Justia Idaho Supreme Court Opinion Summaries

This appeal arose from the dismissal of a petition for adoption filed by Jane Doe, the long-time domestic partner of Jane Doe I. Jane Doe I is the legally recognized parent of the two children subject to the adoption: John Doe and John Doe I. The magistrate court dismissed on the grounds that "petitioner must be in a lawfully recognized union, i.e. married to the prospective adoptee's parent, to have legal standing to file a petition to adopt that person's biological or adopted child." The magistrate dismissed the petition "sua sponte, without any motion or opposition to the Petition, without prior notice to any of the affected parties, without inviting legal briefing, without any apparent consideration of the Pre-Adoptive Home Study and without hearing." A Final Judgment was entered the same day. Jane Doe moved for reconsideration, but before a ruling on that motion was made, I.A.R. 12.2 compelled her to file a Notice of Appeal to the Supreme Court. Upon review, the Supreme Court concluded the district court violated Jane Doe's rights to due process by dismissing the petition without the opportunity to be heard in a meaningful manner. Furthermore, the Court found that Idaho's adoption statutes unambiguously allow a second, prospective parent to adopt, regardless of marital status. Therefore, the Court reversed the district court's judgment and remanded the case for further proceedings. View "In the Matter of Adoption of John Doe" on Justia Law

The State appealed the district court’s decision to affirm the magistrate court’s holding that it did not have jurisdiction over John (2012-10) Doe because he was twenty-one years of age when the State filed its petition in juvenile court. Upon review, the Supreme Court reversed the decision of the district court. View "Idaho v. John Doe (2012-10)" on Justia Law

In 2007, Steven and Valerie Hruza sought to obtain a loan from Clearwater Mortgage (Clearwater). Clearwater requested Defendant-Respondent Wade Massey to perform an appraisal of their real property located in Caldwell. Massey owned co-defendant Capitol West Appraisals and is a professional appraiser licensed to practice in Idaho. Massey performed the appraisal and sent a Summary Appraisal Report to Clearwater indicating that market value of the property was $1,150,000. Clearwater decided to deny the Hruzas' loan application before considering the appraisal. Massey admitted that both he and Clearwater were aware that the appraisal contained errors. Clearwater's president and Massey agreed that Massey would not fix the errors and Clearwater would not pay Massey for the appraisal. The Hruzas submitted a subsequent loan application to Idahy Federal Credit Union (now known as Icon). Icon approved the loan, secured by a deed of trust on the Hruzas' property. Icon sent a check to Capitol, and Capitol accepted payment. Plaintiff-Appellant CUMIS Insurance Society, Inc. was the fidelity bond insurer for Icon. It paid Icon as a result of the Hruzas' default on their loan. As Icon's subrogee, CUMIS filed suit against Massey and Capitol, alleging professional negligence, negligent misrepresentation, and breach of contract based on Massey's conduct in preparing the appraisal. A central point of dispute between the parties was how Icon obtained the appraisal. CUMIS alleged that the Hruzas included the appraisal with their loan application, thus prompting Icon to pay Capitol for the appraisal. Massey suggested that Icon improperly obtained the appraisal, pointing to Icon's admission that it did not know how it obtained it and that Icon did not request a letter of assignment from Clearwater to use or rely on the appraisal. The district court concluded that CUMIS could not establish that Massey owed a legal duty to Icon, that Idaho does not recognize a cause of action for negligent misrepresentation against appraisers, and that CUMIS had no breach of contract claim. Therefore, the district court granted Massey’s motion for summary judgment and dismissed all claims asserted by CUMIS, with prejudice. Finding that there remained issues of material fact, the Supreme Court vacated the district court's judgment dismissing CUMIS's complaint. The case was remanded for further proceedings. View "CUMIS Insurance Society, Inc. v. Massey" on Justia Law

This appeal arose from an action filed against Defendant-Respondent Mallory Martinez, a National Guard member, by Plaintiff-Appellant William Teurlings. Plaintiff alleged he suffered personal injury and economic damage resulting from a vehicle collision caused by defendant's negligence. Defendant moved for summary judgment asserting immunity under I.C. 6-904(4), which provides immunity to National Guard members for claims arising out of certain federal training or duty. The district court granted the motion after concluding defendant fell within the scope of the statutory immunity. Teurlings appealed, arguing that defendant was not immune because she was not "engaged in training or duty" and she was not acting within the course of her employment at the time of the collision. Finding that the district court erred in granting defendant immunity, the Supreme Court vacated the judgment in her favor and remanded the case for further proceedings. View "Teurlings v. Larson" on Justia Law

Defendant-Appellant David Lee appealed the district court's order that denied his motion to strike certain language from his acquittal. In that judgment, the court declared that because defendant was "a serious pedophile, it is hoped that the authorities will be able to keep a closer watch on him in the future." Upon review, the Supreme Court concluded that the "surplus" language should not have been included in the judgment of acquittal in the first place when defendant raised the issue in his motion. That motion should have been granted. Therefore, the Supreme Court reversed the district court's denial of the motion to strike, and the case remanded for entry of an amended judgment eliminating the sentence in question. View "Idaho v. Lee" on Justia Law

This appeal stemmed from a worker’s compensation case in which Michael Vawter sought compensation from his employer, United Parcel Service (UPS), for a back injury he claimed he suffered as a result of his employment. UPS attempted to establish that Vawter did not suffer a compensable injury, but if he did the State's Industrial Special Indemnity Fund (ISIF) was liable for a portion of his benefits. Ultimately, the Idaho Industrial Commission found that Vawter was totally and permanently disabled and that UPS was solely responsible for Vawter’s disability benefits because it was estopped from arguing Vawter had a preexisting condition, a necessary element of ISIF liability. UPS appealed, arguing: (1) the accident causing Vawter’s injury did not arise out of his employment; (2) the Commission improperly applied the doctrine of quasi-estoppel to prevent it from asserting a preexisting condition; and (3) the Commission improperly awarded Vawter attorney fees. Vawter and ISIF both cross-appealed. Upon review, the Supreme Court reversed the Industrial Commission’s determination that Vawter was not entitled to recover all medical expenses incurred between the date of the accident and September 27, 2010. The Court affirmed the Industrial Commission in all other respects. View "Vawter v. United Parcel Service, Inc." on Justia Law

In 1999, Rick and Natalie Foeller entered into an agreement with Melaleuca of Canada, Inc., under which the Foellers would serve as independent marketing executives in exchange for monthly commission payments. In 2008, the Foellers breached this agreement but Melaleuca continued to pay them commissions because it was unaware of the breach. Upon learning of the breach, Melaleuca sued to recover the payments it had made to the Foellers after they breached. The district court granted Melaleuca’s motion for summary judgment, finding that under the forfeiture clause of its agreement with the Foellers, Melaleuca was simply excused from performing once the Foellers breached and ordered the Foellers to refund Melaleuca the commissions they received after their breach. The Foellers appealed, arguing that the district court erred because the forfeiture clause was an illegal penalty and Melaleuca was required to prove damages. Agreeing with the Foellers, the Supreme Court vacated the district court’s judgment and remanded the case for further proceedings. View "Melaleuca, Inc v. Foeller" on Justia Law

This appeal arose from a termination of parental rights based on a Consent in Abeyance. The Idaho Department of Health and Welfare (IDHW) filed a Petition for the Termination of Parental Rights after a prolonged child protection proceeding involving John Doe and his two children, S.M. and C.M. In the Consent, Doe agreed to the conditional termination of his parental rights in exchange for the magistrate court vacating the hearing set on the termination petition and having his children returned to his care on an extended home visit. Doe was subsequently arrested and the magistrate court entered a judgment terminating Doe’s parental rights to both children on the grounds that Doe had signed the Consent and failed to substantially comply with its terms. Doe appealed. The Supreme Court held that Idaho does not recognize conditional consent to the termination of parental rights, and a termination of parental rights based on conditional consent is invalid. The magistrate erred by involuntarily terminating Doe’s parental rights without a showing by clear and convincing evidence of grounds for termination. Accordingly, the Court vacated the trial court's judgment and remanded the case for further proceedings. View "RE: Termination of Parental Rights" on Justia Law

The dominant owners of an easement appealed an adverse grant of summary judgment dismissing all of their claims, which were premised on the servient owner’s construction of a permanent sign within the easement. The sign effectively reduced the width of the easement from twenty-five feet to nineteen feet at one point along its length. On appeal, the dominant owners argued that the district court erred in granting the servient owner’s motion for summary judgment and contended that any reduction in the width of their easement was per se unlawful. Upon careful consideration of the facts of this case, the Supreme Court held that the erection of a permanent structure within an easement of definite location and dimension was per se unreasonable. The Court reversed the grant of summary judgment in favor of Defendant-Respondent Highway 101 Investments, LLC, and remanded the case for further proceedings. View "Johnson v. Highway 101 Investments, LLC" on Justia Law

Dale Piercy appealed the district court’s dismissal of his amended action for declaratory relief, which challenged the validity of a herd district ordinance enacted in 1982 by the Canyon County Commissioners. The district court dismissed Piercy’s claim on the basis that it was barred by a seven-year statute of limitations or, in the alternative, a four-year statute of limitations. Piercy challenged the application of both statutes, and argued that Respondents Jennifer Sutton, Luis Guzman, and Canyon County waived any statute of limitations defense. Upon review, the Supreme Court found no reversible error, and affirmed the district court. View "Guzman v. Piercy" on Justia Law