Justia Idaho Supreme Court Opinion Summaries

Plaintiff-Appellant Billie Jo Major sued Security Equipment Corporation (SEC) alleging that the company failed to provide adequate warning to her employer, the Idaho Department of Corrections (IDOC), on the risks of its oleoresin capsicum pepper spray. Plaintiff alleged that the use of the spray in a training exercise worsened existing bronchial difficulties and caused her permanent injury. The district court granted partial summary judgment to SEC on the grounds that plaintiff failed to create a material issue of fact on whether her injuries were a known or foreseeable risk prior to March 2008 (the date of sale to IDOC). In a motion to reconsider, plaintiff submitted a second affidavit from her expert which was declared a sham affidavit by the district court in its denial of the motion. The district court later granted summary judgment to SEC on the sole remaining issue, the viability of plaintiff's claim under the Federal Hazardous Substances Act (FHSA). Upon review, the Supreme Court disagreed with the district court, vacated its judgment, and remanded the case for further proceedings. View "Major v. Security Eq Corp" on Justia Law

At the heart of this appeal was a mechanic's lien filed against the Black Rock North Development in Coeur d?Alene, Idaho, and an uncompleted golf course community development. American Bank (the Bank) was the lender to BRN Development, Inc. (BRN). BRN hired Wadsworth Golf Construction Company of the Southwest (Wadsworth) to construct a golf course. BRN failed to pay Wadsworth for a portion of the work it performed, and Wadsworth filed a mechanic's lien against the property. BRN defaulted on the loan, and the Bank initiated foreclosure proceedings. Wadsworth's claim of lien was subordinate to the Bank's mortgage interest in the property. In order to proceed with a foreclosure sale, the Bank posted a lien release bond in order to secure the district court's order releasing Wadsworth's lien. The Bank was the successful bidder at the foreclosure sale. The district court ruled that priority of the parties? claims against the property was irrelevant once the property was replaced by the lien release bond as security for Wadsworth's claim and the Bank (by way of the bond) was responsible for payment of Wadsworth's lien claim. The Bank appeals that decision, arguing that Wadsworth should have been prevented from recovering against the lien release bond because its interest would have been extinguished if it had attempted to foreclose its mechanic's lien and the bond merely served as substitute security in place of the property. Wadsworth cross-appealed, arguing the district court erred in holding that Wadsworth waived its right to file a lien for the unpaid retainage on the contract. Upon review, the Supreme Court reversed the district court allowing Wadsworth to recover against the lien release bond and vacated the district court's judgment in favor of Wadsworth. View "Americn Bank v. Wadsworth Golf" on Justia Law

This case centered on a judicial foreclosure action brought by Karl L. Roesch and River Terrace Estates, Inc. against Daniel L. Klemann, Cornerstone Financial, Inc., and Shea Realtors, PLLC. Roesch obtained a foreclosure judgment and decree of sale against Klemann in the amount of $307,800.62. The judgment also provided that interest would accrue on the indebtedness through the date of the sheriff's sale. When the district court later learned that the rate used to calculate the interest was the rate set forth in the note, it ordered counsel to prepare another judgment calculating the interest based upon the statutory post-judgment rate defined in the Idaho Code. Roesch appealed the amended judgment, arguing that he was entitled to interest at the note rate through the date of the sale. Finding no error, the Supreme Court affirmed the amended judgment. View "Roesch v. Klemann" on Justia Law

This was the third appeal pursued by Byron Thomason (deceased) and his wife Marilynn Thomason (Thomasons) against the brothers Terrence and John Bagley (the Bagleys) over a quiet title action. In the first appeal, the Supreme Court affirmed the district court's order quieting title to real property in the Bagleys and awarding them attorney fees. In the second appeal, the Supreme Court affirmed the district court's decision granting the Bagleys certain shares of water previously held by the Thomasons. Subsequent to the filing of the notices of appeal, the Bagleys were awarded attorney fees and obtained a writ of execution to satisfy the judgment for attorney fees. Pursuant to the writ of execution, the sheriff seized some of the Thomasons? personal property to satisfy the judgment. The Thomasons? requests for exemption and emergency stay were denied. After this Court's opinion in "Bagley I" was released, the Bagleys moved for and were granted judgment on the pleadings. The Thomasons appealed. Upon review, the Supreme Court affirmed the district court's judgment. View "Bagley v. Thomason" on Justia Law

Tyler Ray Carter pleaded guilty to aggravated battery on a correctional officer and was sentenced to fifteen years with five years fixed. He appealed the sentence arguing the district court failed to order a separate psychological evaluation prior to sentencing, and also violated his Fifth Amendment privilege against self-incrimination by using pre-trial competency evaluations in making its sentencing determination. Carter did not object to either the use of the competency evaluations or the court?s failure to order a psychological evaluation at trial. The Court of Appeals applied the "manifest disregard" standard to review Carter's claim that the court erred by failing to order a new psychological evaluation, and vacated the sentence. The Supreme Court granted the State's petition for review. The State argued that the fundamental error standard applied to all of Carter's unobjected-to evaulations. Upon review, the Supreme Court disagreed with the State's argument and affirmed the district court's judgment of conviction and sentence. View "Idaho v. Carter" on Justia Law

Dale Shackelford appealed two consecutive fixed life sentences he received on resentencing for two first-degree murder convictions. He was initially sentenced to death for both murders but the death sentences were subsequently set aside. Shackelford contends that the district court committed error in resentencing him to the consecutive fixed life sentences. Upon review of the district court record, the Supreme Court concluded that the district court did not abuse its discretion nor violate Shackelford's Sixth Amendment right of confrontation. Accordingly, the Court affirmed the judgment of conviction sentencing Shackelford to two consecutive fixed life sentences. View "Idaho v. Shackelford" on Justia Law

The underlying dispute in this matter centered on the sale and demolition of a bridge across the Ohio River between West Virginia and Ohio. Advanced Explosives Demolition, Inc. (AED) entered a contract to sell the bridge to KDC Investments, LLC (KDC) for $25,000. AED alleged that it also entered into another contract in which KDC hired it to perform explosive demolition work prior to removal of the bridge. After the bridge sale was complete, KDC terminated its relationship with AED and hired another demolition contractor. AED brought an action for fraud and breach of contract against KDC and asked the district court to rescind the sales contract. The district court denied the request for rescission and granted summary judgment in favor of KDC on the fraud and breach of contract claims, holding that AED had provided no evidence of fraud and concluding that the demolition contract was illegal because AED did not have the necessary West Virginia contractor's license when it entered into the contract. AED appealed the district court's denial of its request. The Supreme Court held that AED waived the issue of whether the district court abused its discretion in striking certain affidavits presented at trial. However, the Court affirmed the district court's grant of summary judgment in favor of KDC and the district court's order quieting title to a Toll Bridge in KDC. View "AED, Inc v. KDC Investments" on Justia Law

This appeal stemmed from Native Wholesale Supply Company's (NWS) cigarette sales to Warpath, Inc. NWS is an Indian retailer organized under the tribal laws of the Sac and Fox Nation. It operates on the Seneca reservation in New York. Warpath is an Idaho corporation that operates on the Coeur d'Alene reservation. The State of Idaho brought suit against NWS for acting as a cigarette wholesaler without a permit and for selling cigarettes that are unlawful for sale in Idaho. The district court enjoined NWS from selling wholesale cigarettes in Idaho without a wholesale permit and assessed civil penalties in the amount of $214,200. NWS appealed that decision, arguing the State did not have subject matter jurisdiction or personal jurisdiction. Upon review, the Supreme Court affirmed in part, reversed in part, and remanded to the district court for further proceedings. The Court found that NWS's sales to Warpath were exempt from Idaho taxation, and NWS was not required to obtain a wholesale permit. Furthermore, the State had subject matter over NWS's importation of non-compliant cigarettes into the State of Idaho, and that the State could validly exercise personal jurisdiction over NWS. View "Idaho Tax Commission v. Native Wholesale Supply" on Justia Law

At issue in this case was a worker’s compensation claim stemming from an accident at an onion processing plant. Petitioner James Clark was injured when his right forearm was caught in a roller machine which resulted in significant soft-tissue damage. The Industrial Commission determined that Clark suffered a compensable injury and that he was entitled to medical treatment for approximately one year. The Commission also found that Clark had a permanent partial impairment (PPI) of 10% of the whole person and a permanent partial disability rated at 25% of the whole person. Clark appealed that determination pro se, arguing the Commission relied on fraudulent evidence because his medical records were fraudulently obtained. Finding no error, the Supreme Court affirmed. View "Clark v. State Ins Fund" on Justia Law

The Department of Health and Welfare appealed an order that disallowed its attempt to recover assets in a probate proceeding. The Department sought to recover assets of a dead Medicaid recipient for medical assistance payments made on the decedent's behalf from her widower. The magistrate court held that the Department could not reach the separate property of the decedent's spouse. Upon review, the Supreme Court concluded the Department was permitted to seek recovery from the decedent's community property that was transmuted to her widow as his separate property. View "In re Estate of Wiggins" on Justia Law