Justia Idaho Supreme Court Opinion Summaries

This appeal stemmed from the sale of dairy cattle that were subject to Appellant Farmers National Bank’s (FNB) perfected security interest and Respondent J&M Cattle Company’s (J&M) agister’s lien. The net sale proceeds received from the sale of the dairy cattle were insufficient to satisfy both FNB’s perfected security interest and J&M’s agister’s lien. J&M filed an action for declaratory relief to resolve FNB’s and J&M’s competing interests. Although FNB’s perfected security interest had a priority date that predates J&M’s lien, the district court determined that J&M’s lien had priority over FNB’s perfected security interest. The district court entered a final judgment in favor of J&M, and FNB appealed. Finding no reversible error, the Supreme Court affirmed the district court's decision. View "J&M Cattle Co v. Farmers National Bank" on Justia Law

John Doe was the biological father of T.C. Doe was a juvenile when T.C. was born. Doe paid Mother a total of $52.00 in child support, despite a court order requiring him to pay Mother child support of $253.00 per month. Doe owed approximately eight thousand dollars in unpaid child support. Doe never provided T.C. or Mother with any alternate form of support such as clothing, diapers, or food. During T.C.’s life, Doe was regularly incarcerated and had no contact with T.C. for months at a time; including a substantial period of time that the child protection proceedings were ongoing. Doe has been unable to maintain employment or a home and typically resides in the homes of various girlfriends. Doe was addicted to methamphetamine and, when not in custody, he used methamphetamine. Doe had an extensive criminal record and has been a defendant in more than forty criminal matters. A petition was filed under the Child Protective Act (CPA) asking a magistrate court to place T.C under the supervision of the Department. The same day, the magistrate court ordered the removal of T.C. on the basis that continuation in the home would be contrary to T.C.’s welfare. The magistrate court placed T.C. in the care of the Department of Child Services. Doe learned of the Department’s petition when his aunt informed him of the proceedings. His parental rights to T.C. were ultimately terminated on grounds that the trial court found Doe neglected T.C., and that it was in the child's best interests to have Doe's parental rights terminated. Doe appealed, but finding no reversible error, the Supreme Court affirmed the trial court's order. View "Health & Welfare v. John Doe (13-29)" on Justia Law

Claimant-appellant Francisco Serrano worked as a framer for Four Seasons Framing from 2001 to 2008. He was injured in two work-related accidents. He appealed an Industrial Commission finding that he failed to prove that the condition for which he was claiming benefits was caused by the two accidents in 2004 and 2008. Finding no reversible error in the Industrial Commission's order, the Supreme Court affirmed. View "Serrano v. Four Seasons Framing" on Justia Law

At the center of this appeal was ABC Agra, LLC's action seeking a declaratory judgment against Critical Access Group, Inc. ("CAG") regarding the enforceability of a real property use restriction. Because there were no existing or proposed uses that implicated the restriction, the district court determined that the claim was not ripe and granted CAG's 12(b)(6) motion to dismiss. Finding no reversible error, the Supreme Court affirmed this dismissal. View "ABC Agra v. Critical Access Group" on Justia Law

This appeal stemmed from a 1983 Ground Lease of over four acres of property in Pocatello which Quail Ridge Medical Investors, LLC leased from Pocatello Hospital, LLC (d/b/a/ Portneuf Medical Centers, LLC (PMC)). Quail Ridge appealed a declaratory judgment which held that 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 of 2010 to 2012. Finding no reversible error, the Supreme Court affirmed. View "Pocatello Hospital v. Quail Ridge Medical Investor" on Justia Law

Appellant Billy J. Bringman appealed an Idaho Industrial Commission decision in favor of Respondents New Albertsons, Inc. and the Idaho Department of Labor. The Commission determined Bringman willfully made a false statement or failed to report a material fact regarding his separation from Albertsons to obtain unemployment benefits from the Department and ordered Bringman to repay the benefits he received and pay a civil penalty. Finding no reversible error with that decision, the Supreme Court affirmed. View "Bringman v. New Albertsons, Inc." on Justia Law

This appeal arose from a Snake River Basin Adjudication (SRBA) court decision on whether Idaho law required a remark authorizing storage rights to "refill,"under priority, space vacated for flood control. The SRBA court concluded that a remark was not necessary because a storage water right that is filled cannot refill under priority before affected junior appropriators satisfy their water rights once. The court declined to address when the quantity element of a storage water right is considered filled. Seven Magic Valley irrigation districts and canal companies (collectively the "Surface Water Coalition") appealed this decision in Docket No. 40974. The Boise Project Board appealed this decision in Docket No. 40975. Because both cases appealed the same decision of the SRBA court and had significant overlap, the Supreme Court addressed them together in this opinion, and held that the SRBA court abused its discretion in designating the question of whether Idaho law required remark as Basin-Wide Issue 17. The SRBA court did not abuse its discretion by declining to address when the quantity element of a storage water right is considered filled or in stating that such a determination was within the Director's discretion. View "In re: SRBA" on Justia Law

The district court awarded attorneys fees to Lynn Urrutia against appellants Ty Harrison and Robert Schutte under Idaho Code section 12-120(3), 12-121, and 12-123, as well as sanctions against the appellants' attorney under Idaho Code section 12-123 and I.R.C.P. 11. These awards stemmed from the divorce of Lynn and Johnny Urrutia in 2007 and the divorce decree's division of the marital property. "'The most egregious conduct of defendants,' in the district court's opinion, was the filing of the Third Amended Counterclaim, which 'states two causes of action against Lynn: (1) that the second lien has priority over Lynn's claims and (2) that Lynn as the owner of the property was unjustly enriched.' The judge noted that the Second Lien, with a priority date of 2008, could not conceivably be higher in priority than Lynn's deed of trust, which was recorded in 2007. He observed that the Appellants knew the $220,000 claimed in the Second Lien, like the First Lien, contained numerous items that did not constitute improvements to the arena property and were not lienable under the mechanic's lien statutes. And, even though the Appellants knew that the owner of record of the arena property was Sundance Arena, LLC, they sought personal recovery against Lynn under an unjust enrichment theory for improvements made to the property, which she did not own." Finding no reversible error, the Supreme Court affirmed the award of fees and sanctions to Lynn Urrutia. View "Urrutia v. Harrison" on Justia Law

Pro se claimant Chance LeBow appealed an Industrial Commission's holding that he quit his job with Right Now, Inc. without good cause and that he willfully failed to report material facts for the purpose of collecting unemployment benefits. Finding no reversible error, the Supreme Court affirmed. View "Lebow v. Commercial Tire" on Justia Law

Richard Giesler and Idaho Trust Deeds, LLC appealed a district court's judgment declaring the rights and obligations on a contract. This case arose out of several oral and written agreements between Giesler and Gregory Hull that related to purchasing and subdividing property. After a bench trial, the court found that Hull sold the property to Giesler, but the parties had a later oral contract where Hull promised to pay off Giesler's loans in exchange for half of the subdivision's net profits. The court held that neither party materially breached the contract and ordered Hull to timely pay Giesler's loans and Giesler to complete the subdivision within certain deadlines. On appeal, Giesler argued Hull failed to prove damages and the district court's remedies were erroneous. Upon review, the Supreme Court affirmed the district court in part, vacated in part, and remanded the case for further proceedings. The Supreme Court found that substantial and competent evidence supported the district court's findings of fact, but that the district court erred in its remedies. The Court vacated the portions of the district court's decision regarding: (1) the conversion payment of half the irrigation equipment's value; (2) the deadlines for completing Parcels 2 and 3; and (3) the provisions that order consequences to encourage performance under the contract. View "Hull v. Giesler" on Justia Law