Justia Idaho Supreme Court Opinion Summaries

Believing that she would be inheriting half of her father’s estate, Deann Turcott and her husband spent considerable time and money making improvements on the father’s land. However, the father subsequently changed his will and left Deann nothing. Deann filed suit seeking quantum meruit damages for the work she had performed. The district court held that quantum meruit damages were not appropriate and awarded damages under a theory of unjust enrichment. Deann appealed the district court’s award of unjust enrichment damages as inadequate. Finding no reversible error in the district court’s judgment, the Idaho Supreme Court affirmed. View "Turcott v. Estate of Clarence D. Bates" on Justia Law

This appeal arose from the district court’s decision to bar Steven Picatti’s 42 U.S.C. section 1983 claims against two deputies on the basis of collateral estoppel. In July 2014, Picatti struggled to drive home because road access was blocked for the Eagle Fun Days parade. After circumventing some orange barricades, Picatti drove toward two uniformed deputies who were on foot patrol by a crosswalk, which was marked with a large sign reading: “road closed to thru traffic.” The factual background from that point was heavily disputed. Picatti alleged Deputy Miner hit the hood of his car, then pulled Picatti out of his truck to tase and arrest him. The deputies contended Picatti “bumped” Deputy Miner with his truck and then resisted arrest, forcing them to tase him into submission. Picatti was ultimately arrested on two charges: resisting and obstructing officers and aggravated battery on law enforcement. At the end of his preliminary hearing, Picatti was bound over. Prior to trial, Picatti accepted a plea agreement in which he pleaded guilty to disturbing the peace for “failing to obey a traffic sign and driving into a restricted pedestrian area.” The court entered a judgment of conviction, which was not appealed, overturned, or expunged. Two years later, Picatti brought a 42 U.S.C. section 1983 suit against his arresting deputies, claiming deprivations of his protected rights to be free from (1) unreasonable seizure, (2) excessive force, and (3) felony arrest without probable cause. The district court granted summary judgment to the defending deputies holding that collateral estoppel barred Picatti from relitigating probable cause once it was determined at the preliminary hearing. Picatti timely appealed. The Idaho Supreme Court affirmed the order granting summary judgment to the deputies as to Picatti’s claims of false arrest and unreasonable seizure; however, the Court vacated the summary judgment as to Picatti’s excessive force claim. The district court correctly applied the doctrine of collateral estoppel to Picatti’s claims of false arrest and unreasonable seizure, but not as to excessive force. In addition, the Court could not find as a matter of law that the deputies were entitled to qualified immunity on Picatti’s excessive force claim when there was a genuine issue of material fact. View "Picatti v. Miner" on Justia Law

Kevin Smith appealed an Idaho Industrial Commission order that concluded the Idaho Industrial Special Indemnity Fund (ISIF) was not liable to him for worker’s compensation benefits. The Commission determined that Smith failed to prove he was totally and permanently disabled under both the 100% method and the odd-lot worker method. He also appealed a denied motion for reconsideration that was denied by the Commission, where he alleged that the Commission determined disability at a future date rather than the date of the hearing, that it improperly interpreted a report, and that it improperly considered an excluded exhibit. Finding no reversible error, the Idaho Supreme Court affirmed the Commission’s order. View "Smith v. Idaho, Industrial Special Indemnity Fund" on Justia Law

Believing that she would be inheriting half of her father’s estate, Deann Turcott and her husband spent considerable time and money making improvements on the father’s land. However, the father subsequently changed his will and left Deann nothing. Deann filed suit seeking quantum meruit damages for the work she had performed. The district court held that quantum meruit damages were not appropriate and awarded damages under a theory of unjust enrichment. Deann appealed the district court’s award of unjust enrichment damages as inadequate. Finding no reversible error in the district court’s judgment, the Idaho Supreme Court affirmed. View "Turcott v. Estate of Clarence D. Bates" on Justia Law

The State appealed a district court order granting Isaac Saldivar’s motion to suppress evidence that he unlawfully possessed a firearm. During a pat-search, police discovered a Smith & Wesson semi-automatic pistol in the left front pocket of Saldivar’s pants. The police later learned that Saldivar was a parolee who was wanted on an active warrant. The district court determined that the officers lacked reasonable suspicion to conduct the pat-search. The district court further held that the inevitable discovery exception was inapplicable to the facts of this case and granted the motion to suppress. The State argued the search was reasonable under the circumstances, and that even if it was not, the inevitable discovery exception applied to this case. It also argued that because of his parole status, Saldivar did not retain a reasonable expectation of privacy regarding the pat-search. The Idaho Supreme Court concluded the search was reasonable under the circumstances presented to the trial court and reversed that court’s suppression order. View "Idaho v. Saldivar" on Justia Law

This appeal arose out of a retaliation action under the Idaho Protection of Public Employees Act (the “Whistleblower Act”) and a negligent infliction of emotional distress claim against the Idaho State Police. Plaintiff Brandon Eller alleged the Idaho State Police (ISP) retaliated against him in two ways: (1) after he testified against another officer in a preliminary hearing; and (2) when he voiced objections to a new ISP policy requiring members of the Crash Reconstruction Unit to destroy draft and peer review reports. A jury awarded Eller $30,528.97 in economic damages under the Whistleblower Act and $1.5 million in non-economic damages for his negligent infliction of emotional distress claim. The district court then entered a memorandum decision and order reducing the award for Eller’s negligent infliction of emotional distress claim to $1,000,000 because Idaho Code section 6-926 capped the State’s liability for actions brought under the Idaho Tort Claims Act (ITCA) at $500,000 per occurrence. Both Eller and ISP timely appealed on several grounds, and their appeals were consolidated. After its review, the Idaho Supreme Court held the district court incorrectly applied the ITCA to Eller’s claim because the Whistleblower Act supplanted it. The district court’s rulings that the Whistleblower Act bars non-economic damage awards and that the ITCA caps Eller’s damages were vacated, and the matter remanded for a partial new trial regarding non-economic damages solely under the Whistleblower Act. View "Eller v. Idaho State Police" on Justia Law

In 2005, Brian Crumb, Frankie McFeron-Crumb, and Marian Crumb joined together with Richard Abbey and Keri Ann Abbey to form Abbey & Crumb Developments, LLC, for the purpose of developing an eighteen-lot subdivision near Post Falls, Idaho. Sometime in 2006, the LLC caused a road to be constructed, which was to serve as the entrance for the subdivision (the entrance road). The road was built on Brian and Frankie Crumb’s land abutting the subdivision and, once constructed, was the only drivable road in and out of the subdivision. In September 2006, the Crumbs withdrew from the LLC. Shortly thereafter, the LLC defaulted on a loan from Security Investor Fund, LLC, and Security Financial Fund, LLC (collectively “Security”). Security then accepted deeds in lieu of foreclosure from the LLC and became an owner of certain lots within the subdivision. At some point in 2017, Brian Crumb took the position that certain subdivision lot owners did not have a right to use the entrance road on his adjoining property, as no applicable easements had ever been recorded. Security then sued in an effort to establish an easement to use the entrance road. The district court granted summary judgment to Brian Crumb and entered judgment in his favor dismissing Security’s complaint. Security appealed. The Idaho Supreme Court affirmed the district court’s grant of summary judgment to Crumb, and its denial of attorney fees to Crumb. View "Security Investor Fund v. Crumb" on Justia Law

In the early 1980s, Ronald and Donna Phelps purchased seven parcels of property in Mores Creek Heights, a subdivision in Boise County. Two of those seven lots are at issue in this appeal (“Lot 26” and “Lot 27”). On October 1, 2004, the Phelpses recorded a quitclaim deed and trust transfer deed, transferring each of the seven lots into their trust. Each deed contained the statement “Mail Tax Statements to: Ronald O. Phelps, Donna J. Phelps, 1 Craftsbury Place, Ladera Ranch, CA 92694.” The Phelpses moved to this address in 2005 and resided there at the time of the bench trial on November 16, 2017. The Phelpses signed for the receipt of certified mail sent to the Ladera Ranch address from Boise County as late as May 18, 2013, and again on December 7, 2015; however, the Phelpses’ mailing address on file with Boise County beginning in 2009, and at all times relevant here, was P.O. Box 1047, El Toro, CA, 92630. Boise County mailed notices regarding property taxes on the lots to the Phelpses at the El Toro address beginning in 2009. The Phelpses did not pay property taxes on the lots for 2010 or any year thereafter. Jeffrey and Johnna Hardy (“the Hardys”) purchased two properties at a tax sale and brought action to quiet title against the Phelpses. The Phelpses counterclaimed against the Hardys and cross-claimed against Boise County, alleging that Boise County failed to provide them proper notice of tax deficiency. Following a bench trial, the district court entered judgment quieting title to the properties in the Hardys and denying the Phelpses’ counterclaim. The Phelpses appealed, asserting the lack of notice makes the Hardys’ deeds void. The Idaho Supreme Court determined Boise County’s efforts to notify the Phelpses of the tax deed satisfied the notice provisions of Idaho law, and were sufficient to satisfy due process requirements. The Court therefore affirmed judgment in favor of the Hardys. View "Hardy v. Phelps" on Justia Law

Miranda Moser dislocated her right shoulder when she lifted a 24-pack of soda while working as a cashier for Rosauers Supermarkets, Inc. (“Rosauers”). Rosauers accepted the claim even though Moser had a pre-existing history of recurrent instability of her right shoulder. Moser underwent shoulder surgery. Afterward, she continued to suffer from “pseudosubluxation” and her surgeon, Dr. Adam Jelenek, recommended she receive a second opinion from a physician in Seattle. Rather than authorizing the request for referral, Rosauers arranged for Moser to be evaluated by Dr. Michael Ludwig who opined that Moser’s shoulder dislocation likely resulted from her pre-existing condition. Dr. Ludwig concluded that Moser had returned to her pre-injury baseline and that she did not require any further medical care. Rosauers filed a notice of medical exam to be performed by Dr. Joseph Lynch on February 5, 2018. Moser responded with a letter conveying she would not be attending the medical exam. Moser filed a Judicial Rule of Practice and Procedure (“J.R.P.”) 15 petition for a declaratory ruling, seeking an order on whether an employer could compel a claimant to attend an Idaho Code section 72-433 examination without first establishing the claimant was within her “period of disability,” which she argued was limited to a period when she was actually receiving benefits. Thereafter, Moser filed a notice that she would not attend the medical examination Rosauers had scheduled for April 2, 2018. The Commission held that following the claim of an accident, injury, or occupational disease, an employer may require a claimant’s attendance at such a medical examination. Moser appeals the Commission’s order. Finding no reversible error in the Commission’s judgment, the Idaho Supreme Court affirmed. View "Moser v. Rosauers" on Justia Law

The Idaho Board of Licensure of Professional Engineers and Professional Land Surveyors (the Board), through its executive director, Keith Simila, brought disciplinary proceedings against Chad Erickson for allegedly violating certain statutes and rules governing the surveying profession. Following an administrative hearing, the Board found that Erickson violated a number of the statutes and rules alleged and revoked his license as a professional land surveyor. Erickson appealed the revocation of his license to the district court. The district court upheld the Board’s finding that Erickson had committed certain violations; however, the district court reversed the portion of the Board’s Order revoking Erickson’s license and remanded the matter for further consideration of the appropriate sanction. Erickson appealed the district court’s decision, arguing that the evidence did not support the Board’s finding of any violations. In addition, Erickson argued numerous procedural errors made by the Board mandated reversal. The Idaho Supreme Court reversed, finding the Board's October 28, 2015 complaint against Erickson was time barred by IDAPA 10.01.02.011.01 and Idaho Code section 54-1220(2); the Board was aware of the allegations against him beginning in 2011, more than four years prior to the submission of the Executive Director’s complaint against him. "The failure to comply with a statute of limitations is jurisdictional and, therefore, this issue is dispositive." Accordingly, the district court’s Substituted Judicial Review Opinion was reversed and the Board’s Order was vacated because it was made upon unlawful procedure. View "Erickson v. Idaho Board of Licensure of Professional Engineers & Professional Land Surveyors" on Justia Law