Justia Idaho Supreme Court Opinion Summaries

Michael Summerfield brought a medical malpractice suit against St. Luke’s McCall, Ltd. (St. Luke’s), following the surgical removal of his gallbladder. During surgery, the attending surgeon, employed by St. Luke’s, unknowingly spilled and left a gallstone in Summerfield’s peritoneal cavity. When it was later determined that the gallstone was not in the removed gallbladder, the surgeon failed to inform Summerfield of the incident, warn him of any potential complications, or properly document the incident in his medical records. St. Luke’s moved for summary judgment, challenging the admissibility of the opinions offered by Summerfield’s expert witness. St. Luke’s claimed Summerfield’s expert, as an emergency medicine and wound care physician, was unable to establish the requisite knowledge of the applicable standards of care and breaches thereof by St. Luke’s and the attending surgeon. The district court initially agreed with St. Luke’s and granted its motion for summary judgment. Summerfield then filed a motion for reconsideration and attached a supplemental declaration from his expert witness that established the requisite foundation. The district court considered this additional evidence and granted Summerfield’s motion. However, the district court later reversed itself, relying on Ciccarello v. Davies, 456 P.3d 519 (2019), which held that a trial court was afforded discretion in determining whether to consider new declarations accompanying a motion for reconsideration if they were untimely for consideration at summary judgment. Summerfield appealed to the Idaho Supreme Court, contending the district court’s sua sponte reversal of itself was in error and contrary to previous decisions issued by the Supreme Court. The Supreme Court affirmed the district court in part, and reversed in part. The Court affirmed district court’s decision to grant St. Luke’s motion for summary judgment on Summerfield’s claim that Dr. Ocmand breached the standard of care for not noticing the spilled gallstone and not retrieving it because Dr. Madsen did not establish a sufficient foundation to testify as to the appropriate standard of care. The Court also affirmed the district court’s sua sponte decision to reverse itself and not consider Dr. Madsen’s third affidavit and reinstate judgment for St. Luke’s on this same ground. However, the Supreme Court reversed the district court’s decision to grant St. Luke’s motion for summary judgment as to Summerfield’s claims that Dr. Ocmand breached the standard of care by failing to inform Summerfield of the spilled gallstone and by failing to note the spilled gallstone in Summerfield’s medical chart because Dr. Madsen laid a sufficient foundation to testify as to these matters. View "Summerfield v. St. Luke's McCall" on Justia Law

Two petitions reached the Idaho Supreme Court, both seeking to declare two statutes unconstitutional and to issue extraordinary writs: a writ of mandamus and a writ of prohibition. First, Michael Gilmore sought a declaration that Idaho Code section 34-1805(2), as amended by SB 1110, violated the people’s constitutional initiative and referendum rights. SB 1110 requires that, for an initiative or referendum to appear on the ballot, organizers must obtain a threshold number of signatures from “each of the thirty-five (35) legislative districts” in the state. Gilmore argued this violated the equal protection clause of the Idaho Constitution and unconstitutionally divides the people’s legislative power. Gilmore also petitioned for a writ of mandamus ordering the Idaho Secretary of State “not to implement” the statute as amended. In the second petition, Reclaim Idaho (“Reclaim”) and the Committee to Protect and Preserve the Idaho Constitution, Inc. (“the Committee”), sought a declaration that the new signature threshold mandated by SB 1110, requiring signatures from every legislative district, was unconstitutional. They also challenged the constitutionality of another statute, Idaho Code section 34-1813(2)(a), amended in 2020, stating that an initiative may not become effective earlier than July 1 of the year following the vote in which it was passed. Reclaim and the Committee contended both amended statutes nullify the people’s fundamental constitutional right to legislate directly. They also sought a writ of prohibition to prevent the Secretary of State from enforcing these statutory provisions. After review, the Supreme Court: (1) dismissed Gilmore's petition because he lacked standing; (2) granted Reclaim and the Committee's petition in part by declaring that section 34-1805(2) violated Article III, Section 1 of the Idaho Constitution, and the SOS and Legislature failed to present a compelling state interest for limiting that right. Furthermore, the Court declared section 34-1813(2)(a), violated Article III, Section 1 of the Idaho Constitution because it infringed on the people’s reserved power to enact legislation independent of the legislature. Accordingly, the Court granted Reclaim and the Committee’s petition for a writ of prohibition preventing the Secretary of State from enforcing this provision. View "Reclaim Idaho/Gilmore v. Denney" on Justia Law

Jane Doe (Mother) and John Doe (Father) were a married couple and the biological parents of E.W. (Child). Mother and Father were both incarcerated from 2015 until 2020. Mother gave birth to Child while incarcerated and asked her friend Jane Doe I (Guardian Mother) and her husband John Doe I (Guardian Father) to care for Child until Mother was released. Guardians raised Child since her birth and presently act as legal guardians for her. Guardians filed a petition seeking to terminate the parental rights of Mother and Father and to adopt Child. A termination trial was held by the magistrate court, after which the magistrate court terminated the parental rights of both Mother and Father. The magistrate court found that Mother had neglected Child and was unable to discharge her parental responsibilities. The magistrate court further found that Father had abandoned and neglected Child and was also unable to discharge his parental responsibilities. The magistrate court then granted Guardian’s petition for adoption. The Idaho Supreme Court reversed, finding the Guardians’ Verified Petition failed to allege any facts supporting termination of Mother’s and Father’s parental rights, thereby violating the parents' due process right to notice regarding the bases upon which termination was sought. The case was remanded to the magistrate court with instructions to dismiss the petition without prejudice. View "Doe I v. Doe" on Justia Law

While the issue on appeal in this case centered on a conviction for violating a protection order, the principal focus was on the statutes and guidelines governing domestic violence courts in Idaho. Moawia Ahmed was charged with violating a protection order under Idaho Code section 39- 6312. At his arraignment, Ahmed’s case was transferred to the Domestic Violence Court (“DVC”). In his pretrial motions, Ahmed moved the magistrate court to dismiss the charge on constitutional grounds. The magistrate court denied Ahmed’s motion, the case proceeded to trial, and, ultimately, a jury found Ahmed guilty. Ahmed appealed his conviction to the district court. Ahmed maintained the magistrate court erred in denying his motion to dismiss. Ahmed also argued the magistrate court erred by: (1) admitting hearsay evidence; (2) failing to properly instruct the jury; and (3) requiring Ahmed to undergo a domestic violence assessment. The district court, in its intermediate appellate capacity, affirmed. Ahmed appealed the district court’s decision. Finding no reversible error, the Idaho Supreme Court affirmed the district court's decision. View "Idaho v. Ahmed" on Justia Law

SRM Arms, Inc. (“SRM”) filed suit against GSA Direct, LLC, (“GSA”) and FFL Design, LLC, (“FFL”) (collectively, the “Entity Defendants”), and Anthony Turlington, David Lehman, and Ryan Fitzgerald (collectively the “Individual Defendants”), alleging breach of contract, breach of the covenant of good faith and fair dealing, fraud, aiding and abetting in the commission of fraud, and unjust enrichment. After the jury awarded verdicts for SRM, all Defendants asked the court to modify the judgments or grant a new trial. The district court entered a remittitur for the claims against the Entity Defendants because it found the amount the jury awarded was excessive and not supported by sufficient evidence at trial. On appeal, SRM argued the district court erred in reducing the awarded damages. In their cross-appeal, the Entity Defendants argued the jury improperly found fraud and improperly found FFL liable for GSA’s debts. The Entity Defendants also argued the damages should have been reduced further. Additionally, the district court granted the Individual Defendants’ motion for a new trial on liability and damages because it found the jury instructions were inadequate to distinguish between direct liability and alter-ego liability. On appeal, SRM argues the jury correctly determined direct liability and associated damages. The Idaho Supreme Court affirmed in part, reversed in part and remanded in part. Regarding the Entity Defendants, the Supreme Court reversed and remanded for reconsideration of the remittitur, or in the alternative, a new trial, in light of the Supreme Court's conclusion that a possible alternate basis for the jury’s verdict could exist. The Supreme Court affirmed the district court’s decision upholding the verdict of fraud against GSA and FFL. The district court’s decision to uphold the verdict that FFL is liable to SRM was also affirmed; the Court found the statute of frauds was satisfied and not, as the jury decided, because an exception to the statute of frauds applied. The Court reversed the district court’s decision to uphold the finding of unjust enrichment and remanded for further consideration of whether there was substantial and competent evidence in the record supporting the jury’s award of damages against FFL for both breach of an implied-in-fact contract and unjust enrichment. Regarding the Individual Defendants, the Supreme Court affirmed the district court’s granting of a new trial on liability against the Individual Defendants. The district court’s award of a new trial on damages against the Individual Defendants was also affirmed. View "SRM Arms, Inc. v. GSA Direct, LLC" on Justia Law

Appellants Michael Allen, Camp Bench Holdings, LLC, Camp River Holding, LLC, and Campbell Farms, Inc., (collectively, “Allen”) appealed two different district court decisions: one in which attorney fees were not awarded to Allen, and one in which attorney fees were awarded against Allen. The Idaho Supreme Court reversed the district court’s determination that there was no prevailing party between Allen and Neil Campbell. Although the district court dismissed the claim against Campbell Contracting, Allen prevailed on the material terms of the agreement against Neil Campbell. On remand, the district court was instructed to award reasonable attorney fees to Allen based on the materials the parties previously filed. The Supreme Court affirmed the district court’s determination that Campbell Contracting was the prevailing party, but vacated the amount of the attorney fee and cost award and remanded the case so that the district court could respond to Allen’s objections and explain how applying the factors in Idaho Rule of Civil Procedure 54(e)(3) logically lead to the specific amount of fees and costs awarded in this case. Further, as the prevailing party on appeal, the Supreme Court awarded Allen attorney fees and costs associated with his appeal against Neil Campbell. View "Allen v. Campbell" on Justia Law

Patricia Amstutz appealed her conviction for driving under the influence of alcohol (“DUI”). Amstutz argued the district court erred in denying her motion to suppress because she was arrested, without a warrant, for a completed misdemeanor offense that occurred outside of the officer’s presence. She claimed that her rights under the Idaho Constitution based on the Idaho Supreme Court’s decision in Idaho v. Clarke, 446 P.3d 451 (2019) were violated. After review, the Supreme Court reversed the district court’s order denying Amstutz’s motion to suppress, vacated her judgment of conviction, and remanded the case for further proceedings. View "Idaho v. Amstutz" on Justia Law

In 2015, Ralph Isom filed for bankruptcy. Ultimately, a bankruptcy trustee for the estate settled with Isom’s primary creditor, Farms, LLC (“Farms”). As part of the settlement, the bankruptcy trustee conveyed a ten-acre parcel from the bankruptcy estate to Farms. Isom was living on the ten-acre parcel at the time. When Isom refused to vacate the ten-acre parcel, Farms initiated this forcible detainer action. The magistrate court entered judgment for Farms and ordered Isom to vacate the ten-acre parcel. Isom appealed to the district court, but also vacated the property as the magistrate court had ordered. Because Isom had vacated, and thus no longer occupied or owned the ten-acre parcel, the district court held that Isom’s appeal was moot. Further, the district court rejected the merits of Isom’s appeal. Isom appealed the district court’s decision on the merits, but failed to appeal the district court’s holding that his appeal was moot. The Idaho Supreme Court found that because Isom failed to raise, let alone argue against, the district court’s decision as it related to mootness, the issue was considered waived."Isom’s waiver is dispositive. As a result, we will not reach the merits of his appeal as it relates to the sufficiency of proof regarding the forcible detainer action." Judgment was thus affirmed. View "Farms, LLC v. Isom" on Justia Law

The United States Court of Appeals for the Ninth Circuit certified a question of law to the Idaho Supreme Court. The federal court asked whether an Idaho state court order reducing a defendant’s judgment of conviction for felony burglary to a judgment of conviction for misdemeanor petit theft under Idaho Code 19-2604(2) changed the operative conviction for the purposes of Idaho Code 18-310, which prohibited the restoration of firearm rights to those citizens convicted of specific felony offenses. In 2019, defendant Antonio Gutierrez was indicted in the District of Montana on four charges: (1) conspiracy to commit robbery affecting commerce; (2) robbery affecting commerce; (3) possession of a firearm in furtherance of a crime of violence; and (4) felon in possession of a firearm. These charges resulted from a robbery of Dotty’s Casino in Billings, Montana, that involved a firearm. The felon in possession of a firearm charge stemmed from Gutierrez’s previous convictions under Idaho state law for burglary. In 2000, Gutierrez pleaded guilty to two counts of felony burglary. He was sentenced to the Idaho State Correctional Institution for a fixed term of two years and a subsequent indeterminate term of three years. In 2003, acting pursuant to Idaho Code section 19-2604(2), an Idaho district court ordered Gutierrez’s burglary convictions “REDUCED to Misdemeanor Petit Theft.” The order specified that Gutierrez was “not to be considered a convicted felon because he has successfully complied with the terms and conditions of probation and paid all restitution/reimbursement and fines in full.” Based on the plain language of Idaho Code section 19-2604 the Idaho Supreme Court's answer to the Ninth Circuit’s question was no. "A grant of leniency under Idaho Code section 19-2604(2) does not remove a defendant originally convicted of an enumerated felony from the reach of section 18-310(2) and (3)." View "United States v. Gutierrez" on Justia Law

The issue presented for review by the Idaho Supreme Court stemmed from an “unfortunate kitchen accident.” Mary Clare Griffin purchased a bottle of Italian wine, which broke in her hands as she attempted to open it, causing substantial injuries. Griffin and her son, a minor who witnessed the event, brought a product liability suit against Zignago Vetro S.P.A., the Italian manufacturer of the wine bottle; Marchesi Antinori SRL (Antinori), the Italian wine company that purchased the bottle from Zignago, filled it with wine, and exported it to the United States; Chateau Ste. Michelle Wine Estates, Ltd. (Ste. Michelle), the United States importer; S & C Importers and Distributors, Inc. (S&C), the Idaho distributor who purchased the bottle from Ste. Michelle; and, Albertson’s LLC (Albertson’s), the retailer that sold the bottle to Griffin. Zignago successfully moved the district court to dismiss Griffin’s complaint based on a lack of personal jurisdiction. Griffin appealed the district court’s decision, asking the Supreme Court to apply the personal jurisdiction framework established by the United States Supreme Court in World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980). Zignago claimed the district court did not err by applying the stricter test that the United States Supreme Court offered in Asahi Metal Indus. Co. v. Superior Court of California, Solano Cnty., 480 U.S. 102 (1987) (plurality). Griffin also appealed several adverse discovery rulings. The Supreme Court held that the correct test when determining personal jurisdictional issues remains the “stream of commerce” test adopted by the United States Supreme Court in World-Wide Volkswagen. Applying that test to the case here, the Court reversed the district court’s decision to grant Zignago’s motion to dismiss for lack of personal jurisdiction and remand the case for further proceedings. Furthermore, the Court affirmed the district court’s decision granting Antinori’s and Ste. Michelle’s motions for summary judgment and hold that it did not abuse its discretion in failing to grant Griffin’s motion to compel discovery against Antinori and Ste. Michelle. View "Griffin v. Ste. Michelle Wine Estates LTD." on Justia Law