Justia Idaho Supreme Court Opinion Summaries

A homeowners association in Fremont County, Idaho sought to enforce an amendment to its covenants, conditions, and restrictions (CCRs) prohibiting short-term rentals (less than thirty days) in a subdivision. The amendment was adopted in 2016 by a majority vote of property owners; however, the owners of one particular property at that time, C&L Lee, L.C., expressly voted against the restriction and did not provide written consent. After the amendment, the property was transferred multiple times, with each new deed referencing the CCRs, but none of the subsequent owners ever gave express written consent to the short-term rental restriction. In 2022, the HOA discovered the property was being advertised as a short-term rental and brought suit against the current owners, seeking injunctive and declaratory relief.The District Court of the Seventh Judicial District reviewed cross-motions for summary judgment, focusing on the interpretation of Idaho Code section 55-3211. The district court found the statute unambiguously protected properties from newly added rental restrictions unless the property owner at the time of the restriction’s adoption expressly agreed in writing. Because no owner of the property, either at the time of the amendment or thereafter, had provided written consent, the court concluded the restriction did not encumber the property and could not be enforced against the current owners.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Supreme Court held that Idaho Code section 55-3211 prohibits a homeowners association from adding or enforcing rental restrictions unless the property owner at the time of the amendment consents in writing. The restriction did not bind the property or successors because consent was never given. Consequently, summary judgment for the homeowners was affirmed, and neither party was awarded attorney fees. Costs on appeal were awarded to the homeowners. View "North Henry's Lake v. Norton" on Justia Law

After the death of Glenna Mae Wylie-Nelson, her Last Will and Testament devised her home and two lots to her son Leslie H. Wylie, but reserved a life estate for her husband, Larry T. Nelson. The Will also provided that if Larry and Leslie agreed to sell the property during Larry’s lifetime, Leslie would receive the first $40,000 from the sale and the remaining proceeds would be split equally. Larry claimed that community property funds were used for maintenance and improvements on the property during his 35-year marriage to Glenna Mae and sought compensation for the increase in property value attributable to these efforts.While Glenna Mae’s estate was being probated in the Magistrate Court of Bonner County, Larry filed a petition under the Trust and Estate Dispute Resolution Act (TEDRA) in the District Court of the First Judicial District. He sought a judicial declaration of his rights in the property and compensation for his claimed community property interest. Respondents, including Leslie and the estate’s co-personal representatives, moved to dismiss the petition, arguing lack of jurisdiction and failure to state a claim. Larry attempted to amend his petition to clarify his claims and remove his request for partition by sale. The district court dismissed the petition for lack of jurisdiction under TEDRA, denied leave to amend, and awarded attorney fees to the Respondents.The Supreme Court of the State of Idaho reviewed the case de novo. It held that TEDRA provides district courts with broad subject matter jurisdiction over estate and trust matters, including Larry’s claims for declaratory relief regarding his interest in property passing at death. The Supreme Court vacated the district court’s judgment, reversed its orders denying leave to amend and awarding attorney fees, and remanded for further proceedings. Larry was awarded costs on appeal. View "Nelson v. Wylie" on Justia Law

A group of cities holding junior ground water rights in the Eastern Snake Plain Aquifer sought judicial review of a final order issued by the Director of the Idaho Department of Water Resources. This order updated the methodology used to assess whether pumping by junior ground water users caused material injury to senior surface water rights holders who divert water from the Snake River. The Director’s Fifth Amended Final Order revised technical aspects of the model and data, and after a hearing on objections by the cities, the Director affirmed the methodology with modifications and issued a Sixth Methodology Order, which expressly superseded all prior methodology orders.The cities filed a petition for judicial review in the Snake River Basin Adjudication district court, challenging the Director’s Post-Hearing Order regarding the Fifth Methodology Order. The district court affirmed the Director’s findings and conclusions, upholding the methodology and the application of the clear and convincing evidence standard, and found that the Director did not prejudice the cities’ substantial rights. The district court’s judgment specifically affirmed the Post-Hearing Order but did not address the operative Sixth Methodology Order.On appeal, the Supreme Court of the State of Idaho reviewed whether the cities had properly invoked its jurisdiction. The Court held that the cities failed to challenge the currently operative Sixth Methodology Order in district court, and therefore, under Idaho law, the Court lacked jurisdiction to consider the appeal or award the requested relief. As a result, the appeal was dismissed for lack of jurisdiction. The Court awarded attorney fees and costs to the Idaho Department of Water Resources but denied attorney fees to the intervening Surface Water Coalition, granting them costs only. View "City of Idaho Falls v. IDWR" on Justia Law

The claimant suffered a workplace injury while lifting a box, resulting in immediate neck and shoulder pain. She promptly sought medical treatment and was diagnosed with a shoulder strain, receiving temporary disability benefits and performing light duty work. Over time, her symptoms persisted and evolved, leading to various medical evaluations, including imaging studies and independent medical exams. Disagreement arose between medical providers regarding the nature and cause of her cervical spine abnormalities, with one provider opining that a herniated disc at C6-7 was caused by the accident and recommending surgery, while others attributed her symptoms to mild degenerative changes not caused by the workplace incident.After exhausting benefits and undergoing surgical procedures outside of the worker’s compensation system, the claimant filed a complaint with the Idaho Industrial Commission seeking additional medical and disability benefits, asserting that her cervical condition was work-related. Following a hearing, the Commission weighed conflicting medical expert testimony and found some inconsistencies and possible exaggeration in the claimant’s symptom reporting. Ultimately, the Commission determined that the claimant had proven a shoulder injury from the accident but failed to establish, to a reasonable degree of medical probability, that her herniated disc or cervical spine condition was caused by the workplace event.The Supreme Court of the State of Idaho reviewed the Commission’s decision. Applying the standard that factual findings by the Commission will not be disturbed unless clearly erroneous, and that legal conclusions are subject to free review, the Court found substantial and competent evidence supporting the Commission’s denial of additional benefits for the cervical spine condition. The Court affirmed the Commission’s decision and held that neither party was entitled to attorney fees on appeal. View "Proulx v. Saveway Market, Inc." on Justia Law

Joel Ward performed construction work for Bishop Construction, LLC and its sole member, Ren Bishop, in Idaho, Montana, and Wyoming, with an agreed hourly wage and travel compensation. Despite keeping detailed records of his hours, Ward was not paid for work completed between 2017 and 2019, leading him to pursue payment through legal action. The dispute centered on whether Ward should be classified as an employee or an independent contractor and whether he was required to register as a contractor under Idaho law.The case was first heard in the District Court of the Seventh Judicial District of Idaho, Bonneville County. After a bench trial, and based on the parties’ stipulation that Ward was an independent contractor, the court dismissed his wage claims, leaving only breach of contract and unjust enrichment claims. The district court initially awarded Ward full damages for breach of contract. However, after Bishop raised the issue of contractor registration under the Idaho Contractor Registration Act (ICRA) in post-trial motions, the court amended its findings, limited contract damages to out-of-state work, awarded unjust enrichment damages for Idaho work, and granted costs and attorney fees.On appeal, the Supreme Court of the State of Idaho reviewed whether Ward was required to register as a contractor under ICRA and whether the contract was illegal. The Court held that Bishop failed to meet his burden to prove Ward was required to register under ICRA, as the record did not establish Ward’s status as a contractor for those purposes. The Supreme Court vacated the district court’s amended judgment and remanded with instructions to reinstate its original findings and amended judgment, including the previously awarded attorney fees and costs. The Court also awarded Ward attorney fees and costs on appeal as the prevailing party. View "Ward v. Bishop Construction" on Justia Law

Two siblings, Ryan and Nancy, disputed the administration of their father Hal’s estate and the status of his ownership interest in Tautphaus Park Storage, LLC (TPS), an Idaho storage facility business. Hal, who suffered from progressive dementia before his death, was TPS’s sole voting member and manager, with Nancy assisting in legal and management matters. Several amendments to TPS’s operating agreement changed ownership and management, culminating—after Hal’s death—in Nancy executing further amendments that retroactively transferred Hal’s economic interest to herself and changed accounting records. Nancy, an attorney, served as both Hal’s lawyer and later as personal representative of his estate. Ryan questioned whether Hal’s interest in TPS remained an estate asset and sought access to business records, which Nancy resisted.The siblings litigated issues in two related cases in Bonneville County: a probate case in the Magistrate Court regarding Hal’s estate, and a separate TEDRA (Trust and Estate Dispute Resolution Act) civil action in District Court initiated by Ryan. Both courts and parties at times treated the cases as consolidated. Ryan’s TEDRA complaint sought judicial determination of estate assets, breach of fiduciary duty, fraud, and appointment of a receiver, naming Nancy in both her individual and representative capacities and TPS as defendants. The magistrate court dismissed Ryan’s claims and removed Nancy and TPS as parties, finding that estate matters should be decided exclusively in probate. The district court affirmed, denying Ryan’s motions and dismissing his amended complaint, reasoning that Ryan’s claims were matters for probate only.On appeal, the Supreme Court of the State of Idaho vacated both lower courts’ judgments. It held that Ryan’s claims for judicial determination of estate assets and breach of fiduciary duty fall within TEDRA’s definition of “matters” and may be raised in a separate civil action, not only in probate. The Court reversed the orders dismissing claims and parties, remanded the case for further proceedings, and awarded costs and reasonable attorney fees to Ryan against Nancy personally. View "Monson v. Monson" on Justia Law

Two couples entered into a written agreement for the sale and purchase of a condominium in Idaho, using a standard real estate contract form. The property was identified by its street address, unit number, and condominium name. After agreeing to terms and signing the contract, the sellers informed the buyers that they no longer wished to sell. The buyers, who had already paid earnest money, secured financing, and prepared for closing, sought to enforce the agreement. The sellers refused to proceed, claiming the contract was unenforceable due to an inadequate property description under the statute of frauds and asserting the parties had mutually rescinded the agreement.The case was first heard in the District Court of the First Judicial District, Bonner County. The court denied both parties’ motions for summary judgment on the statute of frauds and specific performance, finding factual disputes. After a bench trial, the district court ruled that the property description in the contract was sufficient to satisfy the statute of frauds. At a subsequent jury trial, the jury found that the contract was valid, had not been rescinded or abandoned, and that the sellers breached it, awarding the buyers damages. The district court, however, granted the sellers’ motion for partial summary judgment, finding the remedy of specific performance unavailable because the buyers had not tendered the full purchase price at closing.On appeal, the Supreme Court of the State of Idaho affirmed that the contract’s property description satisfied statutory requirements and thus dismissed the sellers’ statute of frauds defense. The court held that the district court erred in denying specific performance solely for failure to tender the full purchase price, especially since the sellers’ conduct prevented completion. The Idaho Supreme Court reversed the denial of specific performance and remanded for the district court to consider equitable factors. The court also affirmed the award of attorney fees to the buyers and awarded them costs and fees on appeal. View "McLaughlin v. Moore" on Justia Law

The case involves Todd Marshall Frandsen, who was charged with three counts of lewd conduct with minors under sixteen, based on allegations from his three sons. The boys reported that Frandsen engaged in lewd and abusive conduct, including fondling and other forms of mistreatment, over many years. Each son described similar patterns of abuse, which included threats and psychological intimidation. Frandsen was tried before a jury in Bannock County, Idaho, in March 2023.After a four-day trial, the jury convicted Frandsen of two counts related to the older boys and acquitted him of the charge involving the youngest. Frandsen was sentenced to two concurrent life sentences with 25-year fixed terms, later reduced to 20 years fixed upon his motion for reconsideration. He filed timely appeals, arguing that the district court erred by not removing a juror who recalled knowing one of the victims, admitting certain text messages between a victim and their mother, permitting a forensic interviewer to offer expert-like testimony without proper disclosure, and imposing an excessive sentence.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in retaining the juror, as she provided unequivocal assurances of impartiality and her past acquaintance with a victim did not establish actual or implied bias. The Court found the text messages were relevant and non-hearsay, though it did identify harmless error in admitting references to uncharged physical abuse without required Rule 404(b) notice. Similarly, it determined that the forensic interviewer’s limited expert testimony, though improper due to non-disclosure, was harmless given the acquittal on the related charge. The Court also found that the sentence imposed was not excessive. Accordingly, the Idaho Supreme Court affirmed the convictions and sentences. View "State v. Frandsen" on Justia Law

The case arises from a procurement process initiated by Idaho’s Division of Purchasing to select a contractor to provide behavioral health and substance abuse services for the Idaho Department of Health and Welfare. Carelon Behavioral Health, Inc. was initially selected as the winning bidder. However, the other two bidders, Magellan Healthcare and United Behavioral Health (Optum), challenged Carelon’s eligibility, arguing that Carelon had previously been paid by the State for services used to prepare the specifications of the contract, which would bar it from bidding under Idaho Code section 67-9230(8). A determinations officer reviewed the matter and found that Carelon's prior work did influence the contract specifications, rendering it ineligible. The Director of Administration adopted this recommendation, rescinded the intent to award the contract to Carelon, and ultimately awarded it to Magellan.Following this, Carelon filed a complaint in the District Court of the Fourth Judicial District seeking declaratory relief and a writ of mandate to overturn the Director’s decision and reinstate its bid. The district court dismissed the complaint for lack of subject matter jurisdiction, reasoning that Carelon’s claims were, in substance, a request for judicial review of the Director’s procurement decision, which is expressly precluded by the State Procurement Act unless the case arises from a contested case hearing. The court also rejected Carelon’s claims for a writ of mandate and its constitutional challenges to the statute.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s dismissal. The Court held that the State Procurement Act prohibits judicial review of procurement decisions made outside of contested case hearings and that Carelon’s claims could not be recast as an original declaratory judgment action to circumvent this limitation. The Court also found that the statutory bar on judicial review does not violate the separation of powers under the Idaho Constitution and that section 67-9230(8) is not unconstitutionally vague as applied to Carelon. View "Carelon Behavioral Health, Inc. v. State" on Justia Law

A woman was convicted of possessing methamphetamine and drug paraphernalia after police discovered these items during a search of a residence she shared with another individual who was on probation. The search was initiated when a probation officer visited to verify the housemate's residence. The woman answered the door, attempted to refuse entry by shutting the door, but the officer entered regardless and proceeded to search the shared bedroom after both occupants indicated there might be contraband present. The officer found drugs and paraphernalia in the room, and both individuals were charged.Previously, the District Court of the Fourth Judicial District, Ada County, denied the woman's motion to suppress the evidence, rejecting her argument that the search was unlawful under Georgia v. Randolph because she had expressly objected to the entry. The district court also admitted a police body camera video at trial, which included statements from her housemate that allegedly violated her Sixth Amendment confrontation rights under Bruton v. United States. The case proceeded to a joint jury trial, resulting in guilty verdicts for both defendants.The Supreme Court of the State of Idaho reviewed the case. It held that the search was lawful because the probationer's waiver of Fourth Amendment rights as a condition of probation allowed officers to enter and search shared areas, even over the objection of a co-occupant. The Court declined to extend the Randolph rule to probation searches, reasoning that co-tenants of probationers have a reduced expectation of privacy. Regarding the confrontation issue, the Court found that admitting the body camera footage was error under Bruton, but determined the error was harmless due to overwhelming independent evidence of guilt. The Court affirmed the district court’s judgment of conviction. View "State v. Horn" on Justia Law