Justia Idaho Supreme Court Opinion Summaries

Claimant-Appellant Dennis Current appealed the Idaho Industrial Commission's denial of his unemployment benefits. Claimant argued that the Commission erred in finding he willfully made a false statement, and in failing to call one of his witnesses. The Department of Labor argued the Commission's findings were supported by substantial and competent evidence. The Supreme Court found that there was indeed substantial and competent evidence to support the Commission's findings that Claimant willfully made a false statement. The Court also found that the hearing officer did not abuse her discretion in finding that one of Claimant's witnesses would not provide relevant testimony. Accordingly, the Court affirmed the Commission's decision. View "Current v. Haddons Fencing, Inc. " on Justia Law

Defendant John Joseph Delling appealed his conviction based on his conditional pleas of guilty to two counts of second-degree murder. Defendant was initially charged with two counts of first-degree murder for the deaths of David Boss and Brad Morse. These counts were later amended to second-degree murder. Shortly after being charged, Defendant's counsel motioned for a mental health evaluation to determine whether Defendant was fit to proceed and able to aid in his own defense. Defendant requested that the Supreme Court reconsider and overrule its decision in "State v. Searcy" (798 P.2d 914 (1990)), to find that Idaho's abolition of the insanity defense was unconstitutional. Defendant also asserted that the district court abused its discretion and imposed excessive sentences. Upon careful review of the applicable legal authority and the arguments presented in Defendant's appellate brief, the Supreme Court concluded Defendant had not provided any argument that showed the precedential cases to be wrongly decided, unwise, or unjust. By looking at each argument individually, none of Defendant's constitutional rights were infringed by the abolition of the insanity defense. Furthermore, the Court also found that the sentence imposed by the district court was reasonable and not an abuse of discretion. View "Idaho v. Delling " on Justia Law

Defendant John Schulz appealed his conviction of felony domestic battery and the attempted strangulation of his fifteen-year-old daughter. Both charges required the state to prove that the daughter was Defendant's "household member" as defined by the applicable statute. The district court granted Defendant's motion to dismiss based on the fact that she did not fall within that definition. Because the Supreme Court found that the definition of "household member" plainly limited the application to "intimate partners" and thus, did not extend to a child living with her father, the Court affirmed. View "Idaho v. Schulz " on Justia Law

In Plaintiff T.J.T., Inc.'s second appeal from a summary judgment in favor of Defendant Ulysses Mori, in which the district court found that the non-competition agreement Mori allegedly breached was unenforceable under California law. This case arose from the execution of a non-competition agreement between TJT and Mori in connection with the sale of Mori’s business, Leg-It Tire Company, Inc., to TJT in 1997. Leg-It owned and operated one production facility in Woodland, California. TJT also operated in the tire and axle recycling business, and it had recycling facilities in Idaho, Oregon, and Washington at the time it purchased Leg-It in 1997. At the time of the sale of Leg-It, Mori was hired as the "Senior Vice President and General Manager of the Leg-it Tire Company Division of [TJT]." In 2000, Mori moved to Idaho and took a new position as Corporate Sales Manager. In 2007, Mori resigned as an employee of TJT and several days later, was hired by West States Recycling, Inc., a competitor to TJT, as a tire and axle salesman. In his employment with West States, Mori facilitated the opening of a warehouse facility in Idaho to support local Idaho customers who purchase tires and axles, and also solicited tire and axle business in Oregon, Washington, California, and Idaho. Because the Supreme Court in its review found that the district court erred in failing to consider whether and to what extent the agreement could be "blue penciled" to make it enforceable, the Court vacated the summary judgment and award of attorney fees and remanded the case for further proceedings. View "T.J.T., Inc. v. Mori " on Justia Law

Former engineering professor Plaintiff Habib Sadid appealed the grant of summary judgment in favor of his former employer Defendant Idaho State University which dismissed his retaliation claim. Plaintiff alleged the University retaliated against him because of his comments criticizing the administration that had been published in a local newspaper over several years and that the University had breached his employment contract. Upon review careful review of the issues Plaintiff raised in his appellate brief, the Supreme Court affirmed the judgment of the district court dismissing the amended complaint. The Court vacated the denial of attorney fees to the University and remanded this case for consideration of its request for attorney fees in defending against the breach of employment contract claim. View "Sadid v. Idaho State University" on Justia Law

John Doe (Father) and Jane Doe (Mother) appeal from an order terminating their parental rights. The two appellants have three children together, and Mother has an additional child with another man. The magistrate terminated the parental rights of both parents as to all children, holding that both Father and Mother neglected the children and that termination was in the children’s best interest. In 2009, Mother was arrested for possession of methamphetamine. The arresting officer declared all four children in imminent danger and took them into protective custody. The children have been in State custody ever since. In June 2010, the State petitioned for termination of Mother's and Father's parental rights. The State's petition contended that both Mother and Father neglected the children: Mother, because she failed to complete a scheduled child protective case plan; Father, because he was incarcerated and unable to provide for the children. Mother stipulated "that she had put forth very little, if any, effort to comply with the … case plan prior to the time the State filed its petition to terminate her parental rights in this matter." In its memorandum decision, the court weighed the trial evidence and ultimately determined that Father and Mother neglected their children and that termination of their parental rights was in the children’s best interest. Both parents timely appealed. Upon review, the issue before the Supreme Court was whether there was substantial, competent evidence to support the magistrate judge's decision to terminate Mother’s and Father’s parental rights, and whether, as Mother argued, the State was estopped from seeking to terminate her rights. Because there was substantial and competent evidence to support the magistrate's findings that the children were neglected and that termination of his rights was in their best interest, the Supreme Court "[would] not disturb those findings." View "In re Termination of Parental Rights of John & Jane Doe" on Justia Law

This was an insurance coverage dispute between the County of Boise and its Insurer, Idaho Counties Risk Mangement Program (ICRMP). ICRMP refused to defend the County in Fair Housing Act (FHA) litigation in federal court, which the County claimed breached its insurance agreement. The district court determined the FHA claims against the County were excluded from the policy and granted summary judgment to ICRMP. Upon review, the Supreme Court concluded the district court properly granted summary judgment to ICRMP based on the land use exclusion in the Policy, and it therefore affirmed the district court's judgment. View "County of Boise v. Idaho Counties Risk Mgmt. Pgm. " on Justia Law

Defendant Christian Rivas-Del Toro is a Mexican citizen who was residing and working in the United States illegally. In the summer of 2005, he began working as a truck driver for co-defendants Willard, Michael, and Douglas Cranney, who are collectively called "Cranney Farms," the name under which they did business. When he began work for Cranney Farms, Defendant had a valid Mexican chauffeur license. While driving a farm truck, Defendant failed to stop at a stop sign and struck another vehicle in an intersection. He contended that the trailer brakes malfunctioned. Plaintiff Beatriz Nava was driving the other vehicle, and her minor daughter was a passenger. She filed this action seeking to recover for property damage and personal injuries to herself and her daughter. In her amended complaint, she alleged that Cranney Farms was liable because it was the registered owner of the truck and Defendant was driving with Cranney Farms’s permission and that Cranney Farms had recklessly allowed the vehicle to become unsafe to operate. Cranney Farms moved for summary judgment on the ground that pursuant to Idaho Code section 6-1607 it was not liable for the negligence of its employee because he was outside the course and scope of his employment at the time of the accident. After the motion was briefed and argued, the district court held that because Defendant chose a longer route in order to avoid law enforcement because he was in the country illegally, Plaintiffs failed to satisfy Idaho Code section 6-1607(2). It ordered that Cranney Farms was entitled to a judgment dismissing the action as to it. Plaintiffs and Defendant moved for reconsideration, which the court denied. It entered judgment dismissing the action with prejudice as to Cranney Farms, and it certified that judgment as final pursuant to Idaho Rule of Civil Procedure 54(b). Plaintiffs appealed and Defendant cross-appealed. Upon review, the Supreme Court concluded that because the burden never shifted to Plaintiffs to provide evidence regarding their claim of negligent maintenance, the district court erred in granting summary judgment on that claim. Furthermore, the Court found that the ground upon which the trial court dismissed the action against the owners (that Defendant was an employee and was outside the course and scope of his employment) was not a defense to the claims alleged in the complaint, the Court vacated the district court's judgment and remanded the case for further proceedings. View "Nava v. Rivas-Del Toro" on Justia Law

Defendant Torey Adamcik appealed his convictions for first-degree murder and conspiracy to commit first-degree murder. In 2007, a jury convicted him for the stabbing death of Cassie Jo Stoddart. Defendant raised multiple issues on appeal, among them, he challenged the sufficiency of the evidence presented at trial. Furthermore, Defendant alleged multiple errors at trial prejudiced him from receiving a fair trial. Upon careful review of the trial court record, the Supreme Court found that the jury was provided with sufficient evidence from which it could reasonably find beyond a reasonable doubt that Defendant was guilty of first-degree murder, and that the trial court did not err in its rulings at trial. Accordingly, the Court affirmed Defendant's convictions and sentences. View "Idaho v. Adamcik " on Justia Law

The issue on appeal in this case stemmed from a 2005 real estate purchase and sales agreement (PSA) entered into between Pines Grazing Association as the seller, and J.C. Investments (owner of Flying Joseph Ranch) as the buyer of the Pines Ranch. Prior to closing, the parties learned that approximately 80 acres of what Pines had previously believed to be a portion of Pines Ranch was omitted from the ranch's legal description. Pines retained attorney Fred Snook to assist with the acquisition of the 80 acres. Mr. Snook determined that the 80 acres had been deeded to Lemhi County and that the County still owned the land. In light of this, the parties entered an addendum to the PSA whereby they would proceed with the original closing on the ranch while giving Pines time to try to acquire the 80 acres from Lemhi County in order to sell the 80 acres to Flying Joseph Ranch. The sale closed before the parties learned that Lemhi County could not sell the 80 acres privately; the land had to be sold at public auction. Pines sent Mr. Snook to the auction to bid on the 80 acres. The parties' agents cut a side deal whereby Pines would be paid not to bid on the 80 acres. Flying Joseph ultimately won the land at auction. Flying Joseph's agent faxed Pines' agent an agreement and release of all claims for the 80 acres. Pines refused to sign, believing that the agreement was not part of the oral agreement not to bid at the auction. Pines subsequently filed suit to enforce the terms of the oral contract. Among the issues brought before the Supreme Court were whether the district court erred in denying Appellant’s motion for JNOV on the grounds that the $20,000.00 offered to refrain from bidding constituted an unauthorized brokerage commission. Upon review, the Supreme Court refused to enforce the oral agreement not to bid at the auction because it was an illegal contract in violation of the Sherman Act. "As such, the parties are left as they are with respect to the oral agreement not to bid, and neither party is entitled to attorney fees on appeal or in the district court with respect to all issues related to the oral agreement not to bid." The Court upheld the jury's finding that Pines did not breach the grazing lease. View "Pines Grazing Association, Inc. v. Flying Joseph Ranch, LLC " on Justia Law