Justia Idaho Supreme Court Opinion Summaries

In July 2015, R.N. went boating on Lake Coeur d’Alene with his friends, C.N. and B.L. All three boys were sixteen years old at the time. The boat was owned by C.N.’s father. C.N., B.L., and R.N. obtained about 12 beers from an unknown source and consumed them while boating. Later, the boys stopped at Shooters, a restaurant and bar near the south end of the lake. Respondent Tracy Lynn allegedly provided C.N., B.L., and R.N. with an alcoholic drink known as a “Shooter sinker” (also known as a “derailer”). The boys left the restaurant and drank the derailer on the lake. At some point during the trip, R.N. jumped or fell off the boat into the water and drowned. Appellant-plaintiffs Brandi Jones (R.N.'s mother), and Dasha Drahos (R.N.'s sister) filed a complaint against Lynn, alleging she recklessly and tortiously caused R.N.’s death by providing him with alcohol before he drowned in Lake Coeur d’Alene. Lynn moved for summary judgment, asking the district court to dismiss the case because the Plaintiffs failed to comply with the notice requirements under Idaho’s Dram Shop Act. The district court agreed and granted Lynn’s motion for summary judgment after concluding there was no uniform body of federal maritime dram shop law that would preempt Idaho’s Dram Shop Act. Thus, the Plaintiffs had to comply with the Dram Shop Act’s notice requirements. The Plaintiffs appealed to the Idaho Supreme Court. Finding that the district court correctly applied with the Idaho Dram Shop Act after concluding the Act did not conflict with any uniform federal common law, and that the district court did not err in finding Appellants' claims were barred because they did not comply with the Dram Shop Act, the Supreme Court affirmed the grant of summary judgment. View "Jones v. Lynn" on Justia Law

Peyton Gifford and Mollie Gabaldon (“Parents”) filed a complaint as individuals, guardians ad litem for their son, and putative class representatives, alleging that the West Ada Joint School District #2 (“West Ada”) illegally charged tuition fees for the second half-day of kindergarten instruction. The district court dismissed Parents’ complaint for lack of standing because Parents did not pay the allegedly illegal fees. On appeal, the Idaho Supreme Court held that although the district court properly concluded that Parents lacked standing to pursue a claim based solely on an economic injury, it failed to consider whether Parents had standing to assert a second, discrete injury: loss of educational opportunity for their son. Accordingly, the Court concluded Parents had standing to pursue their educational claims. View "Gifford v. West Ada Joint School District #2" on Justia Law

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