Justia Idaho Supreme Court Opinion Summaries

Defendants Jay and Theresa Knowlton appealed the grant of summary judgment in favor of Plaintiffs-Appellants Tapadeera, LLC and Cary Hamilton (d/b/a C&J Construction) on their claim that Defendants prevented Plaintiffs from performing a settlement agreement to resolve a lawsuit between the parties. Tapadeera owned a parcel of property that had been platted as one lot. Tapadeera sold the property as two parcels -a two-acre parcel and a six-acre parcel purchased apparently under a real estate contract. The purchasers had a modular home placed on the two-acre parcel, but they failed to make the payments due in both transactions. As a result, the lender foreclosed on the two-acre parcel, and Tapadeera regained title to the six-acre parcel. Defendants desired both parcels to construct a home. They purchased the two-acre parcel from the bank, and contracted with Tapadeera to purchase the six-acre parcel. After making several payments under the contract, Mr. Knowlton contacted Cary Hamilton, Tapadeera's president, to determine the amount necessary to pay the contract in full. Mrs. Knowlton recorded the deed, and the Knowltons stopped payment on the check when they discovered that they could not obtain a building permit for the six-acre parcel because it had been wrongly divided from the two-acre parcel. For over four years, neither party took any action regarding this transaction. Eventually the parties sought to finish the deal, and it headed to court. Mr. Hamilton agreed to fix the subdivision problem and the Knowltons agreed to pay the balance owing. However, when notice of the subdivision was mailed to adjacent and affected property owners, the Knowltons were omitted from the notice. They learned of the hearing regarding the subdivision after it was over; they gave notice that they were withdrawing their subdivision application. The court held that the county's approval of the subdivision application was a condition precedent to the Knowltons' obligation to pay the balance, but that they had wrongfully prevented performance of that condition by withdrawing the subdivision application. The Knowltons moved for reconsideration which was denied. Upon review, the Supreme Court affirmed: "This case illustrates the time and expense that can be wasted when the parties fail to exercise common sense to resolve an issue. Clearly, Tapadeera should have had the lot subdivided in connection with the first sale. When the issue arose after the sale of the six-acre parcel to the Knowltons, the parties should have met and agreed to the resolution they reached six years later. Once they did so, they both should have been reasonable in doing whatever was necessary to effectuate the replatting of the lot." View "Tapadeera v. Knowlton" on Justia Law

Plaintiffs Paul Trunell and Bill Lomu appealed a district court's ruling against them in their request for injunctive relief. Plaintiffs' complaint alleged the existence of a public road across Defendant Verna Fergel's property, and that she denied access to the road causing damage to Plaintiffs. The district court held that Defendant was a bona fide purchaser for value, and that she did not have actual or constructive notice of the public nature of the road when she purchased the property. Upon review of the trial court record, the Supreme Court found that the "bona fide purchaser for value" defense was not available to Defendant as it would have constituted an abandonment of the road in contravention to Idaho law. The Court therefore reversed the district court's holding and remanded the case for further proceedings. View "Trunnell v. Fergel" on Justia Law

Petitioner Richard Leavitt petitioned the Supreme Court for a writ of mandamus to direct the Commission of Pardons and Parole (Commission) to schedule a full hearing on his petition for commutation and comply with its rules for such a hearing by publishing notice of the time and place of the hearing in a newspaper of general circulation at least once per week for four weeks prior to the hearing. After the Supreme Court affirmed the issuance of Petitioner's death warrant, the Commission denied Petitioner's request for a hearing. Petitioner asked the Supreme Court to set a date for a hearing wherein the Commission must show cause why a full hearing should not be conducted; if granted, the hearing would effectively stay his execution. Upon review, the Supreme Court concluded that the Commission was not required to grant Petitioner a full, open hearing regarding his commutation petition. Furthermore, Petitioner did not demonstrate that his request for the writ of mandamus or alternative writ should have issued. Accordingly, the Court denied Petitioner's requests. View "Leavitt v. Craven" on Justia Law

Plaintiff-Appellant Victoria Johnson appealed the district court's grant of summary judgment in favor of North Idaho College (NIC) on her claim of discrimination under the Idaho Human Rights Act (IHRA). Plaintiff alleged one of her instructors sexually harassed her, and that NIC was vicariously liable for that harassment. The district court held that NIC's affirmative defense was factually support, and that she failed to establish a genuine issue of material fact. Upon review of the facts of this case, the Supreme Court concluded that the district court did not err in finding that no genuine issue of material fact existed in regard to Plaintiff's claims. Accordingly the Court affirmed the opinion of the district court. View "Johnson v. North Idaho College" on Justia Law

Appellant Richard Leavitt appealed his death warrant. He also appealed the district court's denial of his motion to quash the death warrant. In 1984, Appellant brutally attacked, sexually mutilated and murdered a 31-year-old woman in Blackfoot, in which a jury found him guilty of first-degree murder. In 1989, the Supreme Court affirmed his conviction, but reversed the death sentence because the trial court failed to weigh all the mitigating factors against the statutory aggravating factor that the murder was especially heinous, atrocious or cruel manifesting in exceptional depravity. On remand, the district court held another sentencing hearing and again sentenced Appellant to death. The warrant was issued in 1992, with a scheduled date of execution 23 days later. The United States Supreme Court granted Appellant's stay of execution. In 2000, Appellant was granted the writ of habeas corpus because of an improper jury instruction and ordered the State to retry Appellant. The State appealed, and the Ninth Circuit reversed the habeas order. The case was remanded to determine whether Appellant's resentencing hearing in 1989 violated his constitutional rights. In 2007 on remand, the district court again granted habeas relief. The State appealed in 2011, and the Ninth Circuit again reversed the habeas order. In 2012, Appellant filed a motion for relief from judgment; the Ninth Circuit issued a mandate automatically lifting any stay previously imposed by the habeas court. The habeas court denied Appellant's motion, and denied his request for a stay of execution. Appellant's appeal of that order was pending before the Ninth Circuit, but anticipating the issuance of a new death warrant, he filed notice of Demand for Opportunity to be Heard regarding the Issuance of the Death Warrant in Idaho district court. The court denied the motion because at that time, no stay of execution or death warrant was then pending before any court. Subsequently, the court signed Appellant's death warrant and scheduled his execution. Appellant raised multiple challenges to each procedural stage of his case, from sentencing, habeas relief, constitutional rights violations and the eventual signing of his death warrant. Taking all in turn, the Supreme Court found no errors arising from this case's journey to the Idaho Supreme Court. Accordingly the Court affirmed the district court and declined to stay Appellant's execution. View "Idaho v. Leavitt" on Justia Law

The issue in this case arose from a judgment which held that a "Designated Project or Premises" endorsement of a commercial general liability insurance policy purchased by a sporting goods store excluded coverage for a claim arising out of the sale of improperly reloaded ammunition. Petitioner Tom Erekson purchased a used .500 revolver from a sporting goods store, along with three boxes of handloaded ammunition, all of which the store purchased from the gun's previous owner. Erekson and his sons took the revolver to a shooting range, loaded five chambers with the reloaded ammunition, and fired. The one cartridge discharged, but two others detonated simultaneously. When the cartridge under the loading gate detonated, it sheared off the gate, a portion of the cartridge rocketed rearward, and struck Erekson in the forehead, lodging three inches into his brain. He also lost a portion of his thumb. The store held a general liability policy through Markel International Insurance Company. The store brought suit for a court order to declare Erekson's injuries were covered under the policy. The district court held that the injury was excluded; Erekson unsuccessfully moved for reconsideration. Upon review of the policy, the Supreme Court affirmed, finding coverage was excluded under the endorsement. View "Markel International Ins. Co. v. Erekson" on Justia Law

A jury returned a special verdict that: (a) awarded damages against an attorney and his girlfriend based upon the jury's finding that they had breached their fiduciary duties to a former client of the attorney by purchasing half of his stock in a closely held corporation for less than its fair market value; and (b) cancelled debts owing by the corporation to the attorney and his girlfriend based upon the jury's finding that they had breached their fiduciary duties to a shareholder, the former client's widow, by making loans to the corporation. The district court granted a new trial on the ground that there was insufficient evidence to justify the verdict, and this appeal followed. Finding sufficient evidence to support the jury's verdict, the Supreme Court affirmed the grant of a new trial. View "Berry v. McFarland" on Justia Law

The issue on appeal in this case came from a decision of a district court which held that in a hearing regarding an administrative license suspension pursuant to Idaho Code section 18-8002A, the hearing officer must consider the margin of error of the breath testing machine when determining whether the test results support suspension. Facing a license suspension, Defendant Alma Elias-Cruz argued at trial that any suspension must be based upon her actual blood alcohol concentration rather than the alcohol concentration as shown by the test because, due to the test's margin of error, her actual blood alcohol content could have been below the statutory limit, and that the testing equipment had not been calibrated once a year as recommended by its manufacturer. The district court ruled sua sponte that her due process rights were violated by the hearing officer's rejection of the equipment's margin of error and that she had a statutory right to present such evidence. The court vacated the hearing officer's decision and ordered the matter remanded. The State then timely appealed. The Supreme Court reversed: "[u]nder Idaho Code section 18-8002A(1)(e), by definition the test results show the alcohol concentration. The issue is not the alcohol concentration in the blood. It is the alcohol concentration as shown by the test results. There is nothing to which to compare the test results. All that is required is that the test results show that the alcohol concentration was above the legal limit." The Supreme Court concluded the district court erred in its interpretation of that statute. View "Elias-Cruz v. Idaho Dept. of Trans." on Justia Law

The issue on appeal to the Supreme Court concerned Appellant Daniel Fuchs appeal of a district court's decision which found that the Director of the Idaho State Police Alcohol Beverage Control (ABC) had properly exercised his discretion when he ruled that neither party had been a prevailing party for the purposes of attorney fees. Fuchs was issued a Retail Alcohol Beverage License and subsequently opened Aubrey's House of Ale (Aubrey's) in Coeur d'Alene. The Alcohol Beverage Control Bureau Chief conducted an unannounced inspection of the premises. After this inspection, ABC filed a Complaint for Forfeiture or Revocation of Retail Alcohol Beverage License regarding Fuchs's license. Eventually, the parties filed cross motions for summary judgment in the action before an ABC hearing officer. After oral argument, the hearing officer granted summary judgment to Fuchs. On appeal to the Director of the ABC, the Director did not order Fuchs' license revoked because of confusion surrounding the proper interpretation of the applicable rule under which Fuchs was cited. The Director's Final Order addressed the hearing officer's erroneous application of quasi-estoppel and Fuchs' unsuccessful arguments regarding improper rulemaking and claim that the agency acted arbitrarily. The Director denied attorneys' fees to both parties, declaring neither was the prevailing party because neither acted without a reasonable basis in fact or law. Upon review, the Supreme Court agreed that Fuchs was not a prevailing party and affirmed the district court's decision to deny fees. View "Fuchs v. Idaho State Police" on Justia Law

The issue before the Supreme Court in this was the denial of attorney fees under Idaho Code section 41-1839 on the ground that the insured's proof of loss was insufficient under the statute because it did not provide the insurer with the legal theory upon which coverage was later determined to exist. Upon review of the matter, the Supreme Court vacated the judgment because a proof of loss need not include an analysis of the proper theory of coverage under the insurance policy. View "Estate of Benjamin Holland v. Metropolitan Property & Casualty Ins." on Justia Law