Justia Idaho Supreme Court Opinion Summaries

Mitchell Smith was employed by Amalgamated Sugar Company (“Amalgamated”) in Nampa, Idaho, when he was injured falling from a flight of stairs after the handrail gave out. Amalgamated had contracted with Excel Fabrication, LLC (“Excel”), to construct and install the flight of stairs and the handrail. Smith received worker’s compensation benefits from Amalgamated. Smith then sued Excel as a third-party tortfeasor, alleging that Excel had been negligent in its construction and installation of the staircase. Excel moved for summary judgment, arguing that it was a “statutory co-employee” with Smith and, therefore, it was immune from liability as a result of the exclusive remedy rule. The district court agreed and granted Excel’s motion for summary judgment. The district court then dismissed the case, with prejudice. Smith appealed. Based on the district court’s failure to recognize the differences between an independent contractor from either a contractor or a subcontractor, the Idaho Supreme Court held that the district court erred in granting Excel’s motion for summary judgment: the text of the Worker’s Compensation Law indicated that “independent contractors” were fundamentally different from “contractors and subcontractors” as those terms were used throughout the Idaho Worker’s Compensation Act. Because of this fundamental difference, an independent contractor was not immune from third-party tort liability as a statutory employer. The judgment was reversed and the matter remanded for further proceedings. View "Smith v. Excel Fabrication, LLC" on Justia Law

After suffering personal injuries and property damage in a multi-car collision with an underinsured motorist, Kelly Lynn Christmann filed suit against her insurer, State Farm Mutual Automobile Insurance Company (“State Farm”). Christmann was seeking to obtain the underinsured motorist benefits provided under her contract of insurance, which she claimed State Farm failed to pay in an amount justly due under her policy. She also alleged that certain terms of her insurance agreement violate public policy. State Farm argued that Christmann waived her rights to additional benefits by failing to comply with the contractual obligations of her insurance policy, thereby prejudicing State Farm’s right to subrogation against the underinsured motorist. The district court awarded summary judgment to State Farm in determining it had been prejudiced by Christmann’s conduct and that the terms of the insurance policy were valid. The court also denied Christmann’s motion for reconsideration and her Rule 60(b) motion for relief. Christmann appealed. Because the record showed State Farm fully settled its claims against the underinsured motorist and waived its subrogation rights, the Idaho Supreme Court concluded it suffered no actual prejudice from Christmann’s actions. Accordingly, the judgment was reversed. View "Christmann v. State Farm Mutual Automobile Insurance Co." on Justia Law

At issue in this case was the distribution of charitable donations received by the International Rescue Committee (“IRC) to aid four refugee families and others in the refugee community who were victims of a mass stabbing incident in Boise, Idaho, in 2018. Mustafa Mohammed and Ekhlas Al Khudhur (“Appellants”) challenged a magistrate court’s order approving the final distribution of funds as proposed by IRC. IRC calculated the final distribution of donated funds to the families using a formula of its own creation based on methodology and principles developed by Kenneth Feinberg, an expert on compensation fund valuation and distribution following high-profile, mass tragedies. The district court, acting in its intermediate appellate capacity, affirmed the magistrate court’s order, which held that a trust had been created and that the proposed distribution method for the donated funds was within IRC’s discretion as trustee. On appeal to the Idaho Supreme Court, Appellants argued the district court erred in affirming the magistrate court's decision by: (1) determining there had been a trust created; (2) concluding that IRC’s final distribution was reasonable or within IRC’s discretion; and (3) prohibiting Appellants from presenting evidence of their respective injuries from the attack. Finding no reversible error, the Supreme Court affirmed. View "International Rescue Committee v. Mohammed" on Justia Law

In 2017, Guy Bracali-Gambino pleaded guilty to possession of major contraband in a correctional facility. On direct appeal, the Idaho Court of Appeals, in an unpublished opinion, affirmed his conviction and sentence. Bracali-Gambino subsequently filed a petition for post-conviction relief, arguing in relevant part that his trial counsel had coerced him into pleading guilty, provided erroneous legal advice regarding sentencing enhancements for persistent violators, and failed to investigate the prosecution’s evidence. Bracali-Gambino contended, that considering these errors, his trial counsel had been ineffective. Except for a portion of one of Bracali-Gambino’s claims (Claim II), the district court summarily dismissed his claims relevant to this appeal without conducting an evidentiary hearing. The district court also ultimately dismissed the one remaining claim following an evidentiary hearing. The Idaho Supreme Court affirmed the district court’s dismissal of Bracali-Gambino’s petition for post-conviction relief. Claim II failed because Bracali-Gambino specifically disclaimed, while under oath at his change of plea hearing, that anyone (which included his defense counsel) had coerced or pressured him into pleading guilty. Claim III failed because Bracali-Gambino’s conclusory allegations were not sufficient to show that he was prejudiced by the purported erroneous legal advice. Finally, Claim VI failed because Bracali-Gambino did not provide a sufficient explanation as to how certain testimony would have contradicted the State’s evidence that he attempted to possess major contraband. View "Bracali-Gambino v. Idaho" on Justia Law

The issue this case presented for the Idaho Supreme Court's review centered on a wage claim dispute between Pat Stiffler and his previous employer, Hydroblend, Inc. After a dispute arose concerning incentive pay on an allegedly miscoded account, Stiffler filed a complaint for unpaid wages, breach of contract, retaliation, and wrongful termination. The proceedings culminated with two orders from the district court that: (1) awarded summary judgment to Hydroblend concerning treble damages; (2) concluded multiple issues were governed by an arbitration provision in Stiffler’s employment agreement; and (3) denied summary judgment where disputed facts remained at issue. Stiffler appealed the district court’s decisions, arguing that he is entitled to treble damages on all wages under Idaho’s Wage Claim Act, as well as severance pay under his 2019 employment contract. Stiffler also argues that the district court erred by compelling arbitration of some of his claims. The Idaho Supreme Court reversed the district court’s dismissal of Stiffler’s arbitrable claims because they should have been stayed, not dismissed. However, the Court affirmed the district court’s determination that a 2019 Contract controlled the issue of incentive pay while the remaining claims arose under a 2021 Contract and its arbitration agreement. As the prevailing party, Hydroblend was entitled to costs on appeal pursuant to Idaho Appellate Rule 40(a). View "Stiffler v. Hydroblend, Inc." on Justia Law

Shake Out, LLC entered into a contract with Clearwater Construction, LLC (“Clearwater”), to repair the building Shake Out’s restaurant occupied. The relationship between the parties quickly deteriorated, resulting in Shake Out filing a lawsuit against Clearwater. The parties attempted to mediate their dispute but were unsuccessful. After the case had proceeded for some time, Clearwater sought to compel arbitration pursuant to the contract. Shake Out objected, asserting that Clearwater had waived its right to enforce the arbitration clause because it had participated in the litigation for almost ten months before seeking to compel arbitration. The district court concluded Clearwater had not waived its right to seek arbitration and entered an order compelling arbitration and staying the proceedings. Finding no reversible error in that judgment, the Idaho Supreme Court affirmed. View "Shake Out, LLC v. Clearwater Construction, LLC" on Justia Law

Appellant North West Neighborhood Association challenged a district court’s decision upholding Boise City Council’s approval of three interrelated land use applications. The Idaho Supreme Court agreed with Appellant that Boise City Council failed to provide a reasoned statement explaining its approval of the applications as required by section 67-6535(2) of the Local Land Use Planning Act. The Court remanded this matter to the district court with instructions to set aside Boise City Council’s actions and remand to the Council for the adoption of a reasoned statement. View "NW Neighborhood Assoc v. City of Boise" on Justia Law

Holly Rich brought a legal malpractice action against her attorneys, Hepworth Holzer, LLP, and E. Craig Daue and Daue Buxbaum, PLLC (“Daue Buxbaum”) (collectively, “Respondents”), regarding their legal representation of Rich in an underlying medical malpractice action against Eastern Idaho Regional Medical Center (“EIRMC”), Dr. John Lassetter (a cardiologist), and Dr. Charles Phillips (an intensivist) (collectively, “EIRMC providers”). In that action, Rich's claims against the EIRMC providers failed because they were filed after the statute of limitations expired. Rich alleged in this action that those claims were not filed on time because of Respondents’ legal malpractice. Both sides filed substantive motions for summary judgment and the district court found that Rich could not prevail because she had “not disclosed any expert [medical] testimony which complies with the requirements of Idaho law for admissibility.” The district court concluded that, lacking evidence to “set out a prima facie case of medical malpractice,” in the underlying case, Rich’s claim against Respondents for legal malpractice failed. Rich appealed. The Idaho Supreme Court found no reversible error and affirmed. View "Rich v. Hepworth Holzer" on Justia Law

This lawsuit arose from an investigation into whether Appellant Kristine McCreery abused or neglected her fifteen-year-old son, B.M. McCreery filed a complaint against two physicians who reported the alleged abuse, the detective who investigated the reports, the deputy prosecutor who filed the Child Protection Act (“CPA”) action, and the social worker for the Idaho Department of Health and Welfare who submitted an investigatory report and testified in the CPA case (collectively “defendants” or “Respondents”), alleging they had violated her constitutional rights and Idaho’s false reporting statutes when they took actions to separate her from B.M. for over fifteen months. The district court dismissed McCreery’s claims with prejudice after finding Respondents were immune from liability and that the allegations in McCreery’s complaint failed to state any valid claim upon which relief could be granted. McCreery moved to amend her complaint, which the district court denied. McCreery appealed to the Idaho Supreme Court, arguing that the district court erroneously dismissed her claims. The Supreme Court found no reversible error and affirmed. View "McCreery v. King, M.D., et al." on Justia Law

After methamphetamine was found on his person during a pat search, Appellant John Doe was charged with felony possession of a controlled substance and two related misdemeanors under the Juvenile Corrections Act (“JCA”). Doe moved to suppress this evidence as the product of an unlawful search under the Fourth Amendment, which the magistrate court denied. Doe then sought permission to appeal the magistrate court’s decision to the district court, sitting in its intermediate appellate capacity. When the magistrate court denied permissive appeal, an intermediate appeal was filed with the district court. The district court dismissed Doe’s appeal, concluding that a permissive appeal was not available to Doe because he had not yet been adjudicated of any violation under the JCA. Doe then appealed to the Idaho Supreme Court, arguing: (1) he was “within the purview” of the JCA; and (2) Idaho Code section 20-528 permitted an appeal as a matter of right to a juvenile defendant whose motion to suppress has been denied. The Idaho Supreme Court concluded the plain language of the statute did not permit a juvenile defendant to file this type of interlocutory appeal. Accordingly, the Court affirmed the district court’s dismissal of John Doe’s interlocutory appeal. View "Idaho v. John Doe" on Justia Law