Justia Idaho Supreme Court Opinion Summaries

Appellant Twin Lakes Canal Company (Twin Lakes) owned a reservoir. Respondents Warren and Sessilee Choules own property subject to a "prescriptive overflow" easement by Twin Lakes. In 2008, Twin Lakes filed suit against the Choules, alleging that the Choules moved earth, rocks, concrete and other debris from elsewhere on their property into areas below the height of the reservoir, which reduced the reservoir's storage space and damaged a lining designed to prevent leaks. The district court determined that state law allows the Choules as owners of the servient property, to use their property in any way they see fit, despite the common law rule that generally prohibits them from using their property in a way that interferes with the "dominant estate." The district court dismissed Twin Lakes' complaint. On appeal to the Supreme Court, Twin Lakes argued that the district court misinterpreted state law in its ruling in favor of the Choules. Upon careful consideration of the plain meaning of the applicable legal authority, the Supreme Court affirmed the lower court's decision. View "Twin Lakes Canal Co. v. Choules" on Justia Law

Plaintiff Eileen McDevitt tripped and fell on a recessed irrigation box outside Sportsman's Warehouse. The store was part of a larger shopping center. Plaintiff sued the store and others to recover for her injuries. The district court granted summary judgment in favor of the store, finding that as a tenant in the shopping center, the store owed no duty to shoppers (or invitees) to warn them of potential hazards. Plaintiff appealed to the Supreme Court. Upon careful consideration of the arguments and the applicable legal authority, the Supreme Court affirmed the lower court's decision. View "McDevitt v. Sportsmans Warehouse, Inc." on Justia Law

In 2004, a jury found Petitioner Erick Hall guilty of first-degree murder, kidnapping and rape. Petitioner was sentenced to death. Petitioner appealed his conviction, and was appointed a public defender. In 2005, Petitioner petitioned the district court for post conviction relief. In that proceeding, the district court limited contact between Petitioner's counsel and the jurors that convicted him. Petitioner moved for reconsideration. In 2006, Petitioner moved to depose his trial attorneys and their investigator. The court allowed the deposition of trial counsel, but denied leave to depose the investigator. Petitioner's petition for post conviction relief was ultimately denied. On appeal to the Supreme Court, Petitioner challenged all of the district court's denials pertaining to the interview and deposition of jurors and key witnesses so that he could mount a successful appellate petition for relief. The Supreme Court found that the district court did not abuse its discretion in denying Petitioner's requests. The Court affirmed the district court's decision on all issues. View "Hall v. Idaho" on Justia Law

Defendant Jonathan Ellington appealed his conviction for murder and aggravated battery. He argued on appeal to the Supreme Court that prosecutorial misconduct, evidentiary errors, a biased jury and the "cumulative error doctrine" entitled him to a new trial. The Supreme Court found merit to several of Defendant's claims. The Court found that the district court abused its discretion when it denied Defendant a new trial after evidence came to light that the State's sole rebuttal witness provided false testimony at trial. The Court vacated Defendant's conviction and sentence, and remanded the case for a new trial. View "Idaho v. Ellington" on Justia Law

Appellants Samuel Jr. and Laurie Schneider appealed the district court's decree quieting title to real property in favor of Respondents Vernon and Dorothy Kennedy as adverse possessors. In 1924, Mr. Kennedy's great-uncle purchased the property that would eventually be passed to the Kennedys. When the Kennedys decided to place their property up for sale, they became aware that three parcels of the property that they believed had been owned by their family for generations were the subject of deeds in favor of other parties. In 2007, the Kennedys initiated a quiet title action to assert ownership over the three parcels as adverse possessors under a written claim of title. A default judgment in favor of the Kennedys was entered against the titleholders of record for two of the three parcels. The Schneiders answered and defended the Kennedys' claim to the third parcel. The district court issued a memorandum finding that the Kennedys had proved the elements of their claim of adverse possession by clear and satisfactory evidence. The court then entered a decree quieting title to the third parcel. The Schneiders appealed to the Supreme Court. Upon review, the Supreme Court found that there was not substantial, competent evidence to support the district court's findings. The Supreme Court vacated the lower court's decree and its judgment awarding attorney fees. The Court remanded the case for further proceedings. View "Kennedy v. Schneider" on Justia Law

Plaintiffs Knipe Land Company (KLC) and John Knipe appealed a jury verdict in favor of Defendants Richard and Johnnie Robertson and Robertson Kennels, Inc. KLC is a real estate broker that specializes in agricultural and commercial real property. In 2005, the Robertsons signed an employment contract with KLC, where KLC was granted an exclusive listing to sell 1400 acres they owned. KLC would earn a percentage commission of the sales price or nonrefundable portions of any earnest money paid. In 2005, Robert and Sheila Harmon signed a purchase contract to buy the Robertsons' 1400 acres. The Harmons paid $50,000 as earnest money. Under the terms of the purchase agreement, $35,000 of the earnest amount would be non-refundable. The Harmons did not purchase the property, and the nonrefundable portion of the earnest money was transferred from the Harmons' real estate broker to KLC, which in turn distributed it to the Robertsons. In 2007, Robertson Kennels signed an employment contract with KLC to sell 1887 acres of land it owned. MidAmerican Nuclear Energy Company, LLC entered into a purchase agreement to purchase all of the Robertsons' property. The company paid $450,000 as nonrefundable earnest money. MidAmerican did not purchase the Robertsons' property. After the Harmon and MidAmerican purchase contracts ended, KLC demanded the Robertsons' pay its commission from the two cancelled purchase agreements. Upon review, the Supreme Court found that the Robertsons "clearly breached the unambiguous employment contracts and there was insufficient evidence to support the jury's verdict." The Court vacated the damages and attorney fees that were awarded to the Robertsons at trial, and remanded the case to the district court for further proceedings. View "Knipe Land Co. v. Robertson" on Justia Law

The Idaho Department of Water Resources (Department) appealed an order of the district court that required it to strike a term from a hydropower water right license issued to the Idaho Power Company. In 1984, an agreement was entered into between Idaho Power, the State, the governor, and the attorney general, in an effort to resolve a controversy associated with the company's water rights at the Swan Falls Dam. As part of the Swan Falls agreement, the parties agreed to support legislation for the commencement of an adjudication of water rights in the Snake River Basin. One key piece of the legislation that was passed pursuant to the Swan Falls Agreement gave the Department specific authority to subordinate hydropower rights in a permit or license to the rights of subsequent upstream depletionary users. The Department was also authorized to limit a permit or license involving hydropower to a term of years. The Department issued a final order that articulated the legal basis for including the "term of years" condition in the license to Idaho Power. The Company sought judicial review of the Department's final order, arguing that the Department did not have statutory authority to include a term condition in its license. The court indeed concluded that the Department did not have the authority to limit the license. The Department appealed to the Supreme Court. Upon review, the Supreme Court found that the Department had the statutory authority to include a term condition in Idaho Power's license. The Court reversed the district court's decision. View "Idaho Power Company v. Idaho Dept of Water Resources" on Justia Law

Appellant Lesia Knowlton appealed the Industrial Commission's determination that she was not entitled to workers' compensation benefits. Appellant was employed as a secretary at Respondent Wood River Medical Center. In 2000, Appellant was working at her assigned station when a drain in a nearby patient's bathroom became clogged. One of the maintenance workers used a chemical cleaner to clear the drain. The chemical produced a foul odor. Workers placed fans at the doorway of the room for ventilation. The air blew past Appellant's station from morning until her shift ended in the afternoon. That night, Appellant developed a cough and body aches. Her symptoms persisted, allegedly from exposure to the chemical drain cleaner. Over the course of five years, Appellant visited multiple doctors and specialists to treat her "bronchitis-like" symptoms. Appellant filed a complaint with the Industrial Commission seeking reimbursement for her medical expenses and for temporary total disability benefits. At a Commission hearing, the referee ultimately concluded that Appellant failed to demonstrate that her medical symptoms were causally related to the chemical exposure. Although the referee determined that Appellant was not entitled to "time loss" benefits or any form of disability benefits, he did find that because the medical treatment Appellant received during the six weeks following the incident was a "reasonable precautionary step" taken in response to the exposure, she was entitled to compensation for those expenses. The Commission adopted the referee's findings of fact and conclusions of law. The Commission denied Appellant's motion for reconsideration. Subsequently Appellant appealed to the Supreme Court. The Supreme Court agreed that Appellant failed to demonstrate her medical symptoms were related to the chemical exposure. Accordingly the Court affirmed the Commission's determination. View "Knowlton v. Wood River Medical Center" on Justia Law

Appellants David and Kathy Caldwell appealed the district court's refusal to allow the removal of trees within and adjacent to an access road easement that ran over property belonging to their neighbors, Respondents Thomas and Lori Cometto. Until 1997, an access road ran in a straight line directly through the Comettos' property and was subject to a deeded easement that benefited the Caldwells. The Comettos rerouted the road so that it avoided buildings on their property. The new road had four new sharp turns, and was narrower than the previous road. The Caldwells filed suit against the Comettos alleging that the new road injured their rights in the easement. To settle that litigation, the parties signed an agreement that granted Appellants an easement over the newly constructed road. The Caldwells then filed suit in 2007 to quiet title to the new easement, and sought a declaration that the Comettos must upgrade the road to the same standards as the previous road. Furthermore, the Caldwells sought to enjoin the Comettos from placing obstacles in the right-of-way. The trial court quieted title to the easement, and specifically held that the Comettos were to keep the easement free of debris. The Comettos were precluded from removing nineteen mature trees from the easement. Neither side was awarded attorney's fees, because as the court concluded, there was no prevailing party. The Caldwells appealed the denial of attorney's fees and the order regarding the trees. They argued that there was no substantial evidence to support the court's decision. The Supreme Court found that the lower court's record sufficient to support its decision. The Court affirmed the lower court's decision on the trees and the denial of attorney fees. View "Caldwell v. Cometto" on Justia Law

Coeur d'Alene Paving, Inc. (CDA Paving) leased several parcels of real property in Kootenai County from Beacon West, LLC. Approximately thirty acres of this leased property was zoned for mining activity. CDA had an interest in two undeveloped parcels that were initially zoned for agricultural use. The two agricultural parcels bordered the mining-parcel, but were not adjacent to it. In January 2008, CDA Paving submitted an application to the Kootenai County Building and Planning Department to have its two agricultural lots rezoned for mining. The Kootenai County Board of County Commissioners (BOCC) held public hearings on the application, and eventually approved the application. Several property owners located in the vicinity of the zone changes, including Appellant Linda Ciszek, petitioned the district court for a declaratory judgment, alleging the zone change was invalid. The district court granted summary judgment in favor of CDA Paving, holding that the BOCC had the authority to amend its zoning map. Appellants raised multiple issues with the district court's decision. Principal among their arguments to the Supreme Court was that the BOCC lacked statutory authority to approve a zoning application as it had for CDA Paving. The Supreme Court found all of Appellants' arguments persuasive, and affirmed the district court's decision. View "Ciszik v. Kootenai County Bd of Commissioners" on Justia Law