Justia Idaho Supreme Court Opinion Summaries

by
Brett Woolley appealed an Idaho Industrial Commission (“Commission”) decision that found him ineligible for unemployment benefits. The Commission determined that Woolley was ineligible for benefits because he was a corporate officer whose claim for benefits was based on wages from a corporation in which he had an ownership interest. The Commission also determined Woolley willfully made a false statement by saying he had not received wages or performed services as a corporate officer. After review, the Idaho Supreme Court affirmed the Commission’s determination that Woolley was ineligible for benefits due to his status as a corporate officer because it was supported by substantial and competent evidence. However, the Court found Woolley did not willfully misrepresent his status as a corporate officer, "The statute makes no mention of a claimant’s performance of services as a corporate officer. To compound the confusion, IDOL provides no information in the unemployment handbook or on its website to explain why it is necessary for claimants to report their corporate officer status when filing a claim for benefits. To serve as the basis for a willful failure to report a material fact, the question to be answered by a claimant must be accurately grounded in the legal requirements of the statute." View "Woolley v. Idaho Dept. of Labor" on Justia Law

by
Nine-year-old girl Shaeley Noel was seriously injured while playing on playground equipment owned by the City of Rigby (City) and located in the City’s South Park. Shaeley and her parents (collectively the Noels) filed suit in district court alleging willful and wanton conduct by the City in the construction and/or maintenance of its playground equipment. The City claimed the park was closed for winter at the time Shaeley was injured. A jury rendered a verdict in favor of the City when it found that the City did not owe a duty to Shaeley. The Noels filed a motion for a new trial, which the district court granted. The City appealed the district court’s decision to grant a new trial, as well as the district court’s decisions to deny the City’s motion for a directed verdict and the City’s motion to exclude the Noels’ expert witness. The Noels cross-appealed, arguing the trial court erred by: (1) rejecting of evidence of Shaeley’s unadjusted medical bills; (2) preventing the Noels’ expert witness from testifying regarding the City’s purported willful and wanton conduct; (3) allowing a jury instruction regarding comparative negligence; and (4) admitting of evidence regarding the seasonal closure of the park. The Idaho Supreme Court affirmed the district court decisions with regard to: (1) the City’s motion for a directed verdict; (2) the Noels’ motion for a new trial; (3) the Noels’ expert testifying; (4) the jury instruction; and (5) admission of evidence of the park closure. Additionally, the Court reversed the district court with respect to: (1) the Noels introducing Shaeley’s unadjusted medical bills; and (2) preclusion of the Noels’ expert from testifying that the City engaged in willful and wanton conduct. As a result, the matter was remanded for a new trial. View "Noel v. City of Rigby" on Justia Law

by
The issue this appeal presented for the Idaho Supreme Court's review centered on whether Sky Down Skydiving, LLC, improperly designated its tandem skydiving instructors and parachute packers as independent contractors, rather than as employees, thereby eliminating the need for worker’s compensation insurance. After notifying the company that it was in violation of Idaho Code section 72-301, the Industrial Commission filed a civil law suit against Sky Down for penalties and injunctive relief. Following a bench trial, the magistrate court concluded that the instructors and parachute packers were independent contractors. The magistrate court then dismissed the Commission’s complaint with prejudice. After the case was dismissed, a witness contacted the Industrial Commission’s counsel to recant his earlier testimony. The Commission then filed a motion for a new trial, which was denied by the magistrate court. The Commission filed an intermediate appeal with the district court, which affirmed the magistrate court’s decision. The Commission then timely appealed to the Idaho Supreme Court, which reversed and remanded because both lower courts erred by failing to apply the proper test, and the district court erred in concluding there was substantial and competent evidence to support the magistrate court’s findings. View "Idaho ex rel. Industrial Commission v. Sky Down Sky Diving" on Justia Law

by
This case involved a dispute over the return of earnest money following termination of an agreement to purchase a storage facility between River Range, LLC, (River Range), the buyer, and Citadel Storage, LLC, (Citadel), the seller. Following River Range’s termination of the agreement, River Range demanded the return of its earnest money. Citadel refused, arguing that the deadline for the return of the earnest money had passed. The district court granted summary judgment in favor of Citadel. River Range appealed, arguing that the district court erred in holding that: (1) the agreement was unambiguous and an addendum eliminated River Range’s right to have the earnest money refunded after a certain date; (2) River Range waived its right to terminate the agreement when it did not exercise the right to terminate the agreement by the due diligence deadline; and (3) Citadel did not breach the duty of good faith and fair dealing. Finding no reversible error, the Idaho Supreme Court affirmed. View "River Range v. Citadel Storage" on Justia Law

by
Jane Doe (Mother) executed a voluntary consent to terminate her parental rights to Son. Mother shortly thereafter filed a motion to rescind her consent. The magistrate court denied the motion. Termination proceedings were then conducted without Mother, her counsel, or a guardian ad litem for Mother being present. Following the hearing, Mother’s parental rights were terminated. Mother appealed the termination of her parental rights. The Idaho Supreme Court determined the magistrate court erred in failing to appoint a replacement guardian ad litem for Mother. "At the time Mother executed the waiver, there was still an outstanding question, recognized but not addressed by the magistrate court, as to Mother’s need for a guardian ad litem. This outstanding question hinged upon the results of Mother’s psychological evaluations, but was never answered despite the availability of these results. It is clear that Mother suffered from significant mental illness. ...However, having identified the earlier need for a guardian ad litem and the continuing need to have a guardian ad litem absent receiving evidence to the contrary, a replacement guardian was never appointed. There is substantial and competent evidence strongly indicating Mother’s ongoing need for a guardian ad litem." The termination was vacated and the matter remanded to the magistrate court for further proceedings. View "DHW v. Jane Doe" on Justia Law

by
John Doe I (Child) was removed from the care of his paternal grandmother (Grandmother) and his father, John Doe (Father) after a referral was made to the Idaho Department of Health and Welfare (the Department). The Department ultimately petitioned to terminate Father’s parental rights. Father failed to attend scheduled hearings, ceased communicating with the Department, and only sporadically contacted his attorney. Father’s counsel sought several continuances, but eventually the termination trial proceeded. Following trial, the magistrate court found that Father had failed to comply with the case plan and was unable to discharge his parental responsibilities. The magistrate court found it was in Child’s best interests to terminate Father’s parental rights. Father’s principal argument on appeal was that the magistrate court abused its discretion in allowing the Department to amend its petition to terminate by adding a separate, alternate basis for termination, and by granting only a two-week continuance to Father to respond to this alternate theory. Finding no abuse of discretion, the Idaho Supreme Court affirmed. View "DHW v. John Doe" on Justia Law

by
Riley Lodge appealed a no contact order entered against him as a result of his being convicted of two counts of sexual battery of a minor child sixteen or seventeen years of age. After Lodge pleaded guilty to these two counts, the district court entered a no contact order which prohibited Lodge from having contact with the named victims and “[a]ll minor children.” On appeal, Lodge contended the district court abused its discretion by failing to provide an exception to the no contact order for two minor children who were also his biological children, and who were conceived as a result of the underlying sexual batteries. Lodge argued the district court failed to exercise reason because there was no evidence that he posed a threat to his own children. The Idaho Supreme Court found no abuse of discretion and affirmed the district court and the no contact order. View "Idaho v. Lodge" on Justia Law

by
At issue in this appeal before the Idaho Supreme Court was the doctrine of successor liability and its applicability to a business known as “Fatty’s Bar” (“Fatty’s”). Tons of Fun, LLC opened Fatty’s in October 2010 and a short time later its manager, Clay Roman, signed a textile services agreement with Alsco, Inc. The Agreement contained an automatic renewal clause, by which the Agreement would renew automatically for a period of 60 months if neither party terminated it in writing at least 90 days before its initial expiration. Fatty’s fell on difficult financial times, and closed for a period in January 2013. Soon after, Steven and Jennifer Masonheimer created a limited liability company called Fatty’s Bar, LLC, and re-opened Fatty’s in mid-February, 2013, continuing to receive textiles from Alsco. The Agreement automatically renewed in March 2016. In March 2017, Fatty’s Bar, LLC terminated the Agreement, well before the 60-month term was set to expire. Alsco then sued Fatty’s Bar, LLC and Clay Roman, seeking damages based on a liquidated damages provision in the Agreement. After a court trial, the district court held that both Fatty’s Bar, LLC and Roman, were jointly and severally liable to Alsco for damages under a liquidated damages clause that was also in the Agreement. Fatty’s Bar, LLC appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Alsco v. Fatty's Bar" on Justia Law

by
Martin Edmo Ish appealed his conviction and sentence for one count of voluntary manslaughter. The State charged Ish with second-degree murder in November 2015 for the June 2009 killing of Eugene Lorne Red Elk in Pocatello, Idaho. Ish and friends were barhopping when at some point, Ish had a confrontation with staff at the Bourbon Barrel. Ish and his friends went a few blocks away to Duffy's Tavern. The friends returned to the Bourbon Barrel, but Ish did not; Barrel staff called Duffy's to alert them of Ish's earlier confrontation. Red Elk was working at Duffy's as a bouncer. He asked Ish to leave, and Ish complied. Later that night, however, Red Elk was discovered in Duffy's parking lot "gurgling blood." He had suffered a brain injury from blunt force trauma to the head; despite being life-flighted to a medical center in Idaho Falls, Red Elk died three days later. TO police, Ish admitted that he “blasted” Red Elk and he “was pretty sure he killed him because he was laying [sic] there gurgling.” A trial was held in April 2017 after which the jury found Ish guilty of the lesser-included charge of voluntary manslaughter. Ish appealed, claiming the trial order erred in seating and instructing the jury, and in making certain evidentiary rulings. After review, the Idaho Supreme Court vacated the judgment of conviction and remand for a new trial. The Supreme Court determined the district court’s finding that the prosecution did not strike Juror 3 with discriminatory intent was clearly erroneous. The Court affirmed the trial court in all other respects. View "Idaho v. Ish" on Justia Law

by
Jeff Good and Harry’s Dairy entered into a contract providing that Harry’s Dairy would purchase 3,000 tons of Good’s hay. Harry’s Dairy paid for and hauled approximately 1,000 tons of hay over a period of approximately eight weeks, but did not always pay for the hay before hauling it and at one point went several weeks without hauling hay. After Harry’s Dairy went a month without hauling additional hay, Good demanded that Harry’s Dairy begin paying for and hauling the remaining hay. Harry’s Dairy responded that it had encountered mold in some of the hay, but would be willing to pay for and haul non-moldy hay at the contract price. Good then sold the remaining hay for a substantially lower price than he would have received under the contract and filed a complaint against Harry’s Dairy alleging breach of contract. Harry’s Dairy counterclaimed for violation of implied and express warranties and breach of contract. The district court granted summary judgment in favor of Good on all claims, and a jury ultimately awarded Good $144,000 in damages. Harry’s Dairy appealed, arguing that there were several genuine issues of material fact precluding summary judgment, that the jury verdict was not supported by substantial and competent evidence, and that the district court erred in awarding attorney fees, costs, and prejudgment interest to Good. Finding only that the district court erred in granting summary judgment on the implied warranty of merchantability counterclaim, the Idaho Supreme Court reversed as to that issue, affirmed as to all others, and remanded for further proceedings. View "Good v. Harry's Dairy" on Justia Law