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

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

David Kosmann appealed a district court judgment relating to a dispute that arose from the sale of real property. He claimed the district court erred in enforcing an oral settlement agreement reached in mediation between Kosmann, Kevin Dinius, and Dinius & Associates, PLLC (collectively “Dinius”). Kosmann also argued the trial court erred in: (1) awarding attorney fees to Dinius as a sanction against Kosmann and his attorney; (2) declining to impose sanctions against Dinius and his attorney; and (3) striking an untimely memorandum and declaration in support of his motion to reconsider. After review of the trial court record, the Idaho Supreme Court affirmed in part and reversed in part. The Supreme Court determined the district court did not err in enforcing the settlement agreement; the court also did not err in declining to impose sanctions against Dinius on ethics violations. However, the Supreme Court determined the district court abused its discretion in imposing I.R.C.P. 11 sanctions against Kossman and his counsel: the district court did not act consistently with the applicable legal standard for imposing sanctions pursuant to I.R.C.P. 11(b). The Supreme Court declined to address all other issues Kossman raised, and determined he was not entitled to attorney fees on appeal. "The record in this case is so tarnished with questionable conduct that it has presented this Court with a vexing ethical and legal dilemma. While we are gravely concerned over the potential ethical lapses which allegedly occurred during the mediation of this matter, there are no findings in the record concerning these matters. Therefore, as the trial court determined, we will leave to the Idaho State Bar, if properly called upon, the responsibility to investigate this matter further and make the necessary findings and conclusions as to the ethical issues presented." View "Kosmann v. Dinius" on Justia Law

Denise M. Ehrlich appealed an Idaho Industrial Commission (the Commission) order that determined she was ineligible for unemployment benefits. The Commission affirmed the determination of the Idaho Department of Labor and the Appeals Examiner that Ehrlich willfully underreported her weekly earnings. On appeal, Ehrlich contended the Commission’s finding that she willfully misrepresented her wages was clearly erroneous. Finding no reversible error, the Idaho Supreme Court affirmed the Commission’s decision. View "Ehrlich v. IDOL" on Justia Law

Relying on Idaho Criminal Rule 47, Jane Doe filed a motion to modify disposition requesting that the juvenile court place her back on probation after sentence had been imposed, and modify its previous computation of credit for time served. The juvenile court held that Doe’s motion was actually a motion to reduce sentence under Idaho Criminal Rule 35 (a rule which has not been incorporated into the Idaho Juvenile Rules) and concluded that it did not have jurisdiction to consider Doe’s motion. Doe appealed the juvenile court’s decision to the district court. The district court affirmed the decision, holding that Rule 47 did not grant jurisdiction to reduce the sentence, but that jurisdiction existed under Idaho Code sections 20-505 and 20-507. The district court held that whether the sentence should be modified was a discretionary call and that the juvenile court did not abuse its discretion in declining to place Doe back on probation or incorrectly calculate Doe’s credit for time served. The Idaho Supreme Court agreed with the district court’s decision to affirm the magistrate court’s denial of Doe’s motion to modify disposition, but took the opportunity to explain there was no jurisdiction for the juvenile court to modify the juvenile’s sentence once it had been imposed and the time for appeal had run. View "Idaho v. Jane Doe (Juvenile)" on Justia Law