Justia Idaho Supreme Court Opinion Summaries

Marti Mortensen appealed the district court’s judgment regarding the scope and location of the Mortensen’s easement across Dennis and Sherrie Akers’ property. Mortensen also appealed the district court’s award of punitive damages, arguing she should not have been liable for the punitive damages assessed against her former husband, Vernon. The Supreme Court affirmed the district court's location of the prescriptive easement and the award of punitive damages against the Mortensens. The Court vacated the district court's judgment to the extent that it awarded attorney fees to the Akers because the district court failed to apportion the fee award. The case was remanded for the sole purposed of apportioning attorney fees. View "Akers v. Mortensen" on Justia Law

David and Michelle White, and D.L. White Construction, Inc. appealed the district court’s judgment regarding the scope and location of the Whites’ easement across Dennis and Sherrie Akers’ property and the district court’s award of compensatory and punitive damages for trespass and emotional distress. The Supreme Court affirmed the district court’s judgment locating the easement and awarding damages, but remanded the case for apportionment of attorney fees. View "Akers v. D.L. White Construction, Inc." on Justia Law

In 1994, an en banc panel of the district judges of the Fourth Judicial District ordered Garden City and Meridian to provide suitable and adequate quarters for the magistrate’s division of the Fourth Judicial District. In addition to providing quarters, the Cities were ordered to provide for the equipment, staff, supplies, and other expenses necessary for the quarters to function properly. The Cities have never complied with the order. In 2010, Ada County brought a declaratory action asking the district judges to find that the 1994 Order was still valid and to require the Cities to comply with it. The Cities responded by filing a motion to vacate the 1994 Order, claiming that the order was invalid because it was entered on an ex parte basis. The en banc panel dismissed Ada County’s complaint, holding that a declaratory judgment action was not the appropriate means to determine the validity of the 1994 Order. The panel also denied the Cities’ motion to vacate on the grounds that before the 1994 Order was entered, the Cities had received all the process to which they were entitled. The Cities appealed. Finding that the appeal did not present a justiciable controversy, the Supreme Court dismissed the appeal. View "Ada County v. Garden City" on Justia Law

Appellant Farmers National Bank (FNB) appealed the district court's grant of declaratory judgment in favor of Green River Dairy, LLC, and four commodities dealers: Ernest Carter, Lewis Becker, Jack McCall, and Hull Farms (Sellers). FNB argued the district court misinterpreted I.C. 45-1802 (a statutory lien provision) and as a result, erred in granting Sellers a priority lien on collateral securing a loan previously made by FNB. Upon review, the Supreme Court agreed with FNB about the misinterpretation and vacated the district court's grant of declaratory judgment in favor of the Sellers. View "Farmers Nat'l Bank v. Green River Dairy" on Justia Law

Attorney L. Clyel Berry argued that he was entitled to a 40% attorney fee award, based on a contingent fee agreement he entered into with Claimant VerDene Page. The Industrial Commission awarded Berry a 30% attorney fee award pursuant to Idaho Code 72-804, which requires an employer to pay reasonable attorney fees when it unreasonably withholds compensation from an injured employee. Upon review of the matter, the Supreme Court held: (1) the Commission's approval of a 30% attorney fee award under I.C. 72-804 was supported by substantial and competent evidence; (2) the Commission properly exercised its discretion in fixing the 30% fee; and (3) counsel's fee agreement with Claimant did not guarantee a certain attorney fee award. View "Verdene Page v. McCain Foods, Inc." on Justia Law

The Campbells appealed the grant of summary judgment in favor of their neighbors The Kvammes. The parties disputed whether a fence between their respective properties constituted the true boundary of their land. The district court found that a land survey submitted by the Campbells lacked adequate foundation to be admissible, and therefore awarded the Kvammes summary judgment. On appeal, the Campbells argued that the district court abused its discretion when it disregarded the affidavit of their land surveyor in their motion for reconsideration. The Supreme Court found that because the district court granted summary judgment on two independent grounds. The Campbells challenged only one of those grounds on appeal. By law, an appellant must challenge all grounds to prevail. The Court therefore affirmed the district court's grant of summary judgment. View "Campbell v. Kvamme" on Justia Law

In 2006, the Christensens began construction of a fabric building adjacent to the property line shared with the McVicarses. After its completion, the McVicarses filed a nuisance action alleging that increased noise, traffic, and dust diminished the value of their property and interfered with the enjoyment of their property. After a bench trial, the district court ruled in favor ofMcVicarses, finding the Christensens’ course of conduct unreasonably interfered with the McVicarses’ enjoyment of their property and was therefore a private nuisance. Furthermore, the court found that there was no evidence to support the McVicarses’ claim of public nuisance or the Christensens’ unclean hands defense. The Christensens appealed. Upon careful consideration, the Supreme Court held that the district court erred to the extent that it considered the building’s size and proximity to the McVicarses’ property to constitute a nuisance. Because the building’s size and proximity do not in and of themselves constitute a nuisance, the district court erred in requiring the McVicarses to move the building from its current location. Therefore, the case was remanded for analysis of whether the cumulative effects of the activities on the property constituted a nuisance in fact. View "McVicars v. Christensen" on Justia Law

American West Enterprises appealed a district court's grant of summary judgement to Case New Holland, Inc. (CNH) in its effort to recover the cost of a remanufactured tractor engine CNH sold to a local seller that American West purchased. The district court dismissed American West's claim of implied warranty because there was no privity between American West and CNH. The district court also rejected American West's claims that it was an intended third party beneficiary of a contract between CNH and Pioneer and that Pioneer was an agent of CNH. American West appeals. The district court denied CNH's request for attorney fees and costs below. CNH cross-appealed. Finding no error, the Supreme Court affirmed all but the denial of attorney fees. The case was remanded to the district court for finding costs and fees in favor of CNH. View "American West Ent. v. CNH, LLC." on Justia Law

This appeal involves the transfer of the experience rating account for unemployment tax purposes from one employer to another pursuant to Idaho Code section 72-1351A(1)(a). After an investigation, the Department of Labor determined that the experience rating account of Diamond Z Trailer, Inc. (Diamond Z), which ceased operating in the spring of 2010, was transferred to Rule Steel Tanks, Inc. (Rule Steel), which hired the majority of the employees who were laid off by Diamond Z and which commenced marketing and manufacturing the same product that was manufactured by Diamond Z. Rule Steel appealed that determination. Finding no reversible error, the Supreme Court affirmed. View "Rule Steel Tanks, Inc. v. Dept of Labor" on Justia Law

Borrower Gregory Renshaw refinanced the mortgage on his home in 2007. Borrower did not make the payments due under the promissory note, and in 2010, the trustee under the deed of trust commenced nonjudicial foreclosure proceedings. Borrower filed this action against the mortgage broker, the lender, MERS, and the trustee. Ultimately, summary judgment was granted in favor of MERS and a partial judgment was entered dismissing this action as to it. Borrower appealed. Finding no reversible error, the Supreme Court affirmed. View "Renshaw v. MERS" on Justia Law