Justia Idaho Supreme Court Opinion Summaries

This issue before the Supreme Court in this case centered on an action to recover damages from a well driller who drilled a well that later caved in. The district court granted the well driller's motion for summary judgment on the ground that the alleged claims of negligence and breach of contract were barred by the applicable statutes of limitations, and the court dismissed the action. Upon review, the Supreme Court held that that the breach of contract claim was indeed barred by the statute of limitations and that the negligence claim was barred by the economic loss rule. The Court affirmed the district court's dismissal of the case. View "Stapleton v. Jack Cushman Drilling" on Justia Law

Defendant Abraham Scraggins appealed two district court orders revoking his probation. Defendant was convicted of sexual battery of a minor in 1993, which required that he register as a sex offender in Idaho. In 2009, the State charged him with failure to register when he moved to Ada County in 2008. Defendant pled guilty and received a unified sentence of ten years, five of which were fixed. The sentence was suspended, and Defendant was placed on probation. Under the terms of his probation, Defendant was to serve time in jail at his probation officer's discretion without prior approval of the court. A month after sentencing, the State moved to revoke Defendant's probation, alleging he violated the terms of probation by drinking alcohol and failing to stay at his registered address for a nine-day period. Later in 2009, the State charged Defendant again with failing to register as a sex offender. In a plea agreement, Defendant admitted to violating the terms of his first probation, and pled guilty to failing to register in the second case. The district court revoked Defendant's probation in the first case, and imposed a unified ten-year sentence, with five and one-half years fixed. Less than two months later, probation officers performing a "residence check" found Defendant had contacted his victim, and that he had consumed alcohol. In lieu of filing a report of violation of his probation, Defendant served ten days of the discretionary jail time previously authorized by the district court. At a disposition hearing, Defendant objected to the district court revoking his probation based on these last violations. He argued that because he "had been punished already for this exact same conduct" by serving discretionary jail time, and because "there [was] no new conduct that he has been found in violation for," that a revocation of probation would be a violation of his due process rights. The district court rejected this argument, and accordingly revoked his probation in both cases. It then ordered that the sentences in both cases be executed. Defendant appealed to the Supreme Court, which consolidated the cases on appeal. Upon review, the Court concluded that nothing the probation officers or district court did "affected any articulable due process right." Accordingly, the Court affirmed the district court's decision to revoke Defendant's probation. View "Idaho v. Scraggins, Jr." on Justia Law

This case stemmed from a divorce proceeding between Michael and Susan Vierstra. The magistrate court made a finding regarding the expected tax liability for 2009 when determining the value of the Vierstra family dairy. In its Judgment and Decree of Divorce, the magistrate court ordered the parties to adjust the valuations and equalizations according to the actual tax liability. After Susan objected to the form of the judgment, the magistrate court entered an Amended Judgment which did not alter the language regarding valuation of the dairy and the parties' obligation to adjust the valuations and equalizations. Because the actual tax liability for 2009 turned out to be much less than expected, Susan filed a motion seeking an adjustment of the equalization payment she was due. The magistrate court ultimately denied her motion, and Susan appealed the Amended Judgment to the district court, asserting that the magistrate court erred in its valuation of the dairy and by denying her motion to adjust the equalization payment. The district court dismissed the appeal, holding that Susan had not timely appealed from the judgment that determined the value of the dairy and that the magistrate court lacked jurisdiction to entertain her motion to adjust. After its review of the matter, the Supreme Court affirmed in part and reversed in part. The Court held that Susan's appeal of the factual finding regarding the amount of the parties' tax liability was indeed untimely, and therefore reversed the district court's decision that the magistrate court lacked jurisdiction to consider her Motion to Adjust. View "Vierstra v. Vierstra" on Justia Law

Appellants Hobson Fabricating Corp. (Hobson) and SE/Z Construction, LLC (SE/Z) appealed a district court decision in their case against the State of Idaho, Department of Administration, Division of Public Works (DPW) regarding costs and attorney fees. Prior to the district court's decision, the parties had settled all of their claims but for costs and attorney fees. The district court declared that all parties had prevailed in part and were to bear their own costs and fees. Hobson and SE/Z appealed the decision, arguing that the district court abused its discretion and should have found that they were the overall prevailing party. Upon review, the Supreme Court affirmed the district court's order that the Contractors and DPW bear their own costs and fees and its order that Hobson pay the individual defendants' costs. View "Hobson Fabricating Corp v. SE/Z Construction" on Justia Law

A mother appealed a magistrate court's order terminating her parental rights with respect to her youngest child. John Doe was born in September, 2011, and was declared to be in imminent danger two days after birth. John's mother, Jane Doe (Mother) had eight other children, all with her ex-husband (Father). One died shortly after birth, and the others are aged three to fifteen years old. Mother was not caring for any of these children when the Department of Health and Welfare (DHW) removed John from her care. In its Memorandum Decision and Order issued the same day, the court found by clear and convincing evidence that Mother "cannot parent this child now and that inability will continue indefinitely" and termination of her parental rights would be in the child's best interest. Mother's argument on appeal focused on whether the magistrate court properly weighed the evidence in making its best interest of the child determination. Upon review, the Supreme Court was satisfied that substantial evidence supported the magistrate court's findings, and accordingly held that the magistrate court did not err in determining that termination of Mother's parental rights was in John's best interest. View "Idaho Dept of Health & Welfare v. Jane (2012-05) Doe" on Justia Law

The issue before the Supreme Court in this case was a jury verdict in favor of the sellers of real property in an action by the buyers to recover damages or be granted rescission of the sale contract on the ground that the sellers made misrepresentations and breached the contract and the Idaho Property Condition Disclosure Act. The buyers also sought to raise the issue of mutual mistake. About a year after purchasing the property, Buyers hired a contractor to see if the garage could be enlarged. The Contractor discovered that the building permit obtained to construct the garage had not been finalized, so that it had lapsed. The permit had been issued in 2000 to construct a garage with storage space above it. In connection with the sale, Sellers completed and delivered to Buyers a property disclosure form as required by the Idaho Property Condition Disclosure Act. When completing that form, Sellers answered "No" to the question: "Have any substantial additions or alterations been made without a building permit?" In 2007, Buyers filed this lawsuit against Sellers seeking damages for breach of the Disclosure Act, misrepresentation, and breach of contract. They also sought, in the alternative, to have the real estate contract rescinded. The matter was tried to a jury in 2010, on the three theories seeking damages. The jury returned a special verdict finding that Buyers had failed to prove a violation of the Disclosure Act, had failed to prove misrepresentation, and had failed to prove a breach of contract. On the second day of trial, Sellers moved to prevent Buyers from raising the issue of mutual mistake of fact, which Buyers had apparently discussed in their pretrial brief. The matter was argued, and the district court ruled that Buyers could not present evidence regarding mutual mistake because it had not been pled. On February 25, 2010, and again on March 8, 2010, Buyers moved to amend their complaint to conform to the evidence by adding a request for rescission based upon mutual mistake. On March 8, 2010, Buyers moved to have the real estate contract rescinded, and on August 30, 2010, they moved for a new trial. The district court denied those motions, and Buyers timely appealed. Upon review, the Supreme Court affirmed the judgment of the district court and the court's denial of the motion for a new trial. View "Bolognese v. Forte" on Justia Law

Two real estate developers, a husband and wife, operated through various entities including a corporation and an LLC. In 2002, the corporation borrowed money from a lender; the developers, in their individual capacities, guaranteed this loan and all future advances. The corporation promptly repaid this loan. In 2005, the LLC twice borrowed money from the same lender. The lender originally insisted on a personal guaranty for these loans, but, in order to secure the developer's business, stated that no personal guaranty would be required. In 2006–07, the corporation again borrowed money from the lender in six separate loans. The corporation defaulted on these six loans, and, after the lender foreclosed on the real estate that served as collateral for the loans, the lender sued the developers for the deficiency. The district court granted the lender's motion for summary judgment, holding that the developers' affirmative defenses (1) were barred by the statute of frauds, (2) failed for lack of consideration, and (3) raised no genuine issues of material fact. The developers timely appealed to the Supreme Court. Upon review, the Court held that the developers' affirmative defenses were neither barred by the statute of frauds nor failed for lack of consideration. However, because none of those defenses raised a genuine issue of material fact, the Court affirmed. View "Washington Federal Savings v. Engelen" on Justia Law

This case appealed a district court's denial of Petitioner Jim Brannon's election contest of the Coeur d'Alene city council election in 2009. In the official vote total, Brannon lost the election for seat 2 of the city council to Mike Kennedy by five votes. Brannon then filed an election contest that alleged numerous irregularities and sought to set aside, void, or annul the election. After a bench trial, the district court issued a memorandum decision that affirmed the election result, finding insufficient illegal votes or irregularities to change the outcome of the election. On appeal, Brannon argued that the City delegated its election duties to Kootenai County in contravention of Idaho law, that the district court made numerous factual and legal errors at trial, and that the district court erred in denying Brannon's motion to disqualify and motion for new trial. Upon review and finding no error, the Supreme Court affirmed the decision of the district court. View "Brannon v. City of Coeur D'Alene" on Justia Law

The issue before the Supreme Court in this case centered on an appeal from several district court rulings in an ongoing dispute between Kyle Athay (Athay) and Rich County, Utah (Rich County). Athay was injured in a motor vehicle collision with Daryl Ervin (Ervin), who was fleeing police pursuit. Subsequently, Athay filed a civil suit against the pursuing law enforcement officers from Bear Lake County, Idaho and Rich County. After "Athay II," a jury trial commenced with Rich County as the sole remaining defendant. The jury returned a special verdict for Athay and awarded him $2,720,126.00 in economic damages and $1,000,000 in non-economic damages. The jury found that Ervin was 70% responsible for Athay’s injuries, and that Rich County was responsible for the remaining 30%. On appeal, Rich County argued that the district court made multiple errors: that the district court abused its discretion when it declined to disqualify the presiding judge for the limited purpose of deciding Rich County’s First Motion for a New Trial; that the district court erred by denying Rich County’s first and second motions for new trial; and that the district court erred when it denied Rich County’s Motion for Judgment Notwithstanding the Verdict. Finding no error, the Supreme Court affirmed the decisions of the district court. View "Athay v. Rich County, Utah" on Justia Law

Ronald (Ron) and Dorothy Arnold appealed the district court's decision to grant a constructive trust property interest in favor of Ron's sister, Mary Snider (Toni) and her husband, Steve Snider. The property in question is a cabin and accompanying forest service permit for land located in Valley County. Toni and Ron's father built the cabin and willed it, along with the permit, to his wife, Bette Arnold. The district court imposed a constructive trust on the property in favor of the Sniders finding that Bette transferred the property to both the Arnolds and the Sniders in 1983. The Arnolds appealed the decision, arguing that the Sniders failed to present clear and convincing evidence of a constructive trust and the district court's finding that Bette intended to give the property to both parties was clearly erroneous. Upon review, the Supreme Court found no error and affirmed the opinion of the district court. View "Snider v. Arnold" on Justia Law