Justia Idaho Supreme Court Opinion Summaries

In 2003, Appellant Bridge Tower Dental hired Respondent Meridian Computer Center to provide its dental practice with a computer hardware system subject to a warranty contract. In June of 2005, Bridge began experiencing problems with its server. Bridge Tower Dental entrusted its computer server, including both of its hard drives, to Meridian in order to repair or restore the failing hard drive. While attempting to restore the failing hard drive, Respondent mistakenly confused the source and destination locations on the motherboard and inadvertently erased all of Bridge's data, including the practice's patient records, from the working hard drive. Bridge filed suit against Meridian for breach of contract and negligence under the law of bailment. At trial, the district court denied Bridge's request to submit different jury instructions for the separate claims, and instead combined the contract claim with the negligent bailment claim in the final jury instructions. The jury entered a general verdict in favor of Meridian. Bridge filed a Motion for Judgment Notwithstanding the Verdict, or alternatively, a Motion for New Trial, both of which were denied by the district court. The court entered an order awarding attorney's fees and costs to Meridian. Bridge appealed to the Supreme Court, arguing that the district court erred in denying its Motion for Judgment Notwithstanding the Verdict because Meridian failed to prove that it was not negligent in erasing the data contained on the working hard drive, that the court erred in denying the Motion for New Trial because the jury instructions were improper, and that the district court erred in awarding attorney's fees and costs. Upon review, the Supreme Court reversed the district court's denial of Bridge's post-trial motion and vacated the lower court's award of attorney's fees because Meridian was no longer the prevailing party. View "Bridge Tower Dental, P.A. v. Meridian Computer Center, Inc." on Justia Law

Plaintiff-Counterdefendant-Appellant David Oakes, M.D. was employed as a cardiologist by Defendant-Counterclaimant-Respondent Boise Heart Clinic Physicians, PLLC (BHC) from January 2000 until the end of July 2008, when he left to pursue other employment opportunities. While employed by BHC, Plaintiff had an employment agreement that entitled him to half the adjusted gross charges he generated. Because of his complicated arrangements with other service providers, Plaintiff's final payment was not calculated until after his departure. After his employment ended, Plaintiff corresponded with BHC regarding his final payment. Plaintiff never received payment. Instead, he received a series of letters that detailed the evolving computation of his final payment. BHC's last letter to Plaintiff included a demand for repayment. Plaintiff then sued claiming that BHC still owed him money under the employment agreement. In rendering its verdict, the jury was given a choice between three special verdict forms that corresponded with the three possible verdicts: one finding that neither party is entitled to recover from the other; one that finding that BHC owed money to Plaintiff; and one finding that Plaintiff owed money to BHC. The jury returned with a verdict in favor of Plaintiff, and against BHC, that awarded Plaintiff $2,043.92. Ultimately the district court entered a final judgment that awarded Plaintiff $2,043.92 and declared that neither party was the prevailing party for purposes of costs and attorney fees. Plaintiff appealed the "prevailing party" decision to the Supreme Court. e sought. The district court entered a judgment conferring to Oakes the amount awarded by the jury, but found that neither party was the prevailing party for purposes of costs or attorney fees. Upon review, the Supreme Court held that the district court abused its discretion by not finding Plaintiff to be the prevailing party. The case was remanded for a determination of costs and fees. View "Oakes v. Boise Heart Clinic Physicians, PLLC" on Justia Law

Plaintiff-Appellant Alesha Ketterling alleged that she slipped on snow in the parking lot of the Burger King restaurant in Burley, Idaho, on December 22, 2006. BDSB of Western Idaho, L.C. had the contractual right to operate the restaurant under a franchise agreement with Burger King. HB Boys managed the Burley Burger King under a contract with BDSB. According to Plaintiff, her fall aggravated an existing knee injury. Plaintiff alleged that Burger King’s failure to make the premises safe was negligent and entitled her to damages for her injuries. HB Boys moved for summary judgment, contending that Plaintiff failed to timely join it as a defendant. The district court agreed and granted the motion. The court subsequently granted summary judgment to Burger King, holding that, as franchisor, it did not control the premises where Plaintiff fell and had no vicarious liability for her injuries. The issue before the Supreme Court was whether either Defendant was entitled to summary judgment. Finding no abuse of discretion, the Supreme Court affirmed the district court's grant of summary judgment in favor of Defendants. View "Ketterling v. Burger King Corporation" on Justia Law

This appeal arose from a negligence action brought by Plaintiff-Appellant Isabel Enriquez against Defendant-Respondent Idaho Power Company (Idaho Power). Plaintiff received severe electrical burns when he encountered an aluminum sprinkler pipe that had become energized by a high-voltage power line. He claimed that after the power line broke and electrified the pipe, Idaho Power's safety equipment did not shut off the current to the downed line, allowing him to be shocked when he approached the pipe to move it. The case went to trial, and Plaintiff argued that Idaho Power was negligent under the doctrine of res ipsa loquitur. At the close of Plaintiff's case in chief, Idaho Power moved for a directed verdict. The district court determined that res ipsa loquitur did not apply to the facts of this case and granted the motion. On appeal, Plaintiff argued that the district court erred in holding that res ipsa loquitur did not apply and the directed verdict was therefore improper. Upon review of the trial court record, the Supreme Court concluded the trial court did not abuse its discretion when it granted a directed verdict in favor of the power company. Accordingly, the Court affirmed the trial court's decision. View "Enriquez v. Idaho Power Co." on Justia Law

On June 28, 2010, Appellant Maria Gomez filed a Worker’s Compensation Complaint with the Industrial Commission (Commission) claiming benefits for an accident that occurred in 2009, when she injured her lower back lifting sixty-pound boxes. The injury occurred at Blackfoot Brass (Dura Mark). Appellant had previously suffered two work-related accidents while working with Dura Mark, one in 2002, the other in 2006, but had returned to work without restrictions after participating in physical therapy for both injuries. The issue before the Supreme Court centered on a Commission order denying reconsideration of Appellant's motion to reopen the record to allow for additional evidence on the issue of causation. The Industrial Commission previously ordered that Appellant had failed to prove the medical treatment she received for a back injury was related to an industrial accident and injury. At the emergency hearing pursuant to the Judicial Rules of Practice and Procedure adopted by the Commission, Appellant introduced evidence regarding her entitlement to reasonable and necessary medical care pursuant to I.C. 72-432, but the referee denied Appellant's claim on the grounds of causation. Upon review, the Supreme Court affirmed the Commission's judgment. In doing so, the Court wanted to provide a "clear message that without a specific stipulation that causation will be a contested issue at the hearing pursuant to I.C. 72-713, and especially if there is a difference of opinion as to causation by opposing parties and their experts, claimant’s attorneys should no longer be lulled by anything other than a stipulation to all legal prerequisites and elements for recovery and be prepared to present evidence of a causal connection between the industrial injury or sickness and the required treatment." View "Gomez v. Dura Mark, Inc." on Justia Law

Appellants Lynn and Jana Nelson argued that they owned a strip of land even though the county records showed respondents Jebb and Brandie Huskinson to be the owners of record. The Nelsons contended that the disputed land belonged to them because of a "boundary by agreement." The district court granted summary judgment to the Huskinsons. Upon review of the trial court record, the Supreme Court vacated the district court's judgment and remanded the case, finding that questions of material facts still existed from review of the evidence presented at trial, and that summary judgment was not appropriate. The case was remanded for further proceedings. View "Huskinson v. Nelson" on Justia Law

This case concerned a commercial lease between Defendants-Appellants-Cross-Appellants Michael Storms and Kathy Burggraf and the Plaitniff-Respondent-Cross-Appellant Watkins Company, LLC’s predecessor in interest, Watkins and Watkins for a restaurant and microbrewery in Idaho Falls, Idaho. Watkins filed a lawsuit seeking to enforce the lease after Storms and Burggraf failed to timely pay the rent. The issues were tried to the district court, which found that Storms and Burggraf had materially breached the lease and that Watkins could regain possession of the property. The district court also found that Storms and Burggraf had been unjustly enriched by failing to pay rent for additional storage space. Further, the district court found that the lease's provision for accelerated rent was a liquidated damages clause and found it be unconscionable. Storms and Burggraf appealed the district court’s decision, arguing that an accord and satisfaction had been reached between the parties and that the court erred in its finding of the rent for the upstairs storage area above the restaurant. Watkins argued on cross-appeal that the district court based its finding regarding the accelerated rent on insufficient evidence. Because of an error in the district court's finding regarding the upstairs storage area, the Supreme Court vacated that part of the court's order but upheld the remaining issues. View "The Watkins Co. LLC v. Storms" on Justia Law

In 2008, Defendant Abelardo Gomez was arrested and charged with one count of conspiracy to traffic in cocaine and eleven counts of trafficking in cocaine. In a plea agreement reached with the State, Defendant agreed to plead guilty to three counts in exchange for an eight year fixed sentence. At sentencing, the district court also imposed a twenty-five year indeterminate sentence and a restitution order totaling $129,534.97. Defendant argued that the imposed sentence was excessive, and that the restitution order is a violation of the plea agreement since it was not contemplated in the agreement. Upon review, the Supreme Court found that the trial court did not abuse its discretion in imposing Defendant's sentence and ordering restitution. Accordingly, the Court affirmed the district court's order. View "Idaho v. Gomez" on Justia Law

Defendant Filip Danney appealed a district court’s denial of his motion to suppress evidence of drugs obtained through the use of a drug dog during a traffic stop. On appeal, Defendant argued that the district court erred in determining that: (1) a proper foundation was laid for the admission of Global Positioning System (GPS) data used in his prosecution; (2) reasonable suspicion existed to justify the warrantless extension of his traffic stop; and (3) the government’s placement of a GPS device constituted an impermissible warrantless search. Because the Supreme Court agreed that the officer had a reasonable articulable suspicion of possible criminal activity justifying the limited detention of Defendant for purposes of a drug dog search, the Court affirmed the district court's decision. View "Idaho v. Danney" on Justia Law

In 2004, Defendant Randy Koivu was charged with possessing methamphetamine. He was found guilty and the district court sentenced him to five years in the custody of the Idaho Board of Correction, with three years fixed and two years indeterminate. The court suspended that sentence and placed Defendant on probation for four years. The terms of probation included that Defendant pay a fine, court costs, public defender reimbursement, and restitution. Defendant later violated the terms of his probation, and the court revoked his probation and committed him to the custody of the Idaho Board of Correction. Defendant was released in 2009. A few months after his release, a deputy court clerk filed an affidavit stating Defendant failed to pay his fines and court costs. The court issued a warrant of attachment to have Defendant seized and brought before the court to show cause why he should not be punished for contempt for failing to pay his fines. No copy of the order was attached to the warrant of attachment, but bail was set and would be released when Defendant posted bail. In 2010, Defendant was pulled over for speeding, and law enforcement arrested him on an outstanding warrant. While searching Defendant at the jail, a baggie of methamphetamine was discovered near his feet. Defendant was ultimately charged again for possession of methamphetamine, and found as a "persistent violator." The prosecuting attorney moved to dismiss the warrant of attachment pursuant to which Defendant had been arrested. The district court dismissed the prosecution's motion for lack of jurisdiction on the 2009 warrant. The lack of jurisdiction was apparently based upon the fact that the district court had not sentenced Defendant to a fine and court costs, but had only ordered him to pay such sums as a condition of probation. Upon the revocation of his probation, Defendant was no longer required to pay them. As a result, the district court issued an order suppressing the methamphetamine. The State then timely appealed. The State asked the Supreme Court to overrule "Idaho v. Guzman," (842 P.2d 660 (1992)) to hold that the good-faith exception to the exclusionary rule applied to violations of Article I Section 17 of the state constitution. Because the State did not show any ground for doing so, the Court declined to overrule that case and affirmed the district court's order suppressing evidence obtained incident to the wrongly issued 2010 warrant. View "Idaho v. Koivu" on Justia Law