Justia Idaho Supreme Court Opinion Summaries

The United States District Court for the District of Idaho certified a question of law to the State Supreme Court: whether a legal malpractice claim that is transferred to an assignee in a commercial transaction (along with other business assets and liabilities) is assignable under law. The issue stemmed from St. Luke's Magic Valley Regional Medical Center's purchase of Magic Valley Medical Center. Thomas Luciani and his law firm Stamper, Rubens, Stocker & Smith, P.S. represented Magic Valley in defending a wrongful termination and False Claims Act action brought by former hospital employees. After the sale of the medical center closed, Magic Valley no longer existed. The operation and management of the center was taken over by St. Luke's. St. Luke's then sued its former lawyer and law firm. The District Court noted that the assignability of a legal malpractice claim in the factual context presented had not yet been squarely addressed by the Idaho Supreme Court. Upon review, the Idaho Supreme Court answered the district court's question in the affirmative: although legal malpractice claims are generally not assignable in Idaho, where the legal malpractice claim is transferred to an assignee in a commercial transaction, along with other business assets and liabilities, such a claim is assignable. View "In re: St. Lukes Magic Valley RMC v. Luciani, et al." on Justia Law

This case arose from a traffic stop and subsequent arrest of Defendant Phillip James Morgan. A Boise City police officer observed Morgan driving in a way that caused the officer to believe Defendant was trying to avoid him. The officer stopped Defendant after observing that Defendant's vehicle did not have a front license plate. Defendant was subsequently arrested for DUI. He filed a motion to suppress all evidence garnered from the traffic stop, arguing the officer did not have reasonable suspicion to initiate the stop. The district court concluded that although Defendant may not have actually violated traffic laws, the officer had reasonable articulable suspicion to believe that he had done so. Defendant's motion to suppress was denied, and he was convicted of felony DUI after a jury trial. Defendant appealed. Upon review, the Supreme Court reversed, concluding the officer lacked the reasonable, articulable suspicion necessary to justify the traffic stop. The judgment of conviction was vacated and the case remanded for further proceedings. View "Idaho v. Morgan" on Justia Law

Defendant Daniel Straub pled guilty to vehicular manslaughter, and as part of his plea, agreed to pay restitution to his victims. After a hearing, the district court determined that Defendant owed $554,506.67 to the decedent's family, primarily for future medical insurance premiums and for five years of lost wages. Defendant appealed the restitution order, arguing that the court unreasonably or illegally interpreted the restitution statutes. Finding that Defendant did not waive his right to appeal the district court's order in his plea agreement, and that the district court abused its discretion in ordering Defendant to pay restitution for the victim's future lost wages, the Supreme Court reversed the order and remanded the case for further proceedings. View "Idaho v. Straub" on Justia Law

Defendant-Appellant Randy McKinney was sentenced to death for first-degree murder, and received sentences for conspiracy to commit murder, robbery, and conspiracy to commit robbery. His death sentence was set aside in a federal habeas proceeding. Defendant and the State reached a sentencing agreement with regard to the murder charge for which he received a fixed life term without possibility of parole to be served concurrently with his other sentences. On appeal, Defendant alleged that he was illegally sentenced, violating the double jeopardy clause of both the state and federal constitutions, as well as Idaho's multiple-punishment statute (repealed in 1995). Upon review, the Supreme Court found no error in Defendant's sentences and affirmed them. View "Idaho v. McKinney" on Justia Law

The Idaho State Tax Commission appealed a district court judgment which held that PacifiCorp, an Oregon corporation, proved by a preponderance of the evidence that the Commission's valuation of its taxable operating property in Idaho was erroneous pursuant to I.C. 63-409(2). The Commission contended on appeal that the district court's decision was not supported by substantial and competent evidence because the appraisal methodologies utilized by PacifiCorp's appraiser are so unreliable as to amount to incompetent evidence. Because the district court's judgment was not clearly erroneous and was supported by substantial and competent evidence, the Supreme Court affirmed the district court's judgment. View "PacificCorp V. Idaho State Tax Commission" on Justia Law

Appellants Raoel and Janet Clark and Jerry and Betty Peterson appealed the district court's grant of summary judgment in favor of Buku Properties, LLC. Buku filed suit against the Clarks and the Petersons to recover earnest money deposits after two codependent land sale contracts failed to close. At the time the parties entered into the land sale contracts, the properties were zoned "R-1," which allowed for a minimum density of one acre lots. However, after the contracts were executed, but prior to closing, the Jefferson County Planning and Zoning Commission began discussions to change the R-1 designation of the properties to R-5, which mandated a five acre minimum density. While conducting its due diligence, Buku discovered the County’s plan to change the zoning designation of the properties. Aware of the potential re-zoning, Buku sent Appellants proposed addenda to the land sale contracts seeking to extend the review period and closing date due to concerns about zoning and financing. The bank financing Buku’s purchase of the properties sent Buku a letter stating that Buku’s loan was only “conditionally approved,” and that, if the property were re-zoned R-5, the property value would be decreased. The bank stated that in order to fund the loan it “must receive verification from Jefferson County that this property will remain zoned R-1 Residential.” Buku sent Appellants’ counsel a letter demanding that all of the earnest money, except for a non-refundable amount from the Peterson contract, be returned. When none of the earnest money was returned, Buku brought suit alleging: (1) return of earnest money under contract; (2) conversion; and, (3) unjust enrichment. Additionally, Buku requested prejudgment interest on the earnest money and attorney fees. Appellants filed a counterclaim with their answer, asserting seven claims: (1) specific performance; (2) breach of contract; (3) unjust enrichment; (4) estoppel; (5) promissory estoppel/unjust enrichment; (6) Consumer Protection Act violations; and, (7) attorney fees. Upon review, the Supreme Court found no error in the district court's judgment, and affirmed its decision to grant summary judgment in favor of Buku. View "Buku Properties v. Clark" on Justia Law

At issue in this case was the definition of the width of an easement for an irrigation pipeline. Dalton Gardens Irrigation District (the District) owned pipeline and intended to replace an existing four-inch pipe with a ten-inch pipe. A portion of the pipeline crosses Diane Ruddy-Lamarca's property. The parties agreed that an easement of some kind existed in favor of the District. However, they disagreed regarding the nature and width of that easement. The district court held that the District had an express easement and an easement by prescription that were identical in location and sixteen feet wide. The District appealed, claiming that the district court erred by restricting the easement to sixteen feet in width and requiring it to make every effort to preserve trees and a drain field on Ruddy-Lamarca's property. Upon review of the district court order, and finding no error in its decision, the Supreme Court affirmed. View "Ruddy-Lamarca v. Dalton Gardens" on Justia Law

Ida-Therm, LLC appealed the grant of summary judgment in favor of Bedrock Geothermal, LLC, which held that a reservation of "all the oil, gas, and minerals, in, on, or under the surface of [deeded] lands," in a 1946 warranty deed included the geothermal resources underlying the property. The district court determined that the Deed's mineral reservation severed the mineral estate from the surface estate, and that geothermal resources were included in the scope of the mineral estate. Because the Supreme Court found that the term "mineral" was ambiguous with respect to the deed in question, and because ambiguous grants in deeds are construed against the grantor, the Court construed the grant in favor of Ida-Therm and reversed the district court. View "Ida-Therm v. Bedrock Geothermal" on Justia Law

Kootenai County (the County) and Panhandle Health District No. 1 (the District) filed an action against Peggy Harriman-Sayler and Terry Sayler, seeking injunctive relief to prevent the Saylers from operating a recreational vehicle (RV) park without a conditional use permit, from occupying or using a building without a certificate of occupancy, and from operating a subsurface sewage system without a permit. The district court granted summary judgment in favor of the County and the District. The Saylers appealed, asking the Supreme Court to vacate the district court's judgment. Their argument on appeal was that the RV park did not require a permit because it was allowed as a nonconforming use and that the sewage system and other building were properly permitted. Finding no error in the district court's decision, the Supreme Court affirmed. View "Kootenai County v. Harriman-Sayler" on Justia Law

The issue before the Supreme Court in this case stemmed from the grant of summary judgment in favor of an insurance company. The insureds contended that the liability coverage provision in their homeowner's policy required the insurer to defend a lawsuit brought by a contractor they hired to repair fire damage to their home and to remodel the home, and that the insurer was required to indemnify against any recovery by the contractor. Upon review of the policy underlying this case, the Supreme Court found no such duties as the insureds contended and affirmed the district court's judgment. View "Linford v. State Farm Fire & Casualty" on Justia Law