Justia Idaho Supreme Court Opinion Summaries

The issue this appeal presented for the Idaho Supreme Court's review centered on a farm lease between Walker Land & Cattle, LLC, (“Walker”) and Sometimes a Great Notion Land and Cattle Company (“SAGN”). The lease agreement required Walker, as tenant, to obtain insurance coverage on “improvements” to the Ririe Farm, which SAGN, as landlord, contended included the property’s five irrigation pivots. The district court granted summary judgment to SAGN, concluding that under the lease agreement irrigation pivots were improvements and Walker defaulted on the lease by failing to provide insurance on the pivots. On appeal, Walker raised several related issues, primarily contending that genuine issues of material fact barred granting summary judgment. Finding no reversible error, however, the Idaho Supreme Court affirmed the award of summary judgment by the district court. View "Stanger v. Walker Land & Cattle" on Justia Law

Brent Meyer appealed pro se a district court’s judgment granting Adam Walker’s breach of contract claim against him. Walker hired Meyer to assist him with the demolition and remodel of a home he had purchased in Soda Springs, Idaho. Walker alleged that in June 2018, the parties entered into an agreement in which Walker agreed to pay Meyer $18,000 in exchange for Meyer’s labor on the home. This contract was subsequently modified by the parties as Meyer performed work on other areas of the home not covered by the contract and Walker paid Meyer more money than provided in the original contract – roughly $60,000. On October 16, 2018, Walker fired Meyer from the job, alleging the labor was not up to industry standards and did not add value to the home. Walker hired another contractor to fix or redo the work completed by Meyer and his subcontractors. Meyer argued the district court erred in concluding he was not a “construction professional” as defined by Idaho’s Notice and Opportunity to Repair Act (“NORA”), Idaho Code sections 6-2501–04, and claimed the case should have been dismissed because Walker failed to comply with the notice requirement of NORA. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Walker v. Meyer" on Justia Law

Eric Christiansen filed a nine-count complaint against respondents, Michael Moser and Potlatch #1 Financial Credit Union (“P1FCU”), following a decision by the Lewiston Roundup Association (“LRA”) to discontinue contracting with Christiansen to produce motorsport events at the LRA’s facility. The complaint alleged that Moser, a P1FCU employee and LRA member, improperly accessed information from Christiansen’s P1FCU account and shared it with the LRA so that it could recreate his business model and produce motorsport events without him. The district court granted summary judgment in the Respondents’ favor on each of Christiansen’s claims. Christiansen appealed, arguing that the district court erred in granting summary judgment because it failed to rule on Christiansen’s motion to compel discovery, failed to grant Christiansen more time to complete discovery, and failed to conclude that genuine issues of material fact precluded dismissal of four of Christiansen’s claims. The Idaho Supreme Court concluded after review that the district court abused its discretion by failing to decide Christiansen’s motion to compel discovery before considering the Respondents’ motions for summary judgment. Accordingly, judgment was reversed and the matter remanded for further proceedings. View "Christiansen v. Potlatch #1 FCU" on Justia Law

Defendant-appellant Danielle Guerra appealed a district court’s decision affirming a judgment of conviction for driving under the influence of drugs (“DUI”). Guerra contended the magistrate court erred when it denied her motion to set aside the jury verdict under Idaho Criminal Rule 29 or, in the alternative, grant a new trial under Idaho Criminal Rule 34. Further, Guerra argued the magistrate court erred when making a number of evidentiary rulings. The district court, acting in its appellate capacity, affirmed the magistrate court’s rulings and judgment of conviction. The Idaho Supreme Court found the district court erred when it upheld the magistrate court’s ruling permitting the arresting officer to testify about the motor vehicle warning on Guerra’s medication bottles. The pill bottles found in Guerra’s car were not offered or admitted into evidence. The officer testified to three warnings or “signs” on the medication bottles. The Court found that the inclusion of a warning on a medication bottle to “take due caution when operating a motor vehicle or heavy equipment” was more than just an admonishment: "The warning impliedly asserts that the medication in the bottle may impair the user’s ability to drive a car or use heavy equipment. Because this warning constitutes an assertion of fact that is capable of being proven true (i.e., the medication may impair the ability to drive), Officer DeLeon’s testimony concerning that warning constituted an assertion of fact and is subject to the hearsay rules." The Supreme Court concluded the State failed to carry its burden of demonstrating a proper non-hearsay purpose for the motor vehicle warning evidence. "The harmfulness of allowing Officer DeLeon’s testimony about the warning to come in for the truth of the matter asserted is evidenced in the statements of multiple jurors during voir dire in response to the prosecutor’s questions related to taking prescription medications while driving." Judgment was affirmed in part, reversed in part, and remanded the case to the district court with instructions to vacate the judgment of conviction and remand the case to the magistrate court for further proceedings. View "Idaho v. Guerra" on Justia Law

A grand jury indicted defendant-appellant Jordan Spencer for three counts of felony trafficking in heroin, one count of felony possession of methamphetamine, one count of felony possession of bath salts with intent to deliver, and one count of misdemeanor possession of drug paraphernalia. After a jury trial, Spencer was found guilty on all counts. Spencer appealed two of the six counts of which he was convicted, arguing there was insufficient evidence to sustain his conviction on one count of trafficking in heroin, and that the district court erred when it admitted the out-of-court statements of the State’s confidential informant because those statements violated his Sixth Amendment right to confront witnesses. The Idaho Supreme Court vacated Spencer's conviction on Count I, finding it was not supported by substantial evidence on which the jury could conclude the prosecution proved all essential elements beyond a reasonable doubt. The Court affirmed Spencer’s conviction of trafficking heroin as charged in Count II. View "Idaho v. Spencer" on Justia Law

Mary Eich appealed a district court judgment ordering her to vacate property owned by the trustees of the Wilbur Eich and Henrietta Eich Revocable Trust (the “Trust”). In 2015, Mary filed an action seeking to quiet title to 2.5 acres of an 80-acre tract of real property owned by her father, who held title to the property as trustee of his Trust. Mary alleged that her parents had gifted her the 2.5 acres with the intent that she build a home and reside there for the rest of her life. On cross-motions for summary judgment, the district court ruled that there was no valid transfer between Mary and her parents, but permitted Mary to pursue an equitable claim of promissory estoppel. After a bench trial, the district court ruled in favor of Mary and that she had a year to obtain Teton County’s approval to partition the 2.5 acres from the remaining Trust property. If she could not do so within the time prescribed, the Trust would have to pay Mary $107,400 for the value of improvements she had made on the land plus her reasonable relocation costs, and Mary would have to vacate the property. Mary worked for several years to separate the 2.5 acres from the remaining Trust property to no avail. In August 2019, the Trust moved to compel enforcement of the district court’s alternative remedy and for entry of final judgment. In January 2020, a newly assigned district court judge granted the Trust’s motion and entered a declaratory judgment ordering the Trust to pay Mary $107,400, plus reasonable relocation expenses, and for Mary to vacate the property. Mary appealed, arguing that the newly assigned district court judge abused his discretion by deviating from the original judge’s equitable remedy. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s decision ordering Mary to vacate the property and for the Trustees to pay Mary $107,400. View "Eich v. Revocable Trust" on Justia Law

Nathan Smith appealed a district court order granting summary judgment in favor of his former employer, Kount, Inc., and denying his cross motion for summary judgment on the grounds that the compensation agreement he signed unambiguously required Smith to remain employed until a specified date to earn the bonus compensation, and Smith resigned before that date. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgment. View "Smith v. Kount Inc." on Justia Law

Defendant-appellant was convicted by jury of domestic battery, attempted strangulation, and aggravated assault. He appealed to the Idaho Court of Appeals, which affirmed his convictions. Reyes petitioned for review by the Idaho Supreme Court, which was granted. On appeal, Reyes requested his convictions be vacated, arguing: (1) several evidentiary issues, including the admission of irrelevant and prejudicial evidence, rendered his trial unfair; (2) the district court abused its discretion when it found that the victim was unavailable to testify at trial under Idaho Rule of Evidence 804(a)(5) and allowed her preliminary hearing testimony to be read into the record; (3) the prosecutor’s closing argument impermissibly implied that the victim did not testify because she feared Reyes; and (4) these errors, when taken together, deprived him of his right to due process and a fair trial. After review, the Supreme Court found the district court erred when it determined the victim was unavailable to testify at trial, and allowed her preliminary hearing testimony to be read into the record. Further, the Court concurred the prosecutor's comment that the victim was "probably scared" to testify at trial was improper. In the aggregate, the Court concluded these errors rendered the trial unfair. Accordingly, Reyes' conviction was reversed and the case remanded for a new trial. View "Idaho v. Reyes" on Justia Law

Pheasant Run VI, LLC, Robert Drinkard, and Nancy Drinkard (collectively, “the Drinkards”) appealed a district court’s order renewing a judgment for Alpha Mortgage Fund II (“Alpha”) for $1,842,509.59. Pheasant Run was a company wholly owned by the Drinkards. Pheasant Run obtained a loan from Alpha. Robert and Nancy acted as guarantors for the loan. Pheasant Run ultimately defaulted on the loan and Alpha foreclosed on property the Drinkards used as collateral for the loan. Although Alpha recouped the property, a significant deficiency existed between the amount Pheasant Run owed and the property’s fair market value. Alpha thereafter sued Robert and Nancy for the amount of the deficiency. The Original Judgment was entered in 2010, and renewed in 2015. Alpha did not record the 2015 judgment. In 2020, Alpha moved the district court to again renew the Original Judgment pursuant to Idaho Code section 10-1111. The Drinkards objected, leading to this appeal. The Idaho Supreme Court found the district court did i not err when it granted Alpha’s motion to renew the Original Judgment, even though the 2015 judgment was not recorded: the judgment remained unsatisfied, and Alpha’s motion was filed within five years of the most recently renewed 2015 judgment. Accordingly, judgment was affirmed. View "Alpha Mortgage Fund v. Drinkard" on Justia Law

After Anne Herr petitioned for divorce from John Herr, John asserted that two investment accounts opened during the marriage were his separate property. The magistrate court disagreed, finding that separate and community property had been commingled in the accounts, triggering the presumption that all assets in the accounts were community property. Because John did not present an argument to rebut this presumption, the magistrate court ordered the accounts divided equally between the parties. The district court affirmed the magistrate court’s decision on intermediate appeal. John argued to the Vermont Supreme Court that the district court’s decision should be reversed because evidence sufficient to trace his separate property was admitted at trial. The Supreme Court affirmed because John was obligated to present an argument at trial to rebut the presumption that the assets were community property, not merely to provide evidence from which an argument could have been made. View "Herr v. Herr" on Justia Law