Justia Idaho Supreme Court Opinion Summaries

Greenbriar Estates Homeowner’s Association and developer Asbury Park, LLC asserted conflicting interests in a Greenbriar Estates subdivision lot upon which Asbury Park constructed storage facilities. The district court granted partial summary judgment in favor of Asbury Park. Greenbriar HOA appealed and asserted that the district court erred by rejecting the HOA's common law dedication and fraud claims, as well as by refusing to apply the Restatement (Third) of Property-Servitudes. Upon review of the district court record, the Supreme Court concluded that the district court properly dismissed the HOA's common law dedication claim because Asbury Park did not make a clear and unequivocal offer to dedicate the lot at issue to the HOA. The Court therefore affirmed the district court's decision that granted partial summary judgment to Asbury Park. View "Asbury Park, LLC v. Greenbriar Estate Homeowners’ Association, Inc. " on Justia Law

This case involved an ongoing dispute between brothers Ron McCann (Ron) and William McCann, Jr. (Bill) concerning the operation of McCann Ranch & Livestock Company, Inc. (Ranch), a closely-held corporation created by their father, William McCann, Sr. (William, Sr.). In 1997, William, Sr.'s shares passed to a trust set up to benefit his wife Gertrude, with Gary Meisner as trustee. In 2008, Ron filed suit against Bill, the Ranch and Meisner (Respondents) alleging a breach of fiduciary duties and seeking equitable relief or, the dissolution of the corporation. The district court granted summary judgment for the Respondents. Ron appealed, arguing that the district court erred in characterizing his claims as derivative and in finding that he failed to satisfy the elements of I.C. 30-1-1430(2)(b). Ron also argued that the court incorrectly limited the scope of discovery. Respondents cross-appealed, arguing that the district court erred in failing to award them attorney's fees. Upon review, the Supreme Court concluded the district court erred in granting summary judgment to Respondents as they failed to establish the necessary elements set forth in I.C. 30-1-1430(2)(b). Furthermore, the Court found that the district court did not err when it denied Respondents attorney fees. The case was remanded to the district court for further proceedings. View "McCann v. McCann, Jr. " on Justia Law

Appellants Kent Whiteman and Whitehorse Properties, LLC, (Whiteman), brought a second appeal of this case before the Supreme Court. In the original trial, Respondent Damian Farrell sued Whiteman for uncompensated architect services rendered for Whiteman's condominium project from 2003 to 2004. Whiteman counterclaimed arguing that Farrell was not entitled to compensation due to his failure to obtain a license to practice architecture in Idaho. Farrell is a resident of Michigan and was licensed as an architect in the states of Michigan, Texas, and New York when he began working with Whiteman. Farrell did not receive his architect's license in Idaho until 2004. The district court found that an implied in fact contract existed between the parties and awarded Farrell damages in quantum meruit for services rendered, expenses incurred, and attorney's fees and costs. Whiteman appealed and the Supreme Court vacated the district court's damage award and its award of attorney's fees, finding that any damages awarded to Farrell prior to being licensed in Idaho should be based on unjust enrichment, not quantum meruit. On remand, the district court heard new evidence and awarded Farrell damages for reimbursement of out of pocket expenses incurred prior to licensing under unjust enrichment, damages for architectural services rendered after Farrell obtained his license based on quantum meruit, and attorney's fees and costs. Upon re-review, the Supreme Court upheld the district court's award of damaged under unjust enrichment and quantum meruit, and upheld the award of attorney's fees and costs. View "Farrell v. Whiteman " on Justia Law

In 2003, Defendant Lonnie Forbes pled guilty to attempted lewd conduct with a minor child under sixteen years of age. The district court withheld judgment three months later and placed Defendant on probation for seven years. As a result of his plea, Defendant was required to register as a sex offender. When Defendant committed the crime, Idaho law permitted him to request to withdraw his guilty plea and have the case dismissed. The district court was given discretion to grant Defendant's request so long as Defendant complied with the terms of his probation. Three years later, the law was amended. Three years after that, Defendant's probation was amended to unsupervised probation, with all other terms of probation still in effect. In 2010 when Defendant met the requirements of his withheld judgment, he moved to set aside his guilty plea and for a restoration of his civil rights. The State opposed Defendant's motion to dismiss, but the district court granted Defendant's request. The State appealed, arguing that the change in the law governing Defendant's sentence and probation barred Defendant's ability to have his case dismissed. Upon review, the Supreme Court held that the district court erred by retroactively applying the amended law to Defendant's case. The district court's decision was vacated and the case remanded for further proceedings. View "Idaho v. Forbes " on Justia Law

Appellants Ismael Chavez and Dolores Mercado (collectively Chavez) appealed the district court's granting their petition for judicial review, claiming that their original complaint should not have been converted into a petition for judicial review. Canyon County cross-appealed the district court's decision that the flat fee included on the County's notice of pending issue of tax deed was in violation of I.C. 63-1005(4)(d) requiring an itemized statement. In 2009, Chavez filed a class action complaint seeking a declaratory judgment and damages. Chavez alleged that Canyon County had violated a requirement in Idaho Code section 63-1005(4)(d) for an itemized statement of all costs and fees in its notice prior to an issuance of treasurer's tax deeds on two parcels of land they owned. In its Notice of Pending Issue of Tax Deed on the two parcels, the County charged a $500 flat fee for administration costs. In 2010, upon a motion for summary judgment, the district court denied the motion and found Chavez had failed to follow the proper procedures. The court allowed Chavez fourteen days to file the required Petition for Judicial Review. In its review, the Supreme Court held that the district court improperly converted Chavez's declaratory action into a petition for judicial review and was without jurisdiction to rule on the petition for judicial review. Furthermore, the Court declared the notices of pending issue of tax deed to be deficient and void and the corresponding fee was found as moot. View "Chavez v. Canyon County " on Justia Law

Respondent-Appellant Pneumotech, Inc. appealed the Industrial Commission's determination that its former employee, Petitioner-Appellee Angela Hopkins, was eligible for unemployment benefits. Pneumotech hired Petitioner as a bookkeeper and receptionist on July 3, 1995. She worked at Pneumotech until June 22, 2010, when her supervisor fired her. The same month, Petitioner filed a claim for unemployment benefits with the Idaho Department of Labor. At the hearing, Pneumotech presented testimony that Petitioner was discharged because: (1) for two years she had been habitually late for work; (2) she took time off without supervisor permission; (3) she took sick time off but went to the water park instead; (4) she spent time at work playing video games and talking on her cell phone; and (5) she failed to help train a new employee when asked. Petitioner denied all of these accusations, including that her supervisor had repeatedly warned her that her conduct was unacceptable. In fact, the supervisor testified that Petitioner never received a written warning or suspension, and in January 2009, she received a $2-per-hour raise. Upon review, the Supreme Court found that the Commission did not abuse its discretion or violate Pneumotech's right to procedural due process in denying the company's request for a new hearing. Furthermore, substantial and competent evidence supported the Commission's decision to uphold Petitioner's award of unemployment benefits. Accordingly, the Court affirmed. View "Hopkins v. Pneumotech, Inc." on Justia Law

Defendant-Appellant Matthew Hanson was convicted of aggravated assault. At the sentencing phase, he exercised his Fifth Amendment privilege against self-incrimination and declined to participate in the preparation of the presentence investigation (PSI) report. Defendant later moved the court to order a presentence psychological evaluation. The district court ruled that unless Defendant agreed to participate in the PSI, his motion would be denied on the ground that a defendant may not selectively invoke his Fifth Amendment privilege with respect to different aspects of a single subject. Defendant again declined to participate, and the court denied his motion. Defendant's attorney subsequently requested a competency evaluation, which was also denied. Defendant was sentenced to five years, with three years fixed. He then moved for reconsideration of his sentence, which motion the district court denied. Defendant appealed the district court's denial of his requests for a psychological evaluation and for a competency evaluation. Upon review, the Supreme Court affirmed the district court's denial of Defendant's request for a competency evaluation. However, the Court reversed the district court's denial of Defendant's request for a psychological evaluation because: (1) the record showed Defendant's mental condition would be a significant factor at sentencing; and (2) it incorrectly held that Defendant could not invoke his Fifth Amendment privilege against self-incrimination with regard to the PSI but waive the privilege in order to obtain a psychological evaluation. Accordingly, the Court vacated the district court's judgment and remanded the case for further proceedings. View "Idaho v. Hanson " on Justia Law

Plaintiff-Appellant Dr. John Noak was dismissed as the medical director for Prison Health Services, Inc. (PHS). He appealed the district court's grant of summary judgment in favor of the Idaho Department of Correction (IDOC) on claims of breach of an implied covenant of good faith, intentional and negligent infliction of emotional distress, defamation, and intentional interference with contract. A 2004 investigation into how Plaintiff treated a female inmate at an IDOC facility lead to IDOC demanding that PHS replace Plaintiff as medical director. Finding no error in the district court's judgment, the Supreme Court affirmed the grant of summary judgment in favor of IDOC. View "Noak v. Dept. of Corrections" on Justia Law

Defendant-Appellant Simona Manzanares appealed the judgment entered after she pled guilty under a conditional plea agreement. She pled guilty to recruiting a criminal gang member in exchange for the dismissal of a charge for providing a firearm to a criminal gang member. On appeal, Defendant argued that the "Recruiting Provision" (I.C. 18-8504(1)(a)) was unconstitutionally overbroad on its face and as applied for encroaching on the First Amendment right to free association; that the "Firearm Provision" (I.C. 18-8505) was unconstitutionally overbroad as applied for punishing her "expressive conduct," and unconstitutionally vague on its face and as applied for failing to adequately define "gang member," as well as being unconstitutional under the Second Amendment of the federal and under Article I, Section 11 of the state constitution. Defendant raised additional constitutional claims, and argued that the evidence presented against her at the preliminary hearing was insufficient to support the charges she faced. Upon careful consideration of Defendant's arguments, the Supreme Court concluded that the "Recruiting" and "Firearm" provisions were not unconstitutionally overbroad nor were they unconstitutional as they applied to Defendant. As such, the Court upheld Defendant's conviction pursuant to her conditional plea agreement. View "Idaho v. Manzanares " on Justia Law

In March 2009, the City of Nampa issued a request for proposals regarding obtaining services to prosecute city misdemeanors and infractions. Former Canyon County prosecuting attorney John Bujak desired to contract with Nampa to perform those services. The Canyon County commissioners unanimously adopted a proposal pursuant to permit him to do so. Plaintiff-Appellant Bob Henry filed three public records requests with the county clerk asking for information regarding the contract with Nampa, including "invoices, etc sent to Nampa by county for prosecuting svc." and "an accounting of where those funds are being deposited + how they are being dispursed [sic] to Canyon County." Upon review, the Supreme Court held that the requested records were public records, but that the City could not be required to produce them because it was not the public official who refused to disclose the records. View "Henry v. Taylor" on Justia Law