Justia Idaho Supreme Court Opinion Summaries

Wade Chapman (“Wade”) and his six siblings (“Siblings”) were the children of Wilford (“Bill”) Chapman. Bill had a life insurance policy for $7,000,000 that named the Chapman Family Multiple Power Liquidity Trust (“Trust”) as its owner. Wade, along with Siblings, were named as the Trust’s beneficiaries. Wade was also named a trustee. After Bill passed away, Wade learned that he was listed as the sole beneficiary of the life insurance policy and retained the entirety of the death benefit for himself. Siblings sued Wade for breach of fiduciary duty, among other causes of action, arguing that the policy was a Trust asset, and its proceeds should have been distributed equally among them. The district court agreed and granted summary judgment in favor of Siblings. It also awarded prejudgment interest against Wade under Idaho Code section 28-22-104 and attorney fees under Idaho Code section 15-8-201, a provision of the Trust and Estate Dispute Resolution Act (“TEDRA”). The Idaho Supreme Court affirmed the district court’s grant of summary judgment to Siblings, affirmed in part and reversed in part the award of prejudgment interest, and reversed the grant of attorney fees to Siblings under TEDRA. View "Vouk v. Chapman" on Justia Law

Deborah Dorr requested to reopen an unemployment appeal hearing that was to address Dorr’s appeal of the Idaho Department of Labor’s (“IDOL”) decision denying Dorr’s request to backdate her Pandemic Unemployment Assistance claim. After Dorr failed to appear at the hearing, IDOL dismissed her appeal and subsequently denied her request to reopen the hearing. Dorr appealed IDOL’s denial of her request to reopen, and the Idaho Industrial Commission (“the Commission”) affirmed. The Commission determined due process was satisfied and agreed with IDOL that Dorr’s own negligence was insufficient cause to reopen the hearing. Appealing pro se, Dorr petitioned the Idaho Supreme Court for relief. The Supreme Court concluded Dorr’s briefing did not meet the standard for an appeal under Idaho Appellate Rule 35(a)(6) and as such, her arguments were forfeited. The Commission’s decision upholding the Appeal Examiner’s denial of Dorr’s request to reopen her appeal hearing was affirmed. View "Dorr v. IDOL" on Justia Law

Mother Jane Doe appealed a magistrate court's judgment granting a petition to terminate her parental rights to her two minor children, Jane Doe I and John Doe I (the children). The magistrate court determined that Mother had neglected the children as defined in Idaho Code section 16-2002(3)(b), and that termination was in the best interests of the children. On appeal, Mother argued the definition of “neglect” provided in section 16-2002(3)(b) violated the Idaho and the United States Constitutions, and she argues that the magistrate court’s finding that termination was in the children’s best interests was not supported by substantial and competent evidence. After its review of the magistrate court record, the Idaho Supreme Court found the magistrate court found, by clear and convincing evidence that Mother’s parental rights should be terminated. That decision was supported by substantial and competent evidence in the record. It was therefore affirmed. View "IDHW v. Jane Doe" on Justia Law

This appeal arose from an Idaho district court decision affirming a declaratory ruling issued by Respondent Dave Jeppesen (the Director) in his capacity as Director of the Idaho Department of Health and Welfare (the Department). Appellant Grace at Twin Falls, LLC (Grace), a residential assisted living and memory care facility, partnered with a preferred pharmacy to offset costs associated with a software system that coordinated the tracking and delivery of residents’ prescription medications. Because residents who failed to choose the preferred pharmacy did not receive the offset, Grace sought to charge those residents an additional $10.00 each month to cover the difference. Grace brought a petition for declaratory ruling to the Department, asking the Director to declare that Idaho Code section 39-3316(12)(b) and IDAPA 16.03.22.550.12.b did not prohibit Grace from charging the $10.00 fee to those residents who did not choose the preferred pharmacy. The Director denied the petition, declaring that Grace would not “be permitted to assess a non-preferred-pharmacy fee as such fee violates residents’ right to choose their pharmacy or pharmacist . . . .” Grace sought judicial review before the district court, which affirmed the Director’s declaratory ruling. Grace then appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the district court. View "Grace at Twin Falls, LLC v. Jeppesen" on Justia Law

Kathryn Adkins appealed her conviction for felony concealment of evidence. Whether the crime of concealment of evidence was a felony depends on whether the investigation or trial to which the evidence related involved a misdemeanor offense or a felony offense. Because the felony status of the underlying offense was a “fact” that increases the maximum sentence that may be imposed, Adkins argued that in a jury trial this must be decided by the jury, not the judge. To this the Idaho Supreme Court disagreed and affirmed the judgment of conviction. The sentence imposed by the district court, however, exceeded the maximum permitted under Idaho Code section 18-2603. The sentence was vacated and remanded for entry of a corrected sentence. View "Idaho v. Adkins" on Justia Law

Darin Ogden was convicted on one count of sexual exploitation of a child and one count of sexual battery. Ogden argued the convictions should have been vacated because of several erroneous evidentiary rulings made by the district court, which deprived Ogden of his constitutional right to confront witnesses and present a defense. Alternatively, Ogden argued his sentences should have been vacated because the court considered unreliable information related to earlier conduct for which he had been acquitted. Ogden also requested that the presentence investigation report be redacted to omit those allegations. The Idaho Supreme Court determined that although the district court did not abuse its discretion by denying Ogden’s first Rule 412(b) motion seeking to introduce evidence of V.H.’s (the victim) sexual history with Michael Roller, it abused its discretion by denying Ogden’s second Rule 412(b) motion seeking to introduce evidence of V.H.’s sexual history with Ty Birchfield. The Court affirmed Ogden's conviction for sexual battery, but vacated his conviction for sexual exploitation of a child, and the case was remanded for a new trial. View "Idaho v. Ogden" on Justia Law

Nathaniel Sheehan lost his job during the COVID-19 pandemic. He applied for and began receiving unemployment benefits. This appeal arose out of the Idaho Department of Labor’s (“IDOL”) later determination that Sheehan was: (1) ineligible for unemployment benefits; and (2) required to repay the benefits he had already received. Sheehan represented himself throughout this case. He appealed these decisions to the Idaho Industrial Commission (“Commission”), claiming he had received misleading instructions concerning notice from IDOL. The Commission dismissed his appeal and later denied his motion for reconsideration. Sheehan then appealed to the Idaho Supreme Court. "While Sheehan presents a poignant story rife with compelling circumstances, we are bound to follow the rules and law of jurisdictional authority." The Court affirmed the Idaho Industrial Commission. View "Sheehan v. Sun Valley Company" on Justia Law

Police apprehended defendant Clarence Lancaster for questioning relating to several ATM thefts in Boise, Idaho. He was later charged and ultimately entered conditional guilty pleas to two felonies: burglary and grand theft. This appeal arose from the denial of his motion to suppress. Lancaster argued that his confession and other evidence should have been suppressed because the arresting officers violated Idaho Code section 19-608 by failing to tell Lancaster the basis of his arrest. He maintains that this statutory violation rendered his arrest an unreasonable seizure under Article 1, Section 17 of the Idaho Constitution. He also argues that the district judge abused its discretion at sentencing by failing to strike an attachment to the Presentence Investigation Report. Finding no reversible error, the Idaho Supreme Court affirmed Lancaster's conviction. View "Idaho v. Lancaster" on Justia Law

Robert Fulfer, while making a delivery, exited his truck and stepped down into a nine-inch-deep pothole, resulting in serious personal injuries. He was working for Ruan Logistics Corporation (“RLC”), which was contracted as a transportation and cargo-hauling provider by Sorrento Lactalis, Inc. (“SLI”). Fulfer filed a personal injury action against SLI seeking damages based on premises liability and negligence. SLI moved to dismiss pursuant to Idaho Rules of Civil Procedure 12(b)(6) and 12(c), arguing that it was immune from a tort action because it was a statutory employer of Fulfer, meaning that Idaho’s Workers’ Compensation laws provided Fulfer’s exclusive remedy. In response, Fulfer argued that an exception to the exclusive remedy rule applied. The district court determined Fulfer’s complaint failed to state a claim upon which relief could be granted because he: (1) failed to comply with Idaho’s notice pleading requirements by not addressing statutory employer immunity; and (2) failed to allege specific facts required for establishing an exception to the exclusive remedy rule based on the Idaho Supreme Court’s decision in Gomez v. Crookham Co., 457 P.3d 901 (2020), which was controlling at the time. Accordingly, the district court dismissed Fulfer’s complaint without prejudice and later denied Fulfer’s motion to reconsider and for leave to file a second amended complaint. Fulfer appealed. The Supreme Court determined the district court erred in dismissing Fulfer’s first amended complaint pursuant to Idaho Rule of Civil Procedure 12(b)(6) because it satisfied Idaho’s pleading requirements. Further, the Supreme Court concluded the exception to the exclusive remedy rule in I.C. 72-209(3) applied to direct and statutory employers. The case was remanded for further proceedings. View "Fulfer v. Sorrento Lactalis, Inc." on Justia Law

Neurosurgeon Donald Blaskiewicz, M.D. went to work for the Spine Institute of Idaho (the “Spine Institute” or the “Institute”) in 2018. The Spine Institute entered into a Professional Services Agreement (the PSA) with Blaskiewicz containing a non-compete clause, contractually proscribing Blaskiewicz from practicing medicine within fifty miles of the Spine Institute’s office (with an explicit exception for Caldwell) for a period of eighteen months, should his employment with the Spine Institute be terminated for any reason. Pursuant to the PSA, Blaskiewicz had two ways to avoid the non-compete clause: he could either get permission from the Spine Institute to practice medicine within the proscribed area, or he could pay the Spine Institute $350,000 in “liquidated damages.” The PSA also required any disputes to be resolved by arbitration. Less than a year and a half after hiring Blaskiewicz, the Spine Institute terminated his employment. Blaskiewicz filed suit in district court, seeking a declaratory judgment that the non-compete clause was unenforceable. The district court concluded that the non-compete clause was against public policy and void as a matter of law, and granted summary judgment in favor of Blaskiewicz. The Idaho Supreme Court reversed, finding the district court did not cite or analyze the statutes governing non-compete agreements in Idaho. The Court concluded there were genuine issues of material fact such that summary judgment was inappropriate as to whether the non-compete provision was void as a matter of public policy or otherwise enforceable. View "Blaskiewicz v. Spine Institute of Idaho" on Justia Law