Justia Idaho Supreme Court Opinion Summaries

This case arose from a contract for services between Defendant Erik Partin and Plaintiff Cody Schroeder under which Defendant assembled a specialty car engine for Plaintiff. A jury returned a verdict finding that Defendant assembled the engine improperly and breached the agreement which contained a liquidated damages clause. The district court granted Defendant's motion for judgment notwithstanding the verdict (JNOV), holding that no reasonable jury could find the liquidated damages clause to be valid. The court also awarded attorney fees to both parties. Plaintiff appealed the grant of JNOV and the award of attorney fees to Defendant. Upon review of the trial record, the Supreme Court found there was substantial evidence to support the jury's determination that the performance agreement was enforceable. Therefore, the Court vacated the trial court's grant of JNOV and reversed the lower court's order granting attorney fees to the parties. The Court remanded the case for further proceedings, and awarded attorney fees on appeal to Plaintiff. View "Schroeder v. Partin" on Justia Law

Following a district court's resolution of a property dispute between Respondents Daniel and Sherri-Jo Garner and Appellants Brad and Leiza Povey, Appellants sought an award of attorney fees under the "commercial transaction" prong of I.C. 12-120(3) and for frivolous litigation under I.C.12-121. The district court denied fees on both grounds, and Appellants appealed to the Supreme Court. Upon review of the lengthy trial court record, the Supreme Court reversed the denial of attorney fees to Appellants under I.C. 12-121. Furthermore, the court reversed the denial of fees for Appellants under I.C. 12-120(3) and remanded the case back to the district court for a determination of the appropriate fee award. The Court awarded Appellants costs and attorney fees on appeal. View "Garner v. Povey" on Justia Law

The State appealed a district court's grant of post-conviction relief to Defendant Trevor Booth. Defendant was charged with first-degree murder for the shooting death of Leonard Kellum in 2005. Prior to trial, the prosecutor handling Defendant's case informed Defendant and his counsel that the prosecution intended to request that the trial court provide a special verdict form for the jury if Defendant was convicted of first-degree murder. Specifically, the verdict form would instruct the jury to determine whether certain statutory aggravating circumstances existed. Defendant's attorney interpreted the applicable statute to mean that if the jury were to find any aggravating circumstances, the court would be required to impose a fixed life sentence. Defense counsel prepared a memorandum to Defendant outlining his understanding of the potential penalties. The memorandum went on to explain what Defendant's options were with regard to entering a plea agreement with the State. Defendant eventually pled guilty pursuant to a negotiated plea agreement. Defendant was sentenced to an indeterminate life sentence with thirty years fixed. Defendant timely filed a petition for post-conviction relief, arguing he received ineffective assistance of counsel at trial and in the handling of the plea agreement. The district court concluded that Defendant's counsel erroneously advised him regarding the potential sentence and with regard to the special verdict form. The court withdrew the guilty plea and set the case for a jury trial. The State appealed this decision to the Supreme Court. Upon review, the Court concluded that Defendant met his burden of demonstrating his counsel's performance was deficient and that he was prejudiced as a result. The Court affirmed the district court's decision to grant Defendant's petition for post-conviction relief. View "Booth v. Idaho" on Justia Law

Defendant Four Rivers Packing Company operated an onion packing plant and hired Plaintiff Stuart Mackay as the company's "field man." Plaintiff had been in the onion business for decades and knew many onion farmers. Four Rivers through its general manager Randy Smith (Smith) offered Plaintiff a job that involved purchasing enough onions to keep Four Rivers' packing shed stocked at a price that Smith would set. Plaintiff contended that Smith offered him a long-term employment contract. From 2000 to 2002, financial and managerial setbacks made it difficult for Four Rivers to operate its business, and for Plaintiff to acquire onions at prices set by Smith in order to keep the sheds stocked. In 2003, Four Rivers laid Plaintiff off. Plaintiff filed suit in 2004 alleging breach of the employment contract. At trial following a remand, Four Rivers contended that the parties had not entered into an employment contract for any specified term. A jury would return a verdict in favor of Plaintiff. In a special verdict form, the jury found that the parties had entered into a long term contract of "up to ten years, or such time as the Plaintiff retired." Four Rivers timely appealed, challenging jury instructions given at trial and the sufficiency of the evidence. Upon review of the trial record, the Supreme Court found that the trial court properly instructed the jury and that the evidence presented was sufficient to support the verdict. The Court affirmed the trial court's judgment against Four Rivers. View "Mackay v. Four Rivers Packing Co." on Justia Law

Respondent John Doe appealed a magistrate court's judgment that terminated his parental rights to his three minor children. The magistrate court found that Respondent neglected his children by failing to provide them with proper parental care. The court found it to be in the children's best interests to terminate his parental rights because, though there was a bond between the father and children, the children needed a stable environment that the father could not provide. On appeal, the father challenged the sufficiency of the evidence presented to support the termination of his parental rights. Upon careful consideration of the magistrate court record, the Supreme Court found substantial and competent evidence that the judgment was in the best interest of the children. The Court affirmed the magistrate court's judgment. View "Idaho Dept. of Health & Welfare v. Doe" on Justia Law

Defendant Richard Hansen appealed the district court's denial of his motion to suppress. He contended that a probationer living in an RV on Defendant's property lacked actual or apparent authority to consent to a search of the common areas in Defendant's home. Defendant asserted that the drugs discovered during that search should have been suppressed, along with additional evidence seized pursuant to a search warrant the State later obtained. Upon review, the Supreme Court found that since the officers in this case reasonably believed the probationer had apparent authority to consent to the search, the denial of Defendant's motion to suppress was properly decided. View "Idaho v. Hansen" on Justia Law

Plaintiff Janet Nightengale brought a medical malpractice action against emergency room doctor Defendant Dr. Kevin Timmel. Defendant failed to diagnose a clot in one Plaintiff's vascular arteries. That condition cut off circulation to Plaintiff's left arm, eventually requiring its amputation above the elbow. At trial, the jury returned a special verdict finding that Defendant had not breached the relevant standard of care in his treatment of Plaintiff. Plaintiff contended on appeal that the evidence presented was insufficient to support the special verdict. Upon review of the trial court record and the applicable legal authority, the Supreme Court affirmed the district court's decision in support of Defendant. View "Nightengale v. Timmel" on Justia Law

Plaintiff Randy Hoffer challenged the district court's dismissal of three of his five tort claims against the City of Boise (City). Of two in particular, the district court dismissed Plaintiff's claims of tortious interference with a contract and defamation against the City because it held as a matter of law that under the Idaho Tort Claims Act (ITCA), a governmental entity could not be held liable for the torts of its employees when a complainant alleges malice and/or criminal intent. Upon review of the applicable legal authority and the trial record, the Supreme Court found that the ITCA indeed exempted governmental entities from liability for the intentional torts at issue in this case. Accordingly, the Court affirmed the lower court's dismissal of Plaintiff's claims. View "Hoffer v. City of Boise" on Justia Law

In 2001, Plaintiff Allied Bail Bonds, Inc. and Defendants the Kootenai County Sheriff and Board of Commissioners entered into a settlement agreement setting forth procedures for how inmates at the county jail would be informed of and obtain bail bonds. Allied brought suit alleging several claims including breach of the settlement agreement. The district court dismissed Allied's claims. Principal among them was Allied's contention that the Sheriff wrongfully diverted Allied's potential customers away from Allied, toward credit card companies, with the intent to harm Allied's business. Upon review, the Supreme Court found that Allied ran afoul of the technical pleading requirements of the legal authorities it used to support its claims. As such, the Court held that the district court properly dismissed Allied's claims against Defendants. View "Allied Bail Bonds, Inc. v. County of Kootenai" on Justia Law

In 2007, a mother walked in on her child and Defendant Jonathan Folk "just playing." She would later learn that Defendant had placed his mouth on the child's penis. The State charged Defendant with lewd conduct. Defendant would be later tried by a jury, found guilty and sentenced to life in prison without parole. Defendant appealed. Principal among his arguments was that the State violated his statutory right to a speedy trial. At issue for the Supreme Court's review was whether the postponement of trial at the defendant's request waived the protection of the speedy trial statute, even if the trial was rescheduled within the proscribed period. The Court found that Defendant's request indeed waives protection of the statute. However, the Court vacated Defendant's conviction on errors by the trial court. The Supreme Court remanded the case for a new trial. View "Idaho v. Folk " on Justia Law