Justia Idaho Supreme Court Opinion Summaries

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

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

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

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

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

This case stemmed from Carol McCoy Brown’s petition for an elective share of her decedent husband’s augmented estate. When Michael Orion Brown (the decedent) died intestate, she discovered that he had set aside multiple payable on death (POD) accounts for his children and grandchildren from a prior marriage. Carol filed a petition to recover a portion of the POD funds as part of the decedent’s augmented estate. The decedent’s children, Dorraine Pool and Michael J. Brown (the Heirs), challenged the petition. The magistrate court denied Carol's petition, concluding that she had not met her burden of demonstrating that the POD funds were quasi-community property as required by the elective share statutes. Carol appealed to the district court, which affirmed the magistrate court’s denial of the petition, and granted the Heirs attorney fees. Still aggrieved, Carol sought certiorari review by the Idaho Supreme Court. But finding no reversible error in either of the lower courts' decisions, the Supreme Court affirmed. View "Brown v. Brown" on Justia Law

Michael Hayes was convicted by jury of felony battery on a correctional officer. Hayes appealed his judgment of conviction on three grounds: (1) the district court erred by failing to issue subpoenas for two medical professionals; (2) the district court abused its discretion by allowing the State to inquire into prior instances of Hayes’ conduct towards correctional officers; and (3) the district court abused its discretion by denying Hayes’ motion for a new trial. The Court of Appeals reversed the district court’s order denying Hayes’ requests for subpoenas, and held that the district court abused its discretion by allowing the State to inquire into prior instances of Hayes’ conduct. Accordingly, the Court of Appeals vacated the district court’s judgment of conviction and remanded the case for a new trial. The Idaho Supreme Court granted the State’s petition for review, and finding the district court did not err in issuing its judgment, the Supreme Court reversed the appellate court and affirmed the trial court's judgment of conviction. View "Idaho v. Hayes" on Justia Law

Michael Richardson was injured while working, and attempted to recover personal injury damages outside of the worker’s compensation system. Hayden Homes subcontracted with Z&H Construction, LLC, Plumbing Unlimited, LLC, and Alignment Construction, LLC for various aspects of a new construction project. Richardson was employed by Alignment, and worked on Hayden’s construction project. He was injured when he fell through a crawl space cover at the construction site. He received a worker’s compensation award from the worker’s compensation insurer for his direct employer, Alignment. After Richardson received his worker’s compensation award, he sued Z&H, Hernandez Framing, LLC (a subcontractor of Z&H), and Plumbing Unlimited (collectively, “Respondent LLCs”), alleging negligence in the construction of the crawl space cover. The district court granted the Respondent LLCs’ motion for summary judgment, determining that the Respondent LLCs were Richardson’s statutory co-employees and immune from suit pursuant to Idaho Code section 72- 209(3). Finding no reversible error in that reasoning, the Idaho Supreme Court affirmed the district court’s order granting summary judgment. View "Richardson v. Z&H Construction, LLC" on Justia Law

Natalie Shubert sued her former public defender, Michael Lojek, former Ada County chief public defender Alan Trimming, and Ada County (collectively the “Ada County Defendants”). In 2008, Shubert was charged with two felonies and pleaded guilty to both charges. Her sentences were suspended in each case, and she was placed on probation. After a probation violation in 2011, the Ada County district court entered an order extending Shubert’s probation beyond the time period allowed by law. The mistake was not caught. After Shubert’s probation should have ended in both cases, she was charged and incarcerated for a subsequent probation violation in 2014. Thereafter, in 2016, Shubert was charged with a new probation violation. Shubert was assigned a new public defender, who discovered the error that unlawfully kept Shubert on probation. Shubert’s new public defender filed a motion to correct the illegal sentence, raising the error that had improperly extended her probation. The district court granted Shubert’s motion to correct the illegal sentence and released Shubert from custody. Shubert then sued the Ada County Defendants, alleging false imprisonment, intentional infliction of emotional distress, negligence per se, negligence, and state and federal constitutional violations. The district court dismissed all of Shubert’s claims except for negligence. In denying the Ada County Defendants’ motion for summary judgment, the district court held that public defenders were not entitled to common law quasi judicial immunity from civil malpractice liability, and two provisions of the Idaho Tort Claims Act (ITCA) did not exempt public defenders from civil malpractice liability. The Ada County Defendants petitioned the Idaho Supreme Court pursuant to Idaho Appellate Rule 12. Finding no reversible error in the district court's judgment, the Supreme Court affirmed the district court’s order granting summary judgment, and remanded for further proceedings. View "Shubert v. Ada County" on Justia Law

Employers Resource Management Company (“Employers”) returned to the Idaho Supreme Court in a second appeal against the Idaho Department of Commerce. In 2014, the Idaho Legislature passed the Idaho Reimbursement Incentive Act (“IRIA”). The Economic Advisory Council (“EAC”), a body created under IRIA to approve or deny tax credit applications, granted a $6.5 million tax credit to the web-based Illinois corporation Paylocity, a competitor to Employers Resource Management Company. Employers claimed Paylocity’s tax credit created an unfair economic advantage. Paylocity, however, had yet to receive the tax credit because it did not satisfy the conditions in the Tax Reimbursement Incentive agreement. Having established competitor standing in Employers Res. Mgmt. Co. v. Ronk, 405 P.3d 33 (2017), Employers argued the Idaho Reimbursement Incentive Act was unconstitutional under the separation of powers doctrine. The district court dismissed Employers’s case upon finding the Act constitutional. Finding no reversible error in that judgment, the Idaho Supreme Court affirmed. View "Employers Resource Mgmt Co v. Kealy" on Justia Law