Justia Idaho Supreme Court Opinion Summaries

Plaintiff-Appellant Thomas Weisel owned two adjacent parcels within the Beaver Springs Subdivision in Ketchum. He sought to unify and develop the lots. At some point, his plan indicated that he intended that construction would take place in a "setback zone" that abutted the lots' shared border. Plaintiff and the Beaver Springs Owners Association executed an agreement whereby Beaver Springs approved the unification and development plan. Construction on the property was completed in 1985, all structures were located on what used to be "lot 14" and the former setback zone and "lot 13" remained vacant. In 2009, Plaintiff filed suit to rescind or reform the agreement. The district court granted Beaver Springs' motion for summary judgment, and Plaintiff appealed. Upon review, the Supreme Court concluded that "[i]n essence, Plaintiff asked the Court to reform an agreement for which the parties freely bargained." As such, the Court found that the district court properly granted summary judgment in favor of Beaver Springs. View "Weisel v. Beaver Springs Owners Association, Inc." on Justia Law

Fall River Rural Electric Cooperative hired Plaintiff-Appellant Suzette Bollinger as a cashier and receptionist at its Ashton headquarters in 1988. She was terminated in 2009 despite having satisfactory performance without cause. Plaintiff alleged in her complaint that she signed an employment contract at the time of her hiring, but she failed to produce the contract at trial. In 2009, Fall River adopted an "at-will" employment policy which expressly superseded any prior conflicting policy. Plaintiff ultimately sued Fall River for: (1) breach of express and implied contract, including breach of the covenant of good faith and fair dealing; (2) retaliatory discharge and wrongful termination in violation of public policy; and (3) negligent and intentional infliction of emotional distress. The district court granted summary judgment to Fall River on all of Plaintiff's claims. The district court also denied her motion for reconsideration, and she timely appealed to the Supreme Court. Finding that Plaintiff's claims were properly dismissed, the Supreme Court affirmed the district court's ruling. View "Bollinger v. Fall River Rural Electric Cooperative, Inc." on Justia Law

Plaintiffs-Respondents father and daughter Jose and Nayeli Carrillo, father and daughter, sued Boise Tire Co. (Boise Tire), alleging that Boise Tire improperly performed a tire rotation on their vehicle and that as a result, the Carrillos and Marisela Lycan, Jose’s wife and Nayeli's mother, were in a motor vehicle accident. Marisela was killed, Jose was injured, and eighteen-month old Nayeli underwent testing that revealed no physical injury. A jury found that Boise Tire's conduct was reckless. Boise Tire moved for new trial on the grounds that: (1) the Carrillos' pleadings merely alleged negligence and therefore the court committed legal error by permitting the Carrillos to argue that Boise Tire's conduct was reckless; (2) the jury verdict was excessive and the result of passion or prejudice; and (3) the jury verdict was not supported by sufficient evidence. The district court issued a remittitur as to Nayeli's noneconomic damage award but otherwise denied the motion. Boise Tire appealed that denial and the court's holding that I.C. 6-1606 did not require the Carrillos' damage awards to be reduced by the subrogation interest transferred from the Carrillos' insurer to their attorney, nor by social security benefits obtained by the Carrillos. Upon review, the Supreme Court affirmed the district court's denial of Boise Tire's motion for a new trial, vacated the judgment and remanded the case for the district court to reduce Jose's personal injury reward by the value of his social security benefits when judgment was originally entered. View "Carrillo v. Boise Tire Co., Inc." on Justia Law

Claimant Brooke Stark worked for Assisted Living Concepts, Inc. from 2008 to 2010 as a "residence director" of one of Assisted Living's facilities. Claimant was called into the sales director's office one day, and the two talked about a rumor that one of Assisted Living's other facilities was imminently closing. Later that evening, Assisted Living's divisional director of human resources called Claimant to ask where Claimant heard of the closing rumor. Claimant did not disclose her source. Five minutes following that call, Assisted Living's chief executive officer called Claimant (with the director of HR on the call) to ask about the rumor. Claimant said she talked to a number of people, but that she did not want to share the information. The CEO emphasized the importance of knowing who started the rumor so that the company could reassure those involved that the facility in question would not close. Still declining to reveal her source, the CEO suspended Claimant. The human resources director, after a little investigation, found that Claimant violated company policy by refusing a direct order from her supervisor. Claimant was then terminated in the fall of 2010. The issue before the Supreme Court involved whether Claimant's refusal to respond to the CEO's question. The Industrial Commission held that Claimant's refusal to obey the direct order did not constitute misconduct under the Employment Security Law. The Supreme Court held as a matter of law, Claimant's conduct was indeed misconduct under the Employment Security Law, and reversed the Industrial Commission. View "Assisted Living Concepts , Inc. v. Idaho Dept of Labor" on Justia Law

This case arose from a district court's dismissal for failure to exhaust administrative remedies of Petitioner-Appellant Daniel Fuchs's petition for judicial review and complaint for declaratory and injunctive relief. Petitioner challenged the Alcohol Beverage Control's (ABC) removal of his name from liquor license priority waiting lists. He argued that the agency's action constituted an informal rule that was not promulgated in accordance with the Idaho Administrative Procedure Act (Idaho APA). In response, ABC argued that Petitioner failed to exhaust administrative remedies before bringing his action before the district court, and that the removal was done in accordance with Idaho APA. Upon review, the Supreme Court found that the district court erred in finding that Petitioner failed to exhaust administrative remedies, but that Petitioner did not have a property interest in his place on the priority list (since the legislature did not have the authority to create such an interest). Accordingly, the Court affirmed the district court's decision. View "Fuchs v. Idaho" on Justia Law

Jane Doe appealed the termination of her parental rights with regard to her son, John Doe, contending that the magistrate court failed to properly consider her improved participation in mental health and family counseling services. Because there was substantial and competent evidence to support the magistrate court's final Judgment that termination of Jane Doe's parental rights was in John's best interests, the magistrate court did not err in terminating her parental rights. View "Dept. of Health & Welfare v. Jane Doe" on Justia Law

Plaintiffs-Appellants Randolph Farber, Scott Becker, and Critter Clinic (Farber) alleged that the Manager of the Defendant-Respondent State Insurance Fund (SIF or "the Fund") failed to comply with I.C. 72-915, which provides the means by which the SIF Manager may distribute a dividend to policyholders. The district court determined that the gravamen of Farber's claim implicated the statute and held that the three-year statute of limitation provided by I.C. 5-218(1) barred all claims that accrued prior to July 21, 2003. Farber timely appealed. Upon review, the Supreme Court held that the five-year statute of limitation in I.C. 5-216 applied to Farber's claim. Therefore, the Court reversed the trial court's decision and remanded the case for further proceedings. View "Farber v. Idaho State Insurance Fund" on Justia Law

Defendant-Respondent Croft & Reed, Inc. and Plaintiff-Appellant Steel Farms, Inc. had a preexisting landlord-tenant relationship when they entered into a written agreement granting Steel Farms a lease and option (Option A) to purchase a farm in Bonneville County (the Property). The lease had an express four-year term. Steel Farms believed the four-year term was a mistake because the option to purchase the Property did not mature until after the four-year lease term expired. In response to a request from Steel Farms, Croft & Reed’s secretary made a handwritten interlineation on the lease agreement which purported to extend the lease term for an additional year. While Steel Farms was a tenant, it purchased and installed irrigation equipment on the Property, which was attached to the Property’s irrigation system. Steel Farms later granted Walker Land, Inc. an option to purchase the Property (Option B) from Steel Farms. Steel Farms sought to exercise Option A after leasing the Property for four years. Croft & Reed refused. Steel Farms sued, and the parties filed cross motions for summary judgment. The district court granted partial summary judgment in favor of Croft & Reed. Steel Farms appealed the certified judgment. Upon review, the Supreme Court vacated and remanded, finding that the secretary's initialed interlineation was insufficient to amend the lease and option. View "Steel Farms, Inc. v. Croft & Reed, Inc." on Justia Law

Defendants-Appellants Stanley and Catherine Jensen, as trustees of the Stanley and Catherine Jensen Family Living Trust, appealed the district court's decision that granted Plaintiff-Respondent Rocky Mountain Power's motion for summary judgment. Defendants are record owners of a cattle ranch that lies within a corridor established by the Utility for a 345 kilovolt transmission line. The Utility sought a perpetual easement and a right of way for the Utility and its successors and assigns to locate, construct, reconstruct, operate, and maintain a 150 foot wide high-voltage overhead power line utility corridor through the eastern part of Defendants' property. In 2008, Defendants entered into an Occupancy Agreement with the Utility, waiving all defenses to the Utility's acquisition of the easement, except the claim of just compensation. Upon execution of the Agreement, Defendants were paid $215,630 which would be deducted from any final determination of just compensation for the easement. Under the terms of the Occupancy Agreement, if just compensation was determined to be less than $215,630, Defendants were not required to return the difference. The parties were unable to reach an agreement for just compensation within a specified time, so the Utility filed its Complaint in early 2009, seeking a decree of condemnation, an award of easement, and specific performance of the Occupancy Agreement. The Utility filed a motion for summary judgment, contending that Defendants did not identify any expert witnesses or laid a proper foundation for any probative evidence of just compensation. Upon review, the Supreme Court found that Defendants failed to establish a genuine issue of material fact to establish the fair market value of their property. Accordingly, the Court affirmed the district court's judgment. View "Rocky Mountain Power v. Jensen" on Justia Law

Defendant-Appellant Robert Gurney pled guilty to possession of marijuana with intent to deliver. He then successfully completed drug court. Upon completion, he requested and received a dismissal of the charge. He also requested that the record of his criminal case be sealed, pursuant to I.C.A.R 32(i), on the basis of economic hardship. The district court denied this second request. It subsequently denied Defendant's request to change the caption of this case on appeal to an abbreviated version of his name which would conceal his identity. Defendant appealed both decisions. Upon review, the Supreme Court concluded the district court did not err by denying Defendant's motion to seal his records or amend the caption of his case: "[a]s the district court recognized that the decision was committed to its discretion, recognized and applied the applicable legal standard, and did so through the exercise of reason, [the Court was] unable to conclude that the decision was an abuse of discretion." View "Idaho v. Gurney" on Justia Law