Justia Idaho Supreme Court Opinion Summaries

The holders of the second priority mortgage, Ray and Susan Montierth brought a foreclosure action against the holders of the first priority mortgage, Hendrik Dorssers and Justice Prevails, LLC, (collectively “Dorssers”), and a variety of other parties with an interest in the real property. In their pleadings, Dorssers asserted that their priority interest as the holder of the first priority mortgage still prevailed over all other encumbrances. In Dorssers view, a payment made by the debtor—years after the statute of limitations had run on the mortgage—revived the previously stale claim to foreclose their first priority mortgage and reinitiated the statute of limitations under Idaho Code section 5-238. However, on summary judgment the district court concluded that Idaho Code section 5-238 only applied when the payment was made prior to the lapse of the statute of limitations. Accordingly, the district court granted summary judgment to the Montierths after finding that no payment had been made by the obligor prior to the lapse of the statute of limitations and concluding that Dorssers’ mortgage was unenforceable as a matter of law. The district court subsequently denied Dorssers’ motion for reconsideration and objection to the proposed judgment. Thereafter, the district court entered a judgment and decree of foreclosure in favor of the Montierths, which specifically stated: “[t]hat the [Montierths’] lien interest is superior in time to all other parties’ liens, except the mortgage of Hendrik Dorssers and Justice Prevails, LLC, which is time barred and therefor [sic], unenforceable.” On appeal, Dorssers argue the district court erred: (1) in concluding that the partial payments did not extend the statute of limitations for enforcement of the first priority mortgage under Idaho Code section 5-238; (2) in the alternative, in concluding that a junior lien holder could quiet title to a senior lien holder; and (3) in issuing an order to quash the lis pendens they recorded after the appeal was filed. The Idaho Supreme Court reversed, finding the district court erred in its determinations: (1) to revive the statute of limitations the payment must have been made prior to the lapse of the statute of limitations; (2) the “transfer of money” was not a payment in recognition of the debt as a matter of law; and (3) the payment was not made by an obligor as a matter of law. In addition, the Court found the district court erred in striking the lis pendens. The matter was remanded for further proceedings. View "Montierth v. Dorssers" on Justia Law

Appellants Walmart and New Hampshire Insurance Company appealed the Idaho Industrial Commission’s determination that the employee’s widow, Sue Jordan, was entitled to medical and death benefits. More specifically, they challenged the Commission’s application of the presumption set forth in Idaho Code section 72-228 where there was unrebutted prima facie evidence indicating that the employee’s death arose in the course of his employment. Finding no reversible error, the Idaho Supreme Court affirmed the decision of the Idaho Industrial Commission. View "Jordan v. Walmart Associates, Inc." on Justia Law

Marianita Martinez alleged that after she and Victorio Carretero divorced in April 1995, they subsequently entered into a common law marriage between their divorce in April 1995 and their move to California in November 1995. After filing of cross-motions for summary judgment on the common law marriage issue, the magistrate court proceeded to hold an evidentiary hearing without ruling on the motions and without objection from either party. At the evidentiary hearing, the magistrate court excluded all evidence of the parties’ conduct on or after January 1, 1996, as being irrelevant to whether the parties had entered into a common law marriage prior to that date. This ruling resulted in the exclusion of, among other things, evidence of a life insurance application in which Carretero identified Martinez as his “wife” on January 10, 1996—two months after the parties left Idaho in November 1995. At the close of the hearing, the magistrate court concluded there was not sufficient evidence to show that the parties had consented to marry within the seven-month period prior to January 1, 1996. The magistrate court then dismissed Martinez’s claim of a common law marriage, and on appellate review, the district court affirmed. The Idaho Supreme Court affirmed in part, reversed in part, and remand. The Supreme Court found any error in the magistrate court’s decision to conduct an evidentiary hearing before ruling on the pending cross-motions for summary judgment was invited and not preserved for appeal. The magistrate court erred by excluding evidence of the parties’ conduct after December 31, 1995, and by granting Carretero’s motion for an involuntary dismissal. The case was remanded with instructions that the district court remand this matter to the magistrate court for further proceedings. View "Martinez v. Carretero" on Justia Law

The issue this appeal raised concerned a default judgment awarded to Scott and Natalie Pinkham against appellants David Plate, Rebeccah Jensen, and their company, Three Peaks Homes, LLC. When Appellants’ attorney withdrew in the middle of the case, Appellants failed to timely designate new counsel as required by Idaho Rule of Civil Procedure 11.3. Accordingly, a default was entered by the district court. Later, the district court, using a form prepared by the Pinkhams’ attorney, awarded the Pinkhams a default judgment of almost $650,000 without: (1) the amount of damages being specified in the Pinkhams’ complaint; or (2) the presentation of any proof of the amount of damages the Pinkhams were claiming. Appellants later retained an attorney and attempted to set aside the default and the default judgment, asserting that both had been improperly entered. The district court denied both requests. Appellants appealed the district court’s denial of their motion to set aside the entry of default and default judgment against them. Finding that Appellants established a right to relief because the district court erred in awarding damages without any proof, the Idaho Supreme Court reversed in this respect. The Court found the district court did not err in denying the motion to set aside the entry of a default judgment, but vacated the default judgment and remanded for a determination as to the proper amount of damages based on the proof submitted. View "Pinkham v. Plate, et al." on Justia Law

In December 2019, Paul Hanks slipped and fell on a patch of ice after exiting a vehicle in the passenger unloading zone at the Boise Airport. Hanks sued defendants the City of Boise, Republic Parking System, LLC, and United Components, Inc. for negligence. Hanks argued that Defendants had a duty to maintain the airport facilities in a safe condition and that Defendants failed in that duty by not keeping the passenger unloading zone free of ice. Respondents the City of Boise and Republic Parking System, LLC moved for summary judgment, arguing they had met all legal duties owed to Hanks. The district court agreed and granted summary judgment. Finding that the district court did not err in its grant of summary judgment, the Idaho Supreme Court affirmed the district court. View "Hanks v. City of Boise" on Justia Law

Following the State’s dismissal of criminal charges against him, Nickolaus Oldenburg moved the district court to seal the criminal court file pursuant to Idaho Code section 67-3004(10). The State did not contest the motion. Nevertheless, the district court concluded that it did not have the authority to seal Oldenburg’s case file under section 67-3004(10) and, therefore, could not grant his request. As a result of its analysis, the district court denied Oldenburg’s motion. The Idaho Supreme Court held the district court correctly concluded that the legislature could not independently vest the district court with the authority to seal Oldenburg’s court file. "The control of court records resides within the prerogative of this Court, and this Court has adopted I.C.A.R. 32 to govern a defendant’s request to seal court records. ... When the statute is procedural, it is viewed as an attempt 'to control this Court’s processes' and is classified as an impermissible overreach into the authority of this Court to develop its own procedures." Thus, the district court correctly found that Idaho Code section 67-3004(10) impinged on the Supreme Court’s prerogative to make its own rules which governed its own procedure. Accordingly, the decision of the district court was affirmed. View "Idaho v. Oldenburg" on Justia Law

Rodney Harrell appealed his conviction for trafficking in methamphetamine, trafficking in marijuana, and possession of drug paraphernalia. Harrell argued his convictions should have been vacated because: (1) the district court erred in denying his motion to suppress; and (2) the district court erred in denying his objection to the reduction of peremptory challenges imposed by the Idaho Supreme Court’s emergency order adopted in response to the COVID-19 pandemic. Finding no reversible error, the Supreme Court affirmed Harrell’s judgment of conviction. View "Idaho v. Harrell" on Justia Law

The parents in this case were brought to the attention of the Idaho Department of Health and Welfare ("Department") regarding reports of neglect and physical abuse to their five children. The child protection case began in February 2023 as a protective supervision case. Nearly three months later, the magistrate court ordered that the children be removed from the home and placed in the legal custody of the Department. John Doe (Father) appealed the magistrate court’s order removing his five children from the parents’ custody and temporarily placing the children in the legal custody of the Department. Father argued the magistrate court’s order failed to contain detailed written findings as required by Idaho law, that the order was not supported by substantial and competent evidence, and that the magistrate court’s actions violated Father’s fundamental rights to the care and custody of his children. Finding no reversible error, the Idaho Supreme Court affirmed the magistrate court. View "IDHW v. John Doe" on Justia Law

Moranda Morley lost one of her two jobs due to the economic impact of the COVID-19 pandemic in March 2020. Morley applied for and received state unemployment compensation benefits and federal pandemic unemployment assistance through the Idaho Department of Labor. However, it was later determined that Morley was ineligible for benefits because she was still employed full-time at her other job. Morley appealed that determination to the Appeals Bureau of the Idaho Department of Labor, which affirmed her ineligibility. Morley then appealed to the Idaho Industrial Commission (“the Commission”), which dismissed Morley’s initial appeal and later denied her request for reconsideration, finding both to be untimely. Morley then appealed to the Idaho Supreme Court, but her notice of appeal was timely only as to the denial of her request for reconsideration. Thereafter, the Supreme Court issued an order dismissing the appeal as to the issues that were determined to be untimely. What remains was a limited review of whether the Commission properly denied her request for reconsideration. Finding no reversible error, the Supreme Court affirmed the Commission’s denial of reconsideration. View "Morley v. IDOL" on Justia Law

Respondent D.L. Evans Bank obtained a default judgment against Appellant Henry Dean in 2010. Pursuant to Idaho Code section 10-1111(1), D.L. Evans obtained orders renewing the 2010 Judgment in 2015 and 2019. In 2020, D.L. Evans filed this lawsuit, alleging a single claim for action on the 2010 Judgment and seeking a new judgment for the amount that Dean owed on the 2010 Judgment plus accrued interest, attorney fees, and costs. The district court concluded that D.L. Evans properly renewed the 2010 Judgment in 2015 and 2019, and that each renewal restarted the applicable six-year statute of limitations on D.L. Evans’ claim for an action on a judgment. Dean argued the district court erred because the limitation period on D.L. Evans’ claim began to run when the judgment was first issued in 2010. Dean also argued the district court erred in denying his motion to dismiss for lack of personal jurisdiction and denying his Idaho Rule of Civil Procedure 60(b)(4) motion to set aside the 2010 Judgment as void. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "D.L. Evans Bank v. Dean" on Justia Law