Justia Idaho Supreme Court Opinion Summaries

Defendant-Respondent Russell Griffeth, a licensed physical therapist, operated a clinic in Idaho Falls. He received no training as a contractor and was never licensed as a contractor. He did, however, act as a general contractor in the construction of his two homes. He organized and supervised various subcontractors. In early 2009, Griffeth decided to remodel his physical therapy clinic by constructing an addition to the existing building. Griffeth intended to be the general contractor for the project, but the city required a licensed commercial contractor. Consequently, Griffeth hired Bryan Robinson, a friend with construction experience, to serve as the general contractor. Robinson obtained a commercial contractor license for the project. Near the end of the project, Robinson hired Claimant Geff Stringer as a carpenter. As the clinic project neared completion, the construction workers used a hoist attached to the roof to move heavy beams into position in the attic. Unfortunately, on or near the last day of the project, the ceiling collapsed, and a beam fell on Stringer. The impact from the beam fractured Stringer's left ankle. At the time of the accident, Robinson did not have worker's compensation coverage. Stringer filed worker's compensation complaints against both Robinson and Griffeth. Following an evidentiary hearing, the Commission held that Robinson was Stringer's direct employer and that Griffeth was his category one statutory employer. Because Robinson did not pay worker's compensation benefits to Stringer, Griffeth, as the statutory employer, normally would be liable for such benefits. However, the Commission held that Griffeth was exempt from worker's compensation liability because Stringer's employment with Griffeth was "casual" under I.C. 72-212(2). Stringer appealed to the Supreme Court. Finding no reversible error, the Supreme Court affirmed the Commission's decision. View "Stringer v. Robinson" on Justia Law

Monsanto, through a wholly owned subsidiary, owns a quartzite mine near Soda Springs. Monsanto and Washington Group International, Inc. (WGI) contracted with each other for WGI to operate the mine. This agreement was memorialized in an agreement set to expire at the end of 2002. A by-product of WGI's operations was silica sand. Silicon International Ore, LLC (SIO) contacted Monsanto about acquiring the sand. SIO presented Monsanto with a proposed contract, but that contract was never executed. However, Monsanto and WGI executed an Addendum to the agreement that authorized WGI to construct and operate a processing facility for silica sand at the quartzite mine and to pay Monsanto royalties for silica that was sold by WGI to a third party. SIO and WGI executed a Master Agreement, under which WGI agreed to provide silica sand to SIO; SIO agreed to pay for the construction of the processing facility for the silica sand; SIO agreed to pay WGI to dry, screen, and bag the silica sand; SIO agreed to pay WGI an additional amount for processed sand; and WGI agreed to load the bagged silica sand onto SIO trucks. Shortly before the First Quarzite Agreement was set to expire, Monsanto and WGI executed a second Quarzite Agreement and addendum. The Second Addendum was almost identical to the First, but provided that WGI would pay Monsanto different amounts for sand based on several considerations and that the "[t]itle to the silica sand sold by SIO shall pass directly from [Monsanto] to SIO upon processing . . . subject to payment." WGI notified SIO that it would no longer be providing SIO with silica sand after the end of the year. After discussions with SIO, SIO was permitted to continue processing and bagging sand through April 29, 2008. SIO dismantled its operations in the quarry and removed its building and equipment. The following year, SIO sued Monsanto and WGI for damages for violating and interfering with an alleged verbal agreement to continue processing silica sand. SIO alleged that it and Monsanto entered into a verbal agreement separate and apart from the Master Agreement for the sale of silica sand. SIO asserted breach of the alleged verbal agreement, breach of the implied covenant of good faith and fair dealing, equitable estoppel, and quasi-estoppel. Monsanto denied SIO's claims and asserted the statute of frauds as an affirmative defense. Against WGI, SIO claimed that WGI breached the covenant of good faith and fair dealing implied into the Master Agreement, and SIO alleged that WGI tortiously interfered with the alleged verbal agreement between SIO and Monsanto. Monsanto and WGI moved to dismiss, which were ultimately granted by the trial court. Finding no reversible error, the Supreme Court affirmed. View "Silicon Int'l v. Monsanto Co." on Justia Law

Plaintiff Wade Frogley appealed the district court's grant of summary judgment in favor of Respondents Meridian Joint School District No. 2, Aaron Maybon, and Linda Clark, on Frogley's complaint of retaliation in violation of Title VII of the Civil Rights Act and the Idaho Human Rights Act. Plaintiff also appealed the district court's grant of summary judgment in favor of Respondents on his claim of negligent infliction of emotional distress. Plaintiff's claims stemmed from his work as an Assistant Principal at Mountain View High School within the Meridian School District. He alleged that within weeks of his hire, he was subject to continuous sexual harassment at the school from the principal and other assistant principals. Upon review, the Supreme Court concluded genuine issues of material facts existed with regard to both of Plaintiff's claims. As a result, the Supreme Court reversed the district court's judgment and remanded the case for further proceedings. View "Frogley v. Meridian Joint School Dist 2" on Justia Law

Claimant-Appellant Dallas Clark appealed an Industrial Commission order that denied her workers' compensation benefits. Claimant worked for Shari's Management Corporation as an experienced server. During a graveyard shift, she suffered a herniated disc in her back while lifting a heavy tray onto a high shelf. She would later be diagnosed with sciatica attributed to the lifting injury from work. Shari's completed a Report of Injury, interviewing Claimant in the process. The investigator testified that Claimant attributed the injury as "standing wrong" at a salad bar, which left her unable to lift the tray. The Commission concluded after a hearing that Claimant was unable to prove an industrial accident had occurred. The Supreme Court agreed with the Commission and affirmed its order. View "Clark v. Shari's Management Corp" on Justia Law

In 1991, appellant Zane Fields was sentenced to death for first degree murder. In 2011, appellant filed his sixth successive petition for post-conviction relief. He raised claims of actual innocence, prosecutorial misconduct, and violations of the right to counsel, due process, and the right to a fair trial. The district court granted the State's motion to dismiss appellant's petition because his claims were barred by I.C. 19-2719(5). Appellant appealed the district court's dismissal of his petition. Finding no reversible error, the Supreme Court affirmed. View "Fields v. Idaho" on Justia Law

Plaintiffs-Appellants Norman and Robin Riley appealed the district court's grant of summary judgment in favor of respondents Spiral Butte Development, LLC and Jim Horkley. Plaintiffs alleged breach of contract against Spiral Butte and sought specific performance of the parties' Lease Option Agreement. Finding no reversible error, the Supreme Court affirmed. View "Riley v. Spiral Butte Development, LLC" on Justia Law

Mother Jane (2013-14) Doe appealed the termination of her parental relationship with her son JLS. Mother left JLS in the care of family members, who then placed JLS with Mr. and Mrs. Doe. The Does petitioned to terminate Mother's parental rights on the grounds of abandonment. Following trial, the magistrate court granted that petition. Finding that the magistrate court's decision was supported by substantial, competent evidence, the Supreme Court affirmed that court's judgment terminating Mother's parental rights. View "John Doe V. Jane Doe (2013-14)" on Justia Law

Several neighbors all owning lakefront property objected when others planned on building a dock on the lake and using a portion of what was believed to be a designated common area. Plaintiffs appealed a district court judgment that dismissed their claims that they had the right to use parcels of property designated as common areas in a plat that was void because the persons who recorded the plat did not own all of the real property included in the plat and that awarded the plaintiffs an easement across a parcel of land owned by the cross-appellants. Upon review of the records, the Supreme Court affirmed the district court's judgment except as to the width of the easement. View "Siegwarth v. Opportunity Management Co., Inc." on Justia Law

Black Rock Development, Inc. developed a planned unit development consisting of residential homes and a golf course on the shore of Lake Coeur d'Alene. Black Rock Development recorded covenants, conditions, and restrictions (CC&R's) applicable to the development. The CC&R's created the position of "Declarant," named Black Rock Development as the Declarant, stated the rights of the Declarant, defined the time period that the Declarant would be entitled to exercise those rights, and specified the qualifications for a "Successor Declarant." The golf course in the development was developed and owned by The Club at Black Rock, LLC. The Club conveyed its real property to the Washington Trust Bank in lieu of foreclosure. Black Rock Development also assigned to the Bank all of its rights and interests as the Declarant under the CC&R's. The Bank then assigned the real property and the Declarant rights to West Sprague Avenue Holdings, LLC. West Sprague deeded the real property and assigned the Declarant rights to an entity named The Golf Club at Black Rock, LLC, which was a different entity than The Club. Black Rock Development assigned to The Golf Club any Declarant rights that Black Rock Development may still have retained due to any procedural or substantive defect in the prior assignments. Plaintiffs, who are the owners of at least one lot in Black Rock and are members of the Black Rock Homeowner's Association, Inc., filed this action against The Golf Club seeking a declaratory judgment that it was not qualified to be a Successor Declarant and therefore could not exercise Declarant rights. Both sides moved for summary judgment on the issue of whether The Golf Club satisfied the requirements of being a Successor Declarant under the CC&R's. The district court held that it did. It therefore dismissed the complaint and awarded court costs, including attorney fees, against Plaintiffs. Plaintiffs then appealed. Upon review, the Supreme Court concluded The Golf Club did not qualify as a Successor Declarant; it did not take title to Property for the purpose of sale and development. Because The Golf Club did not qualify as a Successor Declarant, it could not exercise the rights or powers of a Declarant. Therefore, the Supreme Court reversed the district court's judgment, including its award of costs and attorney fees to The Golf Club. View "Sky Canyon Properties, LLC v. The Golf Club at Black Rock, LLC" on Justia Law

The issue before the Supreme Court in this case related to the service of four members of the Board of Directors for the Southern Valley County Recreation District. The State brought usurpation actions against Donald Keithly, Yvette Davis, Patrick Cowles, and Michael Smith (the Directors), alleging they usurped their offices as directors of the Recreation District. The State requested they be removed from office and sought a fine against each of them. Upon the parties' cross-motions for summary judgment, the district court ruled that this action was an election contest, rather than a usurpation action, which could be brought by the State. The district court also ruled that the Directors' actions while in office were protected by the de facto officer doctrine. The State appealed, arguing this was a proper usurpation action and the de facto officer doctrine did not apply. The Directors cross-appealed, arguing they are entitled to attorney fees. The Supreme Court concluded the matter was moot and affirmed the district court's order denying attorney fees. View "Idaho v. Keithly" on Justia Law