Justia Idaho Supreme Court Opinion Summaries
Harris v. Bank of Commerce
The plaintiffs in this case appealed the grant of summary judgment upholding the validity of a bank's mortgage in real property that the plaintiffs had sold to a mortgagor in exchange for an interest in an investment account that turned out to be a Ponzi scheme. Plaintiffs filed an action against other parties to their transaction including the Bank of Commerce arguing, among other things, that they were entitled to rescind the sale of a portion of their property for lack or failure of consideration and mutual mistake ("They argue[d] that they did not receive any consideration because the . . . interest in their investment account with the Trigon Group turned out to be worthless. Mr. Harris testified that he 'assumed that was real money, which it later proved out not to be.'"). Finding no error in the district court's judgment, the Supreme Court affirmed the lower court.
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Phillips v. Jacobson
This was an appeal of an order setting aside a sheriff's sale of real property. The respondents, Earline Chance and Leon Phillips who were deed of trust beneficiaries and judgment creditors, failed to attend or bid at the sheriff's sale but claimed the successful bidder, appellant Roy Jacobson, obtained the property for a grossly inadequate price. The district court agreed and set the sale aside. Upon review, the Supreme Court found that the district court indeed erred in setting aside the sheriff's sale, and reversed.
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Syringa Networks v. Idaho Dept of Admin
In 2008, the legislature enacted legislation to establish the Idaho Education Network (IEN), which was to be a high-bandwidth telecommunications distribution system for distance learning in every public school in the state. Syringa Networks, LLC (Syringa), an Idaho telecommunications company, entered into a “teaming agreement” with ENA Services, LLC (ENA). Pursuant to their agreement, ENA submitted a proposal in response to a request-for-proposals (RFP) with the Department of Administration, although the cover letter stated that both ENA and Syringa were responding jointly to the proposal. Qwest Communications Company, LLC, and Verizon Business Network Services, Inc., also submitted responsive proposals. The proposals were then scored based upon specific criteria; the ENA and Qwest proposals received the highest scores. The Department issued a letter of intent to award contracts to Qwest and ENA. One month later, it issued amendments to the two purchase orders to alter the scope of work that each would perform. Qwest became "the general contractor for all IEN technical network services" (providing the “backbone”) and ENA became "the Service Provider." The effect of these amendments was to make Qwest the exclusive provider of the backbone, which was what Syringa intended to provide as a subcontractor of ENA. Syringa filed this lawsuit against the Department, its director, the chief technology officer, ENA and Qwest. The district court ultimately dismissed Syringa’s lawsuit against all of the Defendants on their respective motions for summary judgment. Syringa then appealed the grants of summary judgment, and the State Defendants cross-appealed the refusal to award them attorney fees. Upon review, the Supreme Court affirmed the judgment dismissing all counts of the complaint except count three seeking to set aside the State's contract with Qwest on the ground that it was awarded in violation of the applicable statutes. Furthermore, the Court reversed Qwest’s award of attorney fees against Syringa. We remand to the trial court the determination of whether any of the State Defendants were entitled to an award of attorney fees against Syringa for proceedings in the district court. The Court awarded costs and attorney fees on appeal to ENA. Because the State Defendants and Syringa both prevailed only in part on appeal, the Court did not award them either costs or attorney fees on appeal. View "Syringa Networks v. Idaho Dept of Admin" on Justia Law
Fields v. Idaho
Petitioner-Appellant Zane Jack Fields was incarcerated for the 1988 first degree murder of Mary Katherine Vanderford. The district court dismissed his petition for post-conviction relief in 2010, the fifth successive petition for post-conviction relief he filed. In the latest petition, Petitioner argued that the act of destroying an orange camouflage coat (introduced into evidence as a defense exhibit and used by eyewitnesses to identify him) was new evidence that established his innocence. The State moved to dismiss on grounds that Petitioner's newly discovered evidence claims were time-barred by statute, and the district court granted the motion. Upon review, the Supreme Court concluded that the district court was correct in finding Petitioner's petition was untimely filed, and affirmed.
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Ada Co Prosecuting Atty v. 2007 Legendary Motorcycle
This case arose from a district court's review on appeal of a magistrate court's decision regarding the civil forfeiture of a motorcycle and other items that belong to Christopher Rubey. In 2009, Rubey was arrested and charged with possession of methamphetamine with intent to deliver. Subsequently, the Ada County Prosecutor's Office (State) brought an action under I.C. 37-2744 for civil forfeiture of the motorcycle and related items used in the alleged crime. The magistrate court granted summary judgment to the State, and the district court reversed and remanded that decision. The State appealed to the Supreme Court, arguing that the district court erred in its decision and that the legislative intent behind I.C. 37-2744(a)(4) supports civil forfeiture for either the transportation or trafficking of drugs. Upon review, the Supreme Court agreed and affirmed the district court's decision.
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Idaho v. Barton, Jr.
Defendant-Appellant Robert Barton, Jr. was found guilty by jury of solicitation of perjury. Defendant, the victim of aggravated battery, was charged with solicitation and conspiracy to commit perjury in connection to his testimony in the battery case. On appeal, Defendant argued that the jury should have been instructed on his defense of entrapment, and that such a defense was consistent with his plea of innocence. The State disagreed, arguing that no reasonable view of the evidence would support an instruction for entrapment and that such a defense is incompatible with his plea of innocence. Upon review, the Supreme Court found that the district court did not err when it refused to instruct the jury on the affirmative defense of entrapment, and affirmed the decision. View "Idaho v. Barton, Jr." on Justia Law
Peterson v. Gentillon
Appellants Lamon and Lori Gentillon and Wes and Connie Gentillon (the Partnership) appealed a district court’s order granting title to all but .34 acres of a disputed parcel of land and a 30-foot easement in favor of Craig and Janice Peterson in an action to quiet title to certain portions of riparian and agricultural land in Bingham County, Idaho. In 1998, the Partnership entered into a three-party agreement in which they purchased the majority of Scott and Tracy Gentillon's farm and were to exchange three small parcels of land with Marcel and Doris Gentillon following a survey of the land. The survey was completed in 1999 and revealed boundary problems that led to further land exchanges between the Gentillons and the Partnership. In 2006, the Gentillons sold their homestead to the Petersons by a warranty deed that did not reflect the Gentillons' land exchanges with the Partnership. The Petersons then brought the action to quiet title to the property they had acquired by deed. Upon review of the matter, the Supreme Court reversed the district court’s dismissal of the Partnership’s claim for specific performance of the 1998 Agreement and the district court’s denial of the Partnership’s resulting trust claim as to a 50-foot strip on the disputed property. The Court also reversed the district court in defining the width of the Petersons' easement. View "Peterson v. Gentillon" on Justia Law
Magleby v. Garn
The issue before the Supreme Court on appeal in this case related to attorney fees incurred in litigation arising from a construction contract for a custom cabin in Island Park, Idaho. There were two issues: (1) whether the district court erred in holding that the Maglebys were entitled to recover only $2,500 from defaulting parties by operation of I.R.C.P. 54(e)(4); and (2) whether the district court erred in its decision regarding the Maglebys' entitlement to post-judgment attorney fees. Upon review, the Supreme Court concluded that I.R.C.P. 54(e)(4) did not limit the Maglebys' fees to the $2,500 pled in their complaint even though defendants did not contest them. The Court vacated the judgments of the district court as they related to attorney fees awards in light of I.C. sec. 12-120(5) and "ITP" and "Jenks." The case was remanded for further proceedings.
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Altrua Healthshare v. Deal
Appellant Altrua HealthShare appealed the district court's decision affirming the Idaho Department of Insurance's (Department) determination that Altrua transacted insurance without a certificate of authority. Altrua argued that both the Department and the Ada County district court erred in finding that Altrua was an insurer because Altrua never assumed the risk of paying its members' medical bills. The Department found, and the district court affirmed, that when members make their predetermined monthly payments into the escrow account Altrua operates, the risk of payment shifts from the individual members to the escrow account, and in turn to Altrua. Altrua also contended that the Department's determination that it is an insurer despite the disclaimers in its membership contract to the contrary is an unconstitutional interference with Altrua's right to contract. Upon review, the Supreme Court found that the Department's conclusion that Altrua's membership contract was an insurance contract was clearly erroneous, and reversed the findings. The case was remanded for further proceedings.
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Bottum v. Idaho State Police
Petitioner-Appellant Randall Bottum appealed a district court order which held that a 2009 amendment to the sex offender registration law applied to him. Prior to the amendment, Petitioner could have petitioned the court to be exempted, but the amendment foreclosed that opportunity. Upon review of the district court order, the Supreme Court found that the 2009 amendment applied to Petitioner and affirmed the district court order. View "Bottum v. Idaho State Police" on Justia Law