Justia Idaho Supreme Court Opinion Summaries

Husband and Wife divorced in 2020, with Husband required to pay child support and attorney fees. Two years later, Wife initiated a contempt proceeding against Husband for failing to comply with the divorce decree. On the day of the contempt trial, Husband informed the court he was unable to attend due to vehicle issues. The magistrate court proceeded with the trial in his absence, found him in criminal contempt, and sentenced him to 70 days in jail, with 50 days suspended, and ordered him to pay additional attorney fees.The district court affirmed the magistrate court's decision to hold the trial in Husband's absence but reversed the incarceration sanction, finding insufficient evidence that Husband waived his right to counsel. The district court concluded that the magistrate court violated Idaho Rule of Civil Procedure 75(l)(1) by imposing incarceration without an attorney present to represent Husband.The Idaho Supreme Court reviewed the case and determined that the magistrate court erred in holding the contempt trial in Husband's absence. The court held that a contemnor's right to be present at a criminal contempt trial is protected under the Sixth Amendment, similar to a criminal defendant's right. The court concluded that Husband's willful absence did not constitute a knowing, intelligent, and voluntary waiver of his right to be present. The proper procedure would have been to issue a writ of attachment to ensure Husband's attendance.The Idaho Supreme Court reversed the district court's decision and remanded the case with instructions to vacate the order of contempt and remand to the magistrate court for further proceedings. The court also found the district court's failure to address Wife's request for attorney fees harmless, as Husband's appeal was not frivolous. No attorney fees were awarded on appeal, and costs were awarded to Husband. View "Salazar v. Salazar" on Justia Law

Lance A. Roberts appealed the district court's decision affirming the magistrate court's denial of his Idaho Criminal Rule 35 motion in a misdemeanor DUI case, his Rule 35 motions in felony DUI cases, and the dismissal of his petitions for post-conviction relief in those felony DUI cases. Roberts sought to amend his multiple DUI convictions over the past two decades, arguing that his April 1998 conviction for a second "adult" misdemeanor DUI should have been charged as a second "juvenile" misdemeanor DUI. He claimed this error had a domino effect, leading to subsequent DUIs being charged as felonies and resulting in a persistent violator sentencing enhancement in his most recent felony DUI case.The magistrate court initially granted Roberts' Rule 35 motion to amend his April 1998 conviction, but the State's motion to reconsider was denied. Roberts then filed multiple motions and petitions to amend his subsequent DUI convictions and eliminate the persistent violator enhancement. The magistrate court denied these motions, and the district court affirmed, concluding that neither Rule 35(a) nor post-conviction relief statutes authorized the requested relief. The district court also reversed the magistrate court's amendment of the April 1998 conviction and dismissed Roberts' petitions for post-conviction relief.The Idaho Supreme Court reviewed the case and upheld the district court's decisions. The Court held that Idaho Criminal Rule 35(a) does not allow for the amendment of a criminal conviction and is limited to correcting illegal sentences apparent from the face of the record. The Court also affirmed that Idaho Code section 19-4901(a) does not permit the relief Roberts sought, as his claims were time-barred and could have been raised on direct appeal. Consequently, the Court affirmed the district court's denial of Roberts' motions and petitions for post-conviction relief. View "State v. Roberts" on Justia Law

Jennifer and Jesse Smith divorced in 2017 after fifteen years of marriage. Jennifer, a stay-at-home mother, and Jesse, a construction superintendent, entered into a Marital Settlement Agreement requiring Jesse to pay Jennifer spousal support until January 1, 2025. The agreement included a "Review Term" stating that spousal support would be reviewed every two years. In 2018, Jesse unilaterally reduced the spousal support payments and later stopped paying altogether, leading Jennifer to file a breach of contract action.The magistrate judge dismissed Jesse's petition to modify the spousal support due to a non-merger clause, which kept the spousal support provision outside the court's jurisdiction. Jennifer then sought partial summary judgment in district court, arguing that the Review Term was too vague to be enforceable. The district court agreed, striking the Review Term but upholding the rest of the spousal support provision under the agreement's severability clause. The jury found Jesse in breach of the agreement and awarded Jennifer $76,514 in damages, plus attorney fees and costs.The Supreme Court of Idaho reviewed the case and affirmed the district court's judgment. The court held that the Review Term was unenforceable due to its vagueness, indefiniteness, and uncertainty. The court also upheld the district court's application of the severability clause, maintaining the enforceability of the remaining spousal support provision. Jennifer was awarded attorney fees and costs on appeal as the prevailing party. View "Smith v. Smith" on Justia Law

James Wilson and Jillian Wilson, who were married and had one minor child, divorced, leading to a custody dispute. The magistrate court awarded primary physical custody to Jillian and allowed her to relocate with the child to Australia, where both hold citizenship. Jillian was also granted sole legal custody over educational and medical decisions, while James was given two weeks of visitation annually during school breaks. James appealed the decision.The magistrate court's decision was based on several factors, including the unhealthy relationship between James and the child, characterized by controlling and manipulative behavior. The court found that James's actions, such as co-sleeping and inappropriate touching, created an environment that could potentially harm the child. The court also considered Jillian's motivations for relocating, including better family support and higher income prospects in Australia.The Supreme Court of Idaho reviewed the case and affirmed the magistrate court's decision. The court held that the magistrate court did not abuse its discretion in allowing Jillian to relocate with the child, as the decision was supported by substantial and competent evidence. The court also found that the magistrate court correctly applied the legal standard for relocation and considered the best interests of the child.Additionally, the Supreme Court of Idaho upheld the magistrate court's decision to limit James's physical custody and visitation, as well as the award of sole legal custody to Jillian for educational and medical decisions. The court concluded that these decisions were in the best interests of the child and were supported by substantial evidence. Jillian was awarded attorney fees and costs on appeal. View "Wilson v. Wilson" on Justia Law

In 2014, Casey Moyer entered into an agreement with Doug Lasher Construction, Inc. for the construction and purchase of a new home, which was substantially completed in November 2014. Over the next six-and-a-half years, Moyer repeatedly informed Lasher Construction about issues with the home, particularly water leakage, and received assurances that the issues would be fixed. However, the problems persisted, and Moyer and Caitlin Bower filed suit against Lasher Construction in November 2021, alleging breach of contract and violation of the Idaho Consumer Protection Act.The District Court of the Fourth Judicial District of Idaho granted summary judgment in favor of Lasher Construction, ruling that all claims were time-barred under Idaho Code sections 5-241(b) and 5-216, which require that claims arising out of a contract for the construction of real property be brought within five years of the final completion of construction. The court also found that the Idaho Consumer Protection Act claims were time-barred under the two-year statute of limitations provided by Idaho Code section 48-619. The court rejected the homeowners' arguments for equitable estoppel and the repair doctrine, concluding that they failed to show that Lasher Construction prevented them from pursuing their claims within the statutory period.The Supreme Court of Idaho affirmed the district court's decision. The court reaffirmed that the repair doctrine is not available in Idaho and upheld the district court's conclusion that the homeowners failed to establish the elements of equitable estoppel. The court also agreed that the text messages and the July 2, 2021, response to the NORA demand did not constitute enforceable independent contracts. Lasher Construction was awarded attorney fees and costs on appeal as the prevailing party. View "Moyer v. Lasher Construction, Inc." on Justia Law

Tony Heath and Melissa Lish, neighbors in Chubbuck, Idaho, had a dispute after Heath parked two vehicles near Lish’s driveway. Lish, after Heath refused to move the vehicles, obtained a no parking sign from Denny’s Wrecker and had the vehicles towed. Denny’s refused to release the vehicles without payment. Heath sued Lish and Denny’s for civil trespass and conversion. The magistrate court granted summary judgment in favor of Lish and Denny’s and awarded attorney fees to Denny’s. Heath appealed, and the district court affirmed the magistrate court’s decisions.The Idaho Supreme Court reviewed the case. The court affirmed the district court’s decision regarding Denny’s summary judgment, holding that Denny’s actions were lawful under Idaho Code section 49-1806(1) and that Denny’s reasonably relied on Lish’s representations. The court found that Denny’s had no duty to verify the property line beyond Lish’s information and that Heath’s vehicles were towed lawfully. The court also affirmed the district court’s decision to reduce Denny’s attorney fee award, finding that the magistrate court did not need to address every factor in writing.However, the court reversed the district court’s decision regarding Lish’s summary judgment. The court found that genuine issues of material fact existed concerning whether there was boundary by acquiescence or boundary by agreement. The court noted that the declarations from previous property owners and the removal of part of the driveway by Lish’s husband raised questions about the boundary’s location and whether there was an agreement or acquiescence. The court remanded the case for further proceedings on Heath’s trespass and conversion claims against Lish.The court declined to award attorney fees on appeal to any party, noting that the issues raised were not pursued frivolously or without foundation. View "Heath v. Denny's Wrecker Service, Inc." on Justia Law

Ginger Collins, acting on behalf of her mother Jean Mace, sought to invalidate the sale of Jean’s home, which was sold by her sister Judy Mace without Ginger’s knowledge. Jean and her husband had transferred the property to Judy, who lived with them and acted as their caretaker. After Jean was moved to an assisted living facility and Judy was diagnosed with cancer, Judy created a revocable trust and transferred the property to it. Shortly before her death, Judy sold the property to Deborah and Raymond Luther. Ginger, believing the property was held in trust for Jean’s benefit, filed suit to evict the Luthers and invalidate the sale.The District Court of the First Judicial District, Boundary County, granted partial summary judgment in favor of Scott Mace (Judy’s cousin and trustee) and the Luthers, dismissing Ginger’s resulting trust claim. The court ruled that the deed transferring the property to Judy was unambiguous and that extrinsic evidence was inadmissible to establish a resulting trust. Ginger’s motion for reconsideration was denied, and the court also denied Scott Mace’s request for attorney fees under the Trust and Estate Dispute Resolution Act (TEDRA).The Supreme Court of Idaho reviewed the case and held that the district court erred in excluding extrinsic evidence to support Ginger’s resulting trust claim. The court emphasized that extrinsic evidence is admissible to establish a resulting trust, as it can reveal the parties’ intent. The Supreme Court vacated the district court’s judgment, reversed the grant of partial summary judgment, and remanded the case for further proceedings. The court declined to address the public policy argument and denied attorney fees on appeal for both parties. View "Mace v. Luther" on Justia Law

Stephen Lowery, a heavy equipment operator in the logging industry, filed a workers' compensation claim against his employer, Galen Kuykendall Logging, and its surety, Associated Loggers Exchange. Lowery claimed that his work caused a new occupational disease at the L3-4 level of his spine, distinct from his previous L5-S1 injury. Kuykendall Logging argued that Lowery's L3-4 condition was a continuation of his prior degenerative disease, which began in 1992.The Idaho Industrial Commission initially found that Lowery failed to prove his L3-4 injury resulted from an accident but concluded it was a compensable occupational disease. The Commission determined that Lowery's L3-4 condition arose independently from his previous L5-S1 issues and was aggravated by his work as a shovel logger. The Commission awarded Lowery medical and time loss benefits but denied permanent partial impairment or disability benefits. Kuykendall Logging filed a motion for reconsideration, arguing that Lowery's occupational disease manifested while he was employed by another company, Evergreen Timber.The Idaho Supreme Court reviewed the case and affirmed the Commission's decision. The Court held that the Commission's findings were supported by substantial evidence, including expert opinions that Lowery's L3-4 condition was a new occupational disease caused by his work. The Court also agreed that Lowery's occupational disease manifested on or after June 19, 2019, while he was employed by Kuykendall Logging. The Court found that Lowery complied with the notice and limitation requirements and that the Nelson doctrine did not preclude his recovery. Finally, the Court held that the Commission did not abuse its discretion by retaining jurisdiction and holding a second hearing to determine Lowery's last injurious exposure. View "Lowery v. Kuykendall" on Justia Law

Daniel Genho and Riverdale Hot Springs, LLC had a dispute over payment for construction work Genho performed at Riverdale Resort. Genho was not a registered contractor at the start of the project but became registered midway through. Riverdale refused to pay Genho and prevented him from retrieving his tools and materials. Genho filed a Mechanic’s and Materialmen’s Lien and sued for breach of contract, unjust enrichment, quantum meruit, conversion, and to foreclose on the lien.The District Court of the Sixth Judicial District of Idaho granted Riverdale’s motion for a directed verdict on the breach of contract claim but denied it on the other claims. The court found that there were two separate transactions: one before and one after Genho became a registered contractor. The court allowed the jury to consider the unjust enrichment, quantum meruit, conversion, and lien foreclosure claims. The jury found in favor of Genho, awarding him $295,568, which was later reduced to $68,681. The district court also awarded attorney fees to Genho.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision in part and reversed it in part. The court held that equitable remedies are available under the Idaho Contractor Registration Act (ICRA) for work performed after a contractor becomes registered, provided the work is severable from the unregistered work. The court affirmed the denial of a directed verdict on the unjust enrichment, quantum meruit, and lien foreclosure claims but reversed the award of attorney fees for the conversion claim, as it was not based on a commercial transaction. The court also affirmed the award of attorney fees for the foreclosure action under Idaho Code section 45-513. Neither party was awarded attorney fees on appeal. The judgment was vacated and remanded for modification consistent with the opinion. View "Genho v. Riverdale Hot Springs, LLC" on Justia Law

The defendant, Jameel Fakhri Al Muthafar, was convicted of aggravated assault and attempted strangulation. The case arose when K.S., the victim, called the police from a Rite Aid store in Boise, Idaho, expressing suicidal thoughts and claiming she had been attacked by her romantic partner, Al Muthafar. K.S. was taken to St. Alphonsus Hospital, where she was diagnosed with injuries from an alleged assault. She was then referred to FACES for a forensic examination, during which she described the assault and identified Al Muthafar as the perpetrator.At the preliminary hearing, the magistrate court admitted hearsay statements made by K.S. to a nurse during the FACES examination, over Al Muthafar’s objection. The magistrate court found probable cause to bind the case over to the district court. Al Muthafar filed a motion to dismiss the Information, arguing that the hearsay statements were inadmissible and that without them, there was insufficient probable cause. The district court denied the motion, and the case proceeded to trial, where Al Muthafar was found guilty by a jury.The Supreme Court of Idaho reviewed the case and determined that the magistrate court erred in admitting the hearsay statements at the preliminary hearing, as the State failed to establish that the statements were made for the purpose of medical diagnosis or treatment. However, the court held that this error was harmless because Al Muthafar received a fair trial, where the jury found him guilty beyond a reasonable doubt based on properly admitted evidence.Additionally, the court reviewed Al Muthafar’s sentence of fifteen years with five years fixed and found no abuse of discretion by the district court. The sentence was deemed reasonable given the severity of the charges, the defendant’s risk of future violence, and his lack of remorse. The Supreme Court of Idaho affirmed both the conviction and the sentence. View "State v. Al Muthafar" on Justia Law