Justia Idaho Supreme Court Opinion Summaries

This case concerned the Director (Director) of the Idaho Department of Water Resources' application of the Rules for Conjunctive Management of Surface and Ground Water Resources (CM Rules) in response to a ground water to ground water delivery call filed by the A&B Irrigation District (A&B). The Director’s Final Order found that A&B was not materially injured and was affirmed by the district court on nearly all points. A&B appealed to the Supreme Court, contending that the Director and the district court erred in their analyses. The City of Pocatello and the Idaho Ground Water Appropriators, Inc. cross-appealed alleging that the district court erred by requiring that the Director's finding of no material injury must be supported by clear and convincing evidence, rather than a preponderance of the evidence. Upon review of the matter, the Supreme Court affirmed the decision of the district court. View "A & B Irrigation v. Idaho Dept of Water Resources" on Justia Law

On remand, the district court granted Wayne Dawson's Motion for Relief from Judgment and issued its Second Amended Judgment, which in part quieted title to and in part took judicial notice of four undivided one-fourth interests in a forty-acre parcel of land located in Teton County. On appeal, John Bach contended, among other things, that Dawson lacked standing to file his Motion for Relief from Judgment and that the district court abused its discretion and lacked personal and subject matter jurisdiction when it granted the Motion for Relief from Judgment and entered the Second Amended Judgment. Because all of Bach's claims were either frivolous or waived, the Supreme Court affirmed the Second Amended Judgment. View "McLean v. Cheyovich Family Trust" on Justia Law

This case concerned an appeal of a magistrate court's Finding of Fact, Conclusions of Law and Order in denying Appellant Maureen Erickson's Motion for Partial Distribution of her mother's estate. The magistrate court found that the property Maureen sought to partially distribute was not part of the assets of her mother's estate. On appeal to the district court, the court affirmed the decision of the magistrate court and alternatively found that the matter was barred by the statute of limitations. Upon review, the Supreme Court affirmed the district court's decision that this case was barred by the statute of limitations. View "Erickson v. McKee" on Justia Law

This appeal involved a dispute over whether Capstar Radio Operating Company held an easement over the property of Douglas and Brenda Lawrence. Capstar filed a Motion for Summary Judgment, alleging in the alternative, that an easement existed based on the theory of either an easement by implication, an easement by necessity, or a prescriptive easement. The district court filed its Order granting summary judgment, finding that Capstar holds an easement implied by prior use, an easement by prescription, and an easement by necessity. The Lawrences appealed to the Supreme Court, arguing that the district court erred in granting summary judgment because genuine issues of material fact existed. The Lawrences also argued that the district court abused its discretion by failing to recuse itself for alleged bias, and that the lower court erred in determining that the Lawrences' defenses of laches and statute of limitations were meritless. Upon review, the Supreme Court reversed the district court's order granting summary judgment and remanded the case for trial on the (1) easement implied by prior use, (2) easement by necessity, and (3) prescriptive easement theories. The Court affirmed the district court's decision denying the Motion for Disqualification for Cause and affirms the court's ruling that the Lawrences' defenses of laches and statute of limitations were without merit. Nevertheless, the Court ordered that a new judge be assigned to preside over all further proceedings in this case. View "Capstar Radio v. Lawrence" on Justia Law

Two personal injury actions and one wrongful death action arising out of an automobile accident were consolidated on appeal before the Supreme Court. In 2007, Paul -Smith's vehicle collided with a semi-tractor trailer driven by Robert Petrovich. Nicole Plouffe and Tiffany Ann Marie Fragnella were both passengers in Smith's vehicle. Plouffe was severely injured and Fragnella died as a result of her injuries. At the time of the accident, Petrovich was driving the semi-truck for Swift Transportation Co., Inc., and was training a Swift Transportation employee in driving skills. The Swift Transportation trainee, Thomas Thayer, was a passenger in the semi-truck at the time of the collision. Thayer was covered under Swift Transportation's workers' compensation insurance. Smith and his passengers' Amended Complaint alleged that Petrovich was negligently driving the semi-truck. The district court granted summary judgment in favor of the Petrovich and Swift, finding that there was no evidence that the accident was caused by Petrovich. The district court also concluded that a third party claim for negligence against Petrovich was separately barred by the exclusive remedy rule under Idaho's Workers' Compensation statutes. Smith appealed to the Supreme Court arguing that the district court erred in granting summary judgment, that the court abused its discretion in denying the Motions for Reconsideration, and that the court erred in determining that the exclusive remedy rule barred the third-party claims against Petrovich. Upon review, the Supreme Court affirmed the district court's grant of summary judgment in favor of Petrovich, and found no error in the district court's decision. View "Fragnella v. Petrovich" on Justia Law

Jerry and Terry Machado (the Machados) and Richard Clifton appealed a district court's decision finding that their properties were burdened by an express easement and an implied easement by necessity in favor of Charles and Carol Ryan and Kristopher Jones. Ryan and Jones cross-appealed the district court's failure to rule on their claims of implied easement by prior use and easement by prescription. In 1970, Promised Land & Cattle Company conveyed a parcel of land to Timberland Resources, Inc., which included an easement to a then-existing logging road. Later that year, Timberland sold the land to Clifton with the deed containing the easement. The Ryans purchased an adjacent parcel to the Clifton property, conveyed with "all tenements, hereditaments and appurtenances thereunto belonging." The Ryans built a home on the property, accessing their parcel by a private road, access to which was via the former logging road. From 1993 until this suit was filed, the Ryans maintained the private road. Timberland conveyed another portion of its parcel to Jones, with the deed containing reference to the private road. When Clifton purchased his lot from Timberland, there was no public road providing access to what later became the Jones property, and the only access to the Jones property was the private road. Machado filed a complaint to quiet title and for declaratory relief in 2007 with regard to the easement across his property from the private road. Ryan answered and counter-claimed, asking the district court to find an easement of Machado's property by express, implied by necessity, implied by prior use and prescription. Jones was permitted to intervene. Upon review of the district court record, the Supreme Court found that the deed from Timberland to Clifton was unambiguous and did not create an express easement. The Court concluded that there existed an implied easement by necessity as to the Jones property, but to as to the Ryan property. With regard to the Ryans, the Court concluded that the Ryans could not "create" an implied easement because they sited their home in the lease accessible quadrant of their property. The Court reversed the district court with regard to finding an express easement over the Machado property and for finding an easement implied by necessity over the Machado and Clifton properties for the benefit of the Ryans. However, the Court affirmed the district court finding an easement implied by necessity for the benefit of the Jones property. The case was remanded for further proceedings on issues that were not addressed due to the court's findings on the other easement issues. View "Machado v. Ryan" on Justia Law

The issue on appeal before the Supreme Court pertained to an order suppressing evidence. A law enforcement officer following two vehicles turned on the overhead lights of his patrol car in order to pull over the lead vehicle. Both vehicles pulled over, and the officer parked his car behind the lead vehicle and several car lengths in front of the rear vehicle. When the officer got out of his car, he walked back to the rear vehicle to tell the driver he was only stopping the lead vehicle. The district court held that by walking towards the rear vehicle, the officer seized its occupants without a reasonable, articulable suspicion that they had violated any law. The Supreme Court reversed: when approaching the rear vehicle, the trooper did not draw his gun or make any hand gestures indicating that the vehicle should not leave, nor did he even shine his flashlight at it. Considering the totality of the circumstances in this case, the trooper did not seize the rear vehicle by walking up to the driver's door. His actions certainly indicated that he wanted to talk to the driver, but the Supreme Court concluded that did not constitute a seizure. View "Idaho v. Ray" on Justia Law

This case concerned the ownership status of Coolwater Ridge Road in Idaho County. The predecessors in interest of appellant Paddison Scenic Properties, Family Trust, L.C. granted rights of way to the United States for a road which became Coolwater Ridge Road. In the district court, Paddison sought a declaratory judgment that the rights of way did not constitute a public road or highway under Idaho law. That court held that the rights of way were public because the criteria for common law dedication were met. Upon review, the Idaho Supreme Court vacated the district court's judgment because it concluded this case was not ripe for adjudication. View "Paddison Scenic Properties Family Trust v. Idaho County" on Justia Law

This appeal was a consolidation of two actions relating to residential leases on State endowment lands. In one action, the Attorney General sought a declaratory ruling that I.C. 58-310A, which exempts so-called "cottage site" leases from conflict auctions, was unconstitutional in light of Article IX, section 8 of the Idaho Constitution. The district court determined that I.C. 58-310A was constitutional, and thus, dismissed the Attorney General's complaint. The Attorney General appealed that decision. In the other action, Gladys Babcock and several others who lease cottage sites on Payette Lake filed an action against the State Board of Land Commissioners and the Idaho Department of Lands Director. The Payette Lake Lessees alleged that the Board breached their lease agreements when it declined to renew the expiring leases for an additional ten years. The district court granted summary judgment to the Board, finding the Payette Lake Lessees had failed to exhaust their administrative remedies. The Payette Lake Lessees filed a cross-appeal challenging that decision. Upon review of the cases, the Supreme Court reversed the district court's ruling on the Attorney General's claim because I.C. 58-310A was unconstitutional. The Court vacated the district court's holding with respect to the Payette Lake Lessees' claim and remanded both cases for further proceedings. View "Wasden v. Board of Land Commissioners" on Justia Law

This appeal arose from a dispute between two competing creditors, DAFCO, LLC, and New Phase Investments, LLC. DAFCO appealed the district court's determination on summary judgment that DAFCO's deed of trust, although first recorded, was void under I.C. 32-912 because it encumbered community real property but was not signed by both spouses. Because I.C. 32-912 was enacted for the protection of the community rather than third-party creditors, the Supreme Court found that New Phase could not invoke that statute to void DAFCO's competing encumbrance. Accordingly, the Court reversed: the district court erred in declaring DAFCO's trust deed void under that statute at New Phase's request. View "New Phase Investments v. Jarvis" on Justia Law