Justia Idaho Supreme Court Opinion Summaries

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

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

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

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