Justia Idaho Supreme Court Opinion Summaries

The City of Middleton (the City) appealed the district court’s grant of summary judgment to Martin and Patricia Galvin on their claim of prescriptive easement and its award of attorney fees to the Galvins pursuant to Idaho Code section 12-117. In 2016, the Galvins filed a complaint against the City of Middleton for quiet title, declaratory judgment, and a permanent injunction concerning their use of Willis Road, a private road that the City acquired in 2015. The Galvins alleged that their use of Willis Road since 1949 created a prescriptive easement entitling them to use the road for ingress, egress, and farming and irrigation purposes. The City’s answer denied the existence of the easement but did not dispute that the Galvins had used the road for the past sixty years. Finding no reversible error in the grant of summary judgment, the Idaho Supreme Court affirmed. View "Galvin v. City of Middleton" on Justia Law

Bruce Birch appealed a district court decision to affirm a magistrate court decision to award attorney fees against Birch. This case concerned the disposition of the estate of Birch and Linda Bailey’s mother, Ruth Birch. Ruth executed a last will and testament that intentionally omitted Birch. After Ruth’s death in 2011, Bailey was appointed as the personal representative for her estate. The magistrate approved a compromise agreement that allowed Birch and another intentionally omitted sibling to receive equal shares of the estate. After approval of the agreement, Bailey requested Birch pay the estate's attorney fees for preparing the agreement. The magistrate court awarded attorney fees to Bailey. In this appeal, Birch argued the magistrate court’s award of attorney fees was an abuse of discretion because it did not comply with the requirements of the Idaho Rules of Civil Procedure. The Idaho Supreme Court determined the district court erred in awarding fees, reversed and remanded for further proceedings. View "Bailey v. Birch" on Justia Law

On November 20, 2018, the Acting Governor of Idaho issued a proclamation that Proposition 2 had passed, and subsequently the Idaho Code was amended to add section 56-267, a statute to expand Medicaid eligibility in Idaho. Petitioner Brent Regan argued 56-267 violated Idaho’s Constitution by delegating future lawmaking authority regarding Medicaid expansion to the federal government. Regan requested the Idaho Supreme Court declare section 56-267 unconstitutional and issue a writ of mandamus to direct the Secretary of State Lawerence Denney to remove section 56-267 from the Idaho Code. Finding the statute constitutional, the Supreme Court dismissed Regan’s petition and denied his request for a writ of mandamus. View "Regan v. Denney" on Justia Law

Richard Meyers appealed his conviction for grand theft on the grounds that he was denied his Sixth Amendment right to self-representation. Meyers was assigned a public defender, but was dissatisfied with his assigned counsel's performance, and filed a motion for a "change of an attorney." After observing the court’s colloquy with his counsel, Meyers withdrew his motion, indicating that he wanted to give his attorney “a chance,” and that he could work with his counsel. On the day set for trial, counsel expressed concerns about his client’s mental capacity. Ultimately, Meyers was deemed “fit to proceed” with trial, and his case was put back on the trial calendar. Meyers indicated to the court he was “prepared to represent” himself, and would present his defense “as soon as is possible.” In his letter, Meyers discussed other objections he had previously raised about his counsel’s performance. Meyers concluded his letter with the following sentence: “I choose to exercise the right to defend myself in this matter.” There were no indications in the letter that Meyers sent a copy to his public defender. The letter was not written in the form of a motion for the appointment of new counsel; rather, it merely advised the court of Meyers’s decision to “fire” his attorney of record and represent himself. Meyers did not submit a request for a hearing or attempt to schedule one. Nothing in the record suggested the court ever saw the letter, or was made aware of its contents, prior to trial. The bench trial occurred, as previously scheduled; Meyers had a new public defender, and the court confirmed that Meyers wished to proceed without a jury and asked if there were any other matters that needed to be addressed before the trial began. Meyers, through his new attorney, confirmed his decision to proceed with a bench trial. During the trial, Meyers cooperated with his new attorney and eventually, with his attorney conducting the direct examination, testified on his own behalf. His attorney handled all aspects of the trial, and at no point during the trial did Meyers or his counsel mention his earlier request to represent himself. At the conclusion of the trial, the district court found Meyers guilty of grand theft. Thereafter, Meyers was sentenced to a unified term of seven years, with two years fixed. Meyers appealed, arguing that his Sixth Amendment right to self-representation was violated by the district court’s failure to discuss his letter. The State argued Meyers did not unequivocally invoke his right to self-representation, and even if he did, he abandoned his request through his conduct. The Idaho Supreme Court concurred with the State that Meyers abandoned his request, and therefore, affirmed the conviction and sentence. View "Idaho v. Meyers" on Justia Law

After defendant Ryan Matthews was arrested for absconding from parole, methamphetamine was found on his person during the booking process at jail, for which he was charged with possession of a controlled substance. After having his motion to suppress denied, Matthews agreed to a plea deal and the district court sentenced him to seven years with three years fixed. The district court declined to order the full amount of restitution for prosecution costs under Idaho Code section 37-2732(k). The district court stated it agreed with Matthews’s concern that he felt like he was having “to pay for exercising [his] constitutional right.” Matthews appealed, contending the district court abused its discretion by ignoring mitigating factors at sentencing. The State cross-appealed, arguing the district court abused its discretion by refusing to order Matthews to pay the costs of prosecution on the sole basis that it would infringe on his constitutional rights because such a statement is inconsistent with this Court’s precedent. Finding no reversible error in Matthews' appeal or the State's cross-appeal, the Idaho Supreme Court affirmed the district court. View "Idaho v. Matthews" on Justia Law

Appellants Ryan and Kathryn McFarland owned real property in Garden Valley, Idaho, which feathred three structures insured through Liberty Mutual Insurance Group: a main cabin; a detached garage with an upstairs “bonus room”; and a pump house containing a geothermal well. The policy provided two types of coverage for structures. Coverage A (“Dwelling Coverage”) provided up to $188,500 in coverage for “the dwelling on the ‘residence premises’. . . including structures attached to the dwelling . . .” and Coverage B (“Other Structures Coverage”) provided up to $22,350 for “other structures on the ‘residence premises’ set apart from the dwelling by clear space.” In February 2017, a radiant heater burst in the bonus room and damaged the garage and its contents. After the McFarlands filed a claim, Liberty stated that the damage was covered under the policy. Believing the damage to fall under the Dwelling Coverage, the McFarlands hired contractors to repair the damage. However, after Liberty paid out a total of $23,467.50 in March 2017, Liberty stated that the coverage was exhausted because the damage fell under the Other Structures Coverage. This led the McFarlands to sue, alleging among other claims, breach of contract based on Liberty’s interpretation of the policy. The parties filed cross motions for summary judgment on the issue of whether the damage fell under the Dwelling Coverage or the Other Structures Coverage. Ruling that the policy unambiguously provided coverage for the garage under the Other Structures Coverage, the district court denied the McFarlands’ motion and granted Liberty’s. The McFarlands appealed. Finding that the policy at issue here failed to define the term "dwelling", and the term was reasonably subject to differing interpretations, the Idaho Supreme Court reversed the award of summary judgment and remanded for further proceedings. View "McFarland v. Liberty Insurance Corp" on Justia Law

Vernon K. Smith (Smith) appealed a district court’s award of sanctions. This case originally arose from a contract for the sale of lima beans between Victoria Smith (“Victoria”) and Treasure Valley Seed Company (“TVSC”). As Victoria’s son, Smith filed a complaint against TVSC for breach of contract. The original complaint named Victoria as plaintiff, by and through her attorney in fact, Vernon K. Smith, by and through his “Durable and Irrevocable Power of Attorney.” TVSC learned that Victoria had died three months before Smith’s filing of the complaint. Based on Victoria’s death, TVSC moved to dismiss the complaint, arguing that there was no longer a real party in interest. Smith argued that he was a real party in interest because the power of attorney he drafted was irrevocable. The district court held that Smith’s power of attorney terminated on Victoria’s death and granted TVSC’s motion to dismiss. At the hearing for costs and fees, the district court stated that Victoria’s estate should have brought the action, but because no probate had been filed, there was no real party in interest able to substitute or join. After ruling that the complaint was unreasonable and without foundation, the district court awarded attorney fees to TVSC under Idaho Code section 12-121, to be assessed jointly and severally against Victoria and Smith, as counsel. Smith appealed both the dismissal of the case and the award of attorney fees, but his appeal of the dismissal was not filed timely, so the Idaho Supreme Court only addressed Smith’s appeal of the attorney fees. The Idaho Supreme Court concurred with the district court with respect to termination of the power of attorney. Smith maintained the power of attorney gave him authority to sue on his mother's behalf, and upon remand of the case to the district court to determine the appropriate amount of fees to be assessed, the trial court awarded fees as a sanction under Rule of Civil Procedure 11. The Supreme Court declined of offer Smith "an opportunity for a mulligan" on his arguments about the power of attorney, and found the district court did not abuse its discretion when it awarded attorney fees, or levied sanctions against Smith. View "Smith v. Treasure Valley Seed Co." on Justia Law

2M Company Inc. (“2M”) appealed an Industrial Commission (“Commission”) decision that determined Matthew Atkinson was entitled to reasonable medical benefits for injuries he sustained in an accident on his way to work. The Commission found that an exception to the “going and coming” rule applied based on 2M’s intent to compensate Atkinson for his travel time while going to or coming from work. 2M and its surety, Employer Assurance Company, appealed. Finding no reversible error, the Idaho Supreme Court affirmed the Commission's determination. View "Atkinson v. 2M Company, Inc." on Justia Law

This case began as a highly contentious divorce proceeding between vexatious litigant-appellant Ronald Van Hook and his then-wife Dawn Cannon, in which Van Hook lost custody of his children (hereinafter the Canyon County divorce case). Van Hook was represented by legal counsel only for portions of the divorce proceeding as each of his attorneys withdrew from the case. Following each attorney’s departure, Van Hook filed a new series of pro se motions and objections to the court, which were similar and repetitive. Van Hook filed numerous motions to amend the magistrate court’s temporary custody and visitation orders, disqualify the magistrate judge assigned to the case, change venue, and find Cannon in criminal contempt. He also filed multiple petitions for a writ of habeas corpus. His pro se motions and petitions were continuously denied and largely found to be frivolous. When Van Hook appealed the Canyon County divorce case, the district court found Van Hook’s motion to recuse the magistrate judge frivolous, and that his appeal was also without foundation. The issue this case presented for the Idaho Supreme Court's review arose from an administrative order declaring Van Hook a vexatious litigant under Idaho Court Administrative Rule 59. The Idaho Supreme Court determined Van Hook: met I.C.A.R. 59 (d)(1) because he commenced more than three pro se litigations that were adversely determined against him; met I.C.A.R. 59 (d)(2) because he repeatedly attempted to relitigate the final divorce and custody determinations by the magistrate court; and met I.C.A.R. 59 (d)(3) because he repeatedly filed frivolous motions and pleadings. Therefore, the Supreme Court affirmed the prefiling order declaring Van Hook a vexatious litigant. View "Order Re: Vexatious Litigant (Van Hook)" on Justia Law

This case stemmed from Truck Insurance’s refusal to defend its insured, Scout, LLC, in a trademark infringement action brought over Scout’s use of the trademark ROGUE in the advertisement of its restaurant, Gone Rogue Pub. Scout claimed its use of ROGUE constituted an advertising injury that was covered by the insurance it purchased from Truck Insurance. Truck Insurance did not dispute that ordinarily Scout’s advertising injury would be covered and it would accordingly have a duty to defend, but coverage was properly declined in this instance based on a prior publication exclusion found in the policy. The district court granted summary judgment to Truck Insurance after determining that a Facebook post of Scout’s Gone Rogue Pub logo before insurance coverage began triggered the prior publication exclusion, thereby relieving Truck Insurance of the duty to defend Scout. Scout appealed. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Scout, LLC v. Truck Insurance" on Justia Law