Justia Idaho Supreme Court Opinion Summaries

A bank hired a contractor to perform janitorial and snow removal services. The written contract between the parties lapsed, but they orally renewed their agreement according to the same terms. One morning, a bank employee arrived at work and parked in the parking lot. She stepped out of her car, slipped on black ice, and was injured. The employee sued the contractor, claiming that it had negligently failed to spread ice melt on the parking lot. The district court granted the contractor's motion for summary judgment, holding that the contractor owed no duty to spread ice melt on the parking lot on any day in which less than two inches of snow had fallen. The employee then appealed to the Supreme Court. Finding no genuine issue of material fact remaining regarding whether the contractor owed a duty to spread ice melt on the parking lot, the Supreme Court concluded the trial court properly granted summary judgment in favor of the contractor. View "Gagnon v. Western Building Maintenance, Inc." on Justia Law

John Doe was in prison when his son was born. The baby's mother was living with another man, and gave the boy the boyfriend's surname. The baby was abused while in her care; the Department of Health and Welfare took the child into custody. The boyfriend was listed as the putative father in a Child Protective Act (CPA) proceeding; after a DNA test, Doe was substituted as the putative father. Prior to the test, Doe had no prior contact with the child. The Department requested termination of Doe's and the biological mother's parental rights. The mother voluntarily consented to the termination. The Department submitted a new petition, requesting for the first time an "Order of Non-Establishment of Parental Rights." The Department averred that Doe was "not the 'parent' of [Son] as [he had] failed to assert any parental rights to [Son] either by statute or by timely establishing some relationship to [Son]." The magistrate judge entered her Findings of Fact, Conclusions of Law and Nonestablishment of Paternity. Doe timely appealed. He raised two issues: (1) whether under Idaho Code he was entitled to an evidentiary hearing prior to the "nonestablishment" of his parental rights; and (2) whether his due process rights were violated. The Supreme Court concluded that Doe did not show he was entitled to an evidentiary hearing prior to the "nonestablishment" of his parental rights, or that his due process rights were violated. View "Doe v. Idaho Department of Health & Welfare" on Justia Law

Appellants Richard Hehr and Greystone Villages, LLC (collectively "Greystone") appealed a district court's grant of summary judgment in favor of Respondent City of McCall. Greystone's claims arose out of its development agreement with McCall. Greystone alleged it deeded nine lots to McCall in lieu of paying the required community housing fee, which was later declared unconstitutional in a separate proceeding. Greystone brought inverse condemnation claims against McCall alleging that the conveyance of the lots and the improvements made to those lots constituted an illegal taking under both the Idaho Constitution and the United States Constitution. McCall moved for summary judgment, which the district court granted. Finding no error in the district court's decision, the Supreme Court affirmed. View "Hehr v. City of McCall" on Justia Law

The issue on appeal to the Supreme Court in this case stemmed from district court decisions regarding an uninsured motorist claim between Plaintiffs-Appellants Sam and Deva Ferrell and Defendant-Respondent United Financial Casualty Company (United Financial, d.b.a. Progressive Insurance Company). The parties underwent arbitration, and the Ferrells subsequently filed a petition that sought confirmation of the arbitration award and an award of costs and attorney fees. The district court ordered confirmation of the arbitration award and interest based upon an agreement of the parties. On the issue of attorney fees, the district court found that arbitration began five months prior to the amendment of I.C. 41-1839 which explicitly allowed attorney fees in arbitration, and therefore the statute as it existed did not provide for attorney fees in this case. The Supreme Court reversed in part and remanded the case back to the district court. View "Ferrell v. United Financial Casualty Co." on Justia Law

Defendant Preston Joy was charged with felony domestic battery, sexual penetration by a foreign object, and second-degree kidnapping in connection with an altercation with his wife. A jury convicted defendant of domestic battery, acquitted on the sexual penetration charge, and was unable to reach a verdict on the kidnapping charge. He then entered a conditional guilty plea reserving his right to appeal all of the district court’s pre-trial, trial, and post-trial rulings. Defendant argued on appeal that evidence of prior misconduct was erroneously admitted, that the district court made other errors in admitting evidence, and that the district court erred by refusing to instruct the jury on lesser included offenses. Upon review, the Supreme Court vacated the conviction and remanded the case for a new trial. View "Idaho v. Joy" on Justia Law

William Shapley appealed the district court’s dismissal of his breach of contract and negligence claims against Centurion Life Insurance Company and Wells Fargo Financial. Shapley and his wife applied for credit life insurance with Centurion on the same day they closed on a real estate loan with Wells Fargo. The Shapleys were provided with a notice of insurance underwriting practices. The application papers stated that the Shapleys would receive insurance coverage only if Centurion approved their application. Centurion never had a chance to have a phone interview with Mrs. Shapley (a requirement for the policy). The day after the Shapleys closed on their loan, Mrs. Shapley suffered a brain hemorrhage from which she died four days later. Mr. Shapley contacted Centurion the same day to claim benefits in connection with Mrs. Shapley’s passing. Centurion denied the claim because it never issued an insurance policy on Mrs. Shapley. Because the interview never took place, Centurion issued insurance solely to Mr. Shapley. Mr. Shapley argued on appeal that the district court's dismissal was in error. Upon review, the Supreme Court affirmed the district court’s decisions, finding that while the district court incorrectly concluded that there must be a contract for estoppel to apply, the denial of Mr. Shapley’s motion to amend was appropriate because his estoppel claim was futile. View "Shapley v. Centurion Life Ins Co" on Justia Law

The Supreme Court affirmed the district court’s order granting a new trial on plaintiffs' claim for breach of the implied warranty of habitability and its denial of defendants' request for attorney fees at trial. Plaintiffs Shawn and Shellee Goodspeed purchased a home from Robert and Jorja Shippen via warranty deed. After the basement of the home flooded, the Goodspeeds filed suit against the Shippens, alleging breach of the implied warranty of habitability. The district court denied a request for a jury instruction on the requirements for disclaiming the implied warranty of habitability and the case went to trial. The jury returned a verdict in favor of the Shippens, and the Goodspeeds moved for judgment notwithstanding the verdict or, alternatively, for a new trial, arguing the disclaimer of the implied warranty of habitability in the purchase and sale agreement was ineffective because it was not conspicuous. The district court granted a new trial after determining it had excluded the disclaimer instruction based upon its incorrect belief that the Goodspeeds had actual knowledge of the disclaimer. View "Goodspeed v. Shippen" on Justia Law

Plaintiff-Appellant Pedro Pelayo appealed several rulings the magistrate court made in his divorce from Defendant-Respondent Bertha Pelayo. Specifically he challenged the magistrate's ruling with regard to: spousal maintenance awarded to Defendant; calculation of his annual income for child support calculation purposes; and the award of attorney fees. The district court upheld those challenged rulings; Plaintiff then appealed to the Supreme Court. Finding no error or abuse of discretion in the magistrate court's or district court's decisions, the Supreme Court affirmed. View "Pelayo v. Pelayo" on Justia Law

The State Board of Dentistry fined Plaintiff-Appellant Lon Peckham, DMD for failing to adequately inform a patient prior to performing a procedure, and for publishing misleading material on his website. The district court affirmed the Board's decision. On appeal, Plaintiff challenged the district court's affirming of the Board's final Order. Upon review of the matter, the Supreme Court found insufficient evidence to support findings that Plaintiff failed to inform a patient prior to performing a procedure or for publishing misleading material. Accordingly, the Supreme Court reversed the district court. View "Peckham, DMD v. State Bd of Dentistry" on Justia Law

The issue before the Supreme Court in this case centered on a district court's judgment to condemn an easement across the appellants' real property for an irrigation pipeline. The Supreme Court found no error in the district court's holding that there was a reasonable necessity required for condemnation of the easement in question. The Court vacated a portion of the judgment as it pertained to Defendants-Appellants Donald and Carolyn Cain's counterclaim and the award of a perpetual easement across their property, but the Court affirmed in all other respects. The case was remanded for further proceedings. View "Telford Lands v. Cain" on Justia Law