Justia Idaho Supreme Court Opinion Summaries

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

This appeal arose from a condemnation action brought by the Idaho Transportation Board (ITB) against HI Boise, LLC. ITB sought to acquire a strip of land as part of a project to improve the I-84/Vista Avenue Interchange in Boise. ITB offered HI Boise the condemned property's appraised value of $38,177, but HI Boise filed a counterclaim for inverse condemnation, claiming damages of $7.5 million for additional lost rights of access and visibility. HI Boise appeals the district court's summary dismissal of those claims. Because the Supreme Court found that neither claim involved a compensable taking, the Supreme Court affirmed. View "Idaho Transportation Board v. HI Boise, LLC" on Justia Law

This appeal arose from a products liability action brought by Jesus Hurtado and John Reitsma, d/b/a J & J Calf Ranch (J & J), against Land O'Lakes, Inc. (Land O'Lakes). J & J alleged that the Land O'Lakes milk replacer it used to feed its dairy calves was defective and caused the death of more than one hundred calves. A jury found in favor of J & J and awarded damages. Land O'Lakes appealed, arguing that the district court improperly admitted expert testimony and that J & J failed to prove both liability and damages. Land O'Lakes petitioned the Supreme Court to vacate the judgment of the district court and enter judgment in its favor or, alternatively, to vacate the judgment and order a new trial. J & J cross-appealed the district court's award of attorney fees, arguing that the court abused its discretion by excluding fees incurred before and during previous litigation in this matter. J & J petitioned the Supreme Court to vacate the award of attorney fees and remand with instructions to include attorney fees accrued in the first trial in its calculation of reasonable attorney fees. Upon review, the Supreme Court affirmed, holding that Land O'Lakes waived issues regarding expert testimony. The Court affirmed the jury verdict because it was supported by substantial competent evidence and affirmed the district court's award of attorney fees because it properly exercised its discretion. View "Jesus Hurtado v. Land O' Lakes, Inc." on Justia Law

This case was the third appeal to the Supreme Court arising from a 2002 real estate transaction between Thomas and Colleen Birch-Maile and the Theodore L. Johnson Revocable Trust. Attorney and Real Estate Broker Thomas Maile advised the Trust to reject an offer to sell certain trust property. Months later, Mr. Maile submitted an earnest money agreement for the same property. The prospective buyers, collectively the Taylors, sued the Mailes and Berkshire Investments, LLC (the company that the Mailes formed and to whom they assigned rights to the property) for professional malpractice and breach of fiduciary duties. The Mailes filed suit seeking to set aside a 2006 judgment against them, which the Court affirmed in the second appeal. The district court determined on summary judgment that the 2006 judgment was res judicata with regard to the issues raised in the Mailes' complaint. At trial the jury awarded damages against the Mailes on the Taylors' counterclaim. The Mailes appealed and the Supreme Court affirmed: the district court was correct in summarily dismissing the Mailes' lawsuit and denying their motion for JNOV. Further, the district court did not abuse its discretion in awarding attorney to two of the prospective buyers. View "Berkshire Investments, LLC v. Taylor" on Justia Law

The issue before the Supreme Court in this case concerned the approval of a permit application for a Livestock Confinement Operation (LCO), also known as a Concentrated Animal Feeding Operation (CAFO), by the Jerome County Board of County Commissioners. The Board approved the application after a remand by the district court of the Board's decision previously denying the permit. Several individuals and organizations opposed to the LCO because of the potential harms to the neighboring farms and to the Minidoka National Historic Site petitioned the district court for review of the Board's decision. The district court affirmed the Board's approval of the permit, finding in the process that four of the organizations concerned with the effects on the Minidoka National Historic Site lacked standing. Several of the objecting parties appealed the district court's decision, asking the Supreme Court to find that these parties had standing to challenge the permit approval, that the Board's procedure for presenting evidence before the Board violated procedural due process rights, and that the Board failed to follow all of the county's relevant zoning ordinances when it approved the application. The issue central to the Court's opinion pertained to standing of all the appellant-organizations, the Board's procedure for presenting evidence throughout the LCO permit application process, the constitutionality of the "one mile rule" of Idaho Code section 67-6529, and the application of the Jerome County Zoning Ordinances. The Court concluded that the Board properly applied its zoning ordinance to the LCO permit application process, that I.C. 67-6529 was not unconstitutional, and that the public was afforded appropriate due process prior to, and during the LCO permit application hearing. View "Friends of Minidoka v. Jerome County" on Justia Law

After moving from the address that he reported to the Idaho State Police Sex Offender Registry pursuant to the sex offender registration requirements of I.C. 18-8309 (2001) and having been extradited from Belize, Defendant David Leroy Lee was convicted of Failure to Register as a Sex Offender in 2009. Defendant asserted on appeal that the plain language of I.C. 18-8309 did not require sex offenders to register or update their address information with either the Registry or the sheriff of the county where the offender was required to register after moving to another country. In the alternative, he contended that the State failed to provide evidence establishing beyond a reasonable doubt that he moved from his last known address to a definite new address or actual residence thereby triggering his duty to notify the Registry or the sheriff. Furthermore, Defendant claimed that I.C. 18-8309 was unconstitutionally vague and that his due process rights were violated. Upon review, the Supreme Court found that the evidence was not sufficient to prove beyond a reasonable doubt that Defendant changed his address or actual residence. The Court therefore vacated the district court's Amended Judgment of Conviction, and remanded this case with instructions for the entry of a judgment of acquittal. View "Idaho v. Lee" on Justia Law