Justia Idaho Supreme Court Opinion Summaries

Plaintiffs-Appellants JoAn and Fred Ball were patrons of the City of Blackfoot's municipal pool. JoAn slipped on ice accumulated on the sidewalk between the pool and the parking lot. The Balls brought suit against the City. A district court granted summary judgment in favor of the City, dismissing the Balls' claims on grounds that property owners are not liable for injuries resulting from natural accumulations of snow or ice. The Balls appealed. Upon further review, the Supreme Court concluded the district court appealed the wrong legal standard to the Balls' case, and therefore its grant of summary judgment was in error. The Court reversed the district court and remanded the case for further proceedings. View "Ball v. City of Blackfoot" on Justia Law

When "Child" was three years and seven months old, his Mother was arrested while Child was in her care. Since Father was already incarcerated, the state declared Child to be in imminent danger. Child was placed in the the Department of Health and Welfare's custody, and a child protection case was initiated. The matter proceeded to trial, after which the trial court granted the Department's petition to terminate Father-Petitioner John Doe's parental rights. Father appealed. Finding clear and convincing evidence that termination of Father's parental rights were in Child's best interests, the Supreme Court affirmed the trial court's decision to terminate. View "Department of Health & Welfare v. Doe" on Justia Law

This appeal arose from a decade-long fight over title to a piece of real property. Juan Cuevas allegedly agreed to sell the property to Defendant-Counterclaimant-Appellant Bernardino Barraza in 2001. However, after Barraza failed to pay the purchase price, Juan filed a quiet title action against Barraza. Barraza defaulted. While Barraza was seeking to set aside the default, Juan quitclaimed the property to his relative, Plaintiff-Counterdefendant-Respondent Wilfrido Cuevas. Meanwhile, Barraza was successful in setting aside the default on appeal. On remand, Juan defaulted and the district court quieted title in Barraza. Wilfrido then filed the present quiet title action against Barraza, in which the district court found the default judgment against Juan void and quieted title in Wilfrido. Upon review, the Supreme Court held that the default judgment against Juan is void, but vacated the summary judgment quieting title in Wilfrido as against Barraza. View "Cuevas v. Barraza" on Justia Law

As a team building exercise, Plaintiff-Appellant Paul Morrison's employer wanted him and his coworkers to participate in a program at Defendant-Respondent Northwest Nazarene University that included a climbing wall activity. Several days prior to doing so, Plaintiff's employer required him to sign an agreement prepared by the University holding it harmless from any loss or damage he might incur due to the University's negligence or that of its employees. This appeal arose from the district court's grant of summary judgment that held Plaintiff's action for personal injuries suffered when he fell from the climbing wall was barred by the hold harmless agreement. Upon review, the Supreme Court concluded the district court did not err in dismissing Plaintiff's negligence claim because he was barred by the hold harmless agreement. View "Morrison v. Northwest Nazarene University" on Justia Law

Real estate purchasers Thomas and Vicki Stevenson appealed the district court's grant of summary judgment that dismissed their unjust enrichment claim against Windermere Capital Group (Windermere), broker to seller 323 Jefferson, LLC (Jefferson). The Stevensons desired to purchase a condominium from Jefferson, and the parties executed a Real Estate Purchase and Sale Agreement (REPSA) for that purpose. Pursuant to the REPSA, the Stevensons deposited $38,000 earnest money with Jefferson’s broker, Windermere. Upon the Stevensons' written authorization, Windermere transferred the funds to Jefferson. Jefferson then paid Windermere a partial commission pursuant to an Exclusive Seller Representation Agreement which obligated Jefferson to pay Windermere a commission whenever a ready, willing, and able purchaser was procured. Jefferson decided not to sell the condominium to the Stevensons and notified them that it was terminating the REPSA. The REPSA specified remedies upon default by either of the parties to the agreement. In the event that Jefferson failed to comply with any term of the agreement, the Stevensons were entitled to their deposit plus interest. Despite this unambiguous provision, Jefferson failed to return the deposit. The Stevensons filed suit against both Jefferson and Windermere. Their complaint alleged that Jefferson breached the REPSA and also advanced a claim of unjust enrichment against both Jefferson and Windermere. The Stevensons also asserted that the REPSA was unenforceable because it did not contain an adequate legal description. Jefferson settled with the Stevensons, agreeing to refund the Stevensons' earnest money, less the commission paid to Windermere. Windermere answered and cross-claimed against Jefferson, alleging two counts of breach of contract, two counts of unjust enrichment and one count of fraud. Windermere later moved for summary judgment as to the Stevensons’ unjust enrichment claim. Upon review, the Supreme Court held that the district court properly exercised its discretion and affirmed the award of summary judgment to Windmere. View "Stevenson v. Windermere Real Estate" on Justia Law

Plaintiff-Appellant Robert Arambarri was Regional Director of Region VI with the Idaho Department of Health and Welfare. In this capacity, he was a non-classified, at-will employee serving at the pleasure of the Director of the Department. Due to budget reductions, four of the seven regional director positions, including Plaintiff's position, were eliminated by the Director. Responsibility for the seven administrative regions was consolidated in the remaining three regional directors. Plaintiff contended that the Director did not have the statutory authority to abolish those positions. He further contended that the Idaho Board of Health and Welfare did not properly concur with a formal vote in the elimination of the four regional director positions. Upon review, the Supreme Court concluded that the district court did not err when it granted the Director's Motion for Summary Judgment and the denial of Plaintiff's Motion to Strike did not affect his substantial rights. The Court affirmed the judgment in favor of the Department. View "Arambarri v. Armstrong" on Justia Law

Claimant Gary Brown filed a complaint with the Industrial Commission seeking disability benefits after he injured his back while working for The Home Depot. Arguing that the injuries caused by the accident in combination with his preexisting conditions, left him permanently and totally disabled, Claimant sought workers' compensation benefits from both Home Depot and the Idaho Industrial Special Indemnity Fund (ISIF). The Commission determined that Claimant was not permanently and totally disabled. Claimant contended on appeal that the Commission erred by evaluating his ability to find work based upon his access to the local labor market at the time his medical condition stabilized in 2005. He argued that his labor market access should have been evaluated as of the date of the Commission hearing in 2009. He also argued that the Commission based its finding that he was 95 percent disabled on an incorrect understanding of the expert testimony presented at the hearing. Upon review, the Supreme Court held that Claimant's labor market at the time of the disability hearing was the proper labor market to be used in evaluating his disability. But because the Commission applied an incorrect legal standard, the Court vacated the Commission's decision and remanded the case for further proceedings. View "Brown v. Home Depot" on Justia Law

In April and June of 2008, Best of the Best Auto Sales, Inc. purchased seven vehicles from Dealers Auto Auction of Idaho and Brasher's Idaho Auto Auction with checks that were returned for insufficient funds. As a result, Dealers and Brasher refused to provide Best of the Best with the titles to the vehicles. Best of the Best then sold the vehicles to Idaho consumers without providing them with titles. Dealers and Brasher filed claims with CNA Surety d/b/a Western Surety Company which acted as a surety for a "$20,000 Vehicle/Vessel Dealer Bond." Best of the Best was the principal. Upon Best of the Best's failure to provide evidence or defenses for Dealers' and Brasher's claims, Western Surety alleged that it lawfully settled those claims in good faith upon the condition that the consumers received their titles, even though they were not based on final judgments. Plaintiff Nick Hestead submitted his claim, which was based on a final judgment. Plaintiff's claim involved fraud and fraudulent representation concerning a separate vehicle that he purchased from Best of the Best that was previously branded a lemon in California. Western Surety responded by asserting that the Dealer Bond was exhausted. Plaintiff contended that the plain meaning of I.C. 49-1610(4) provides that his claim should be given priority because it was submitted thirty days after a final judgment was entered, unlike Dealers' and Brasher's claims. Western Surety asserted that the plain meaning of I.C. 41-1839(3) permits sureties to settle Dealer Bond claims in good faith. Upon review, the Supreme Court found that the payments on the surety bond were lawfully made in good faith pursuant to I.C. 49-1610(1) and I.C. 41-1839(3) because Dealers' and Brasher's claims were undisputed and supported by competent evidence. View "Hestead v. CNA Supply dba Western Surety Co." on Justia Law

Appellant Lincoln McNulty worked as a ski patroller for Sinclair Services Company as a member of the Sun Valley Resort from 2005 to 2010. Once the ski season ended in 2009, Appellant filed for unemployment benefits effective April 2009, through November 2009. During those off-season months, he began working part-time at the Sawtooth Club for extra income. However, Appellant failed to report such employment or any earnings from the Sawtooth Club to the Idaho Department of Labor when he filed for unemployment benefits each week. The Idaho Department of Labor discovered the discrepancy and a claims investigator spoke with Appellant and ultimately issued an Eligibility Determination that Appellant was ineligible for benefits because he willfully made false statements or failed to report material facts in order to obtain benefits. Appellant appealed to the Supreme Court, arguing that his failure to report was not willful, the facts were not material, and that he should be eligible for a waiver of the requirement to repay the unemployment benefits. Upon review, the Court affirmed the Industrial Commission's conclusion that Appellant willfully failed to disclose material facts in order to obtain unemployment benefits and that he must repay the overpayment of both state and federal benefits as well as any applicable interest and penalties. View "McNulty v. Sinclair Oil" on Justia Law

Appellant John Stem was helping to load a forklift at his place of work when another employee backed the forklift over a water meter cover which broke under the weight of the forklift. The forklift toppled and pinned Appellant to the ground, resulting in severe injuries and the amputation of his right leg. He sued Respondent Wesley Prouty, the owner and landlord of the property where the accident occurred, for negligence under a theory of premises liability for failing to keep the premises safe. Appellant alleged that the water meter cover was a light duty cover and was inadequate to support heavy duty vehicles such as forklifts. He later amended his complaint to include a negligence-per-se claim against Respondent for failing to obtain a building permit in violation of city and state codes, which he argued would have likely led to the discovery of the defective water meter cover. The district court granted Respondent's Motion for Partial Summary Judgment, dismissing the negligence claim based on premises liability. Respondent filed a second Motion for Summary Judgment on the negligence-per-se claim which was originally denied by the court. Then, upon Motion for Reconsideration, the court granted Respondent summary judgment. Appellant appealed the judgments in favor of Respondent. Upon review, the Supreme Court found no genuine issues of material facts. Accordingly, the district court did not err in granting summary judgment in favor of Respondent. View "Stem v. Prouty" on Justia Law