breakup of the Indian family." On appeal, Doe argued that the magistrate court erred in finding that DHW made such efforts and erred in failing to make that finding by clear and convincing evidence. Finding no reversible error, the Supreme Court affirmed the magistrate court's decision terminating Doe's parental rights. View "In re Termination of Parental Rights of Jane (2014-23) Doe" on Justia Law

A jury found defendant Joseph Thomas, Jr. guilty of first degree murder for the strangulation death of his ex-wife, Beth Irby Thomas in 2011. A friend of Defendant testified that at about 12:30 a.m. the following day, Defendant came to the friend’s home and stated that he had strangled the decedent. After Defendant left, the friend called 911. The first police officer to arrive at the decedent’s home found her with a leather belt cinched tightly around her neck. The belt was Defendant’s, and he was standing outside her house when the police arrived. After review of defendant's arguments on appeal, the Supreme Court concluded that because the district court erroneously excluded evidence that could have corroborated the defendant’s version of what had occurred and the State did not show that such error was harmless, the Court vacated the jury verdict and the judgment and remanded this case for further proceedings. View "Idaho v. Thomas" on Justia Law

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