Justia Civil Procedure Opinion Summaries

The case involves a failed business relationship between Mike Jones, Jeremy Sligar, and Sligar's business, Overtime Garage, LLC. Jones claimed they formed a joint venture in 2011 to buy and sell used vehicles, which Sligar disputed. The relationship deteriorated, and Sligar terminated the venture in 2016. Jones filed a complaint in 2016 seeking a declaratory judgment, dissolution of the joint venture, and other relief. Sligar counterclaimed for similar relief. During the litigation, Safaris Unlimited, LLC, bought Jones's interest in the case at a sheriff's sale and settled the case by dismissing Jones's claims against Sligar.The District Court of the Fifth Judicial District, Twin Falls County, denied Jones's motion to set aside the judgment in the first case (Sligar I) and granted summary judgment to Sligar in the second case (Sligar II), finding that Jones's claims were barred by res judicata. The court also awarded attorney fees to Sligar and Safaris, finding Jones's motion to set aside the judgment was frivolous and untimely. Jones appealed these decisions, arguing the consolidation of small claims actions with Sligar I was improper and that his Rule 60(b) motion was timely.The Supreme Court of Idaho affirmed the district court's decisions. It held that the consolidation of the small claims actions with Sligar I was proper, as the small claims were related to the disputed property in Sligar I. The court also found that Jones did not file his Rule 60(b) motion within a reasonable time, as he delayed over five months without a valid reason. Additionally, the court upheld the summary judgment in Sligar II, agreeing that Jones's claims were barred by res judicata. The court awarded attorney fees to Sligar for the appeal in Sligar I but not in Sligar II, as Sligar did not prevail on its cross-appeal. View "Jones v. Sligar" on Justia Law

This case involves a dispute between siblings Elizabeth and Jason Carter, who are both licensed dentists and co-owners of Carter Dental. In 2020, Jason accused Elizabeth of misusing the practice’s funds for her personal benefit. The parties agreed to mediation, which resulted in a settlement agreement that included a noncompete clause. Elizabeth later refused to sign a written mutual release, leading Jason to move to enforce the settlement agreement. The district court found the settlement agreement and noncompete clause enforceable and dismissed the case with prejudice. Elizabeth appealed, arguing that the noncompete clause and the settlement agreement were unenforceable.The Supreme Court of the State of Idaho affirmed the district court's judgments. The court found that Elizabeth was estopped from arguing that the settlement agreement was unenforceable because she had not appealed the district court’s dismissal of the case with prejudice. The court also held that the district court did not err in awarding attorney fees and costs to Jason and Carter Dental. The court concluded that Jason and Carter Dental were entitled to attorney fees and costs on appeal. View "Carter Dental v. Carter" on Justia Law

The case involves Scott and Natalie Pinkham, who contracted with Three Peaks Homes, LLC, for the construction of a custom home. The construction did not go as planned and the contract was terminated before the home was completed. Three Peaks subsequently filed two $600,000 mechanics’ liens against the Pinkhams’ home. The Pinkhams then filed a complaint against David Plate, Rebeccah Jensen, Three Peaks, Rebel Crew Construction, LLC, and Legacy Management Enterprises, LLC, asserting several causes of action.The district court denied the Pinkhams’ motion for summary judgment. Later, the Pinkhams’ attorney, Lance Schuster, filed a motion to withdraw as counsel for Plate, Jensen, Three Peaks, and Legacy, which the court granted. The court ordered Appellants to appoint another attorney or appear in person within twenty-one days of service of the order, failing which, the court may enter default judgment against them. The court clerk served a copy of the withdrawal order on Appellants via first class mail.The Pinkhams moved for the entry of default and default judgment against Appellants and for dismissal of Appellants’ counterclaims with prejudice. The district court granted the Pinkhams’ motion without a hearing. Appellants later secured new counsel and filed a motion to set aside the default and default judgment under Idaho Rule of Civil Procedure 60(b)(1), (4), and (6). The district court denied Appellants’ motion.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision denying the motion to set aside the default and default judgment. The court held that the district court did not err in concluding that Appellants failed to demonstrate good cause to set aside the entry of default. The court also held that Appellants have failed to establish a right to relief under Rule 60(b). The court declined to award attorney fees on appeal. View "Pinkham v. Plate" on Justia Law

The case involves an individual, referred to as "John Doe," who repeatedly applied for admission to the Idaho State Bar. Doe's applications were denied due to concerns about his character and fitness, including his honesty, judgment, and respect for the rights of others. Doe challenged these denials, arguing that his federal lawsuits against the Idaho State Bar were a necessary defense of his rights and that his conduct was protected by the First Amendment.The Idaho State Bar filed a petition with the Idaho Supreme Court, seeking permission to reject Doe's third application and to prohibit him from filing future applications for a specified period. Doe cross-petitioned, seeking immediate admission to the Idaho State Bar.The Idaho Supreme Court denied Doe's cross-petition, finding that he had not demonstrated that he met the essential eligibility requirements to practice law. The court granted the Idaho State Bar's petition in part, allowing it to reject Doe's third application and prohibiting Doe from filing a new application for two years. The court found that Doe had not shown a significant change in his circumstances that would render him eligible to practice law. The court also ordered the Idaho State Bar to refund Doe's application fee. View "ISB v. John Doe" on Justia Law

In this case, Laurie Barton, a third-year law student at the University of Idaho, was accused of violating the university's honor code by committing academic misconduct during a final examination. Despite denying the allegations, she was sanctioned with degree denial after a series of Honor Court proceedings. Barton exhausted her administrative review options, including an appeal to the Idaho State Board of Education, and then petitioned for judicial review. The district court denied her petition. Instead of appealing this decision, Barton sued the Board of Regents of the University of Idaho and Idaho State Board of Education, alleging nine causes of action, all of which the district court dismissed at summary judgment.The district court's judgment was affirmed by the Supreme Court of the State of Idaho. The Supreme Court found that Barton had failed to raise a genuine issue of material fact that the University violated its duty of good faith and fair dealing or that it made a specific promise that induced her action. The court also found that Barton's motion for a protective order was implicitly denied and moot, as the case was resolved on summary judgment. The court concluded that Barton's appeal was pursued frivolously, unreasonably, and without foundation, and awarded attorney fees and costs to the University. View "Barton v. Board of Regents" on Justia Law

Michelle Oksman sued the City of Idaho Falls after slipping and falling on a wet surface in the lobby of the West Deist Aquatic Center, a facility owned and operated by the City. Oksman alleged negligence on the part of the City. The district court initially granted the City's motion for summary judgment, concluding that the City had no actual notice of a dangerous condition and did not fail to take reasonable action to remedy potential hazards. However, the court later withdrew its grant of summary judgment after Oksman identified the person who had allegedly stated that people frequently fell in the area where she had fallen. The case proceeded to a jury trial, during which the district court limited Oksman's testimony and declined to give a jury instruction Oksman requested regarding the reasonable value of necessary services. The jury returned a verdict in favor of the City, and the district court dismissed Oksman's complaint with prejudice. Oksman appealed.The Supreme Court of the State of Idaho vacated the district court's judgment and remanded the case for a new trial. The Supreme Court found that the district court had erred in limiting Oksman's testimony about a statement made by the manager of the aquatic center, which was crucial to Oksman's case. The Supreme Court also provided guidance on issues likely to arise again on remand, including the use of depositions for impeachment and the use of leading questions. The Supreme Court further vacated the district court's award of costs to the City as the prevailing party. Neither party was awarded attorney fees on appeal. View "Oksman v. City of Idaho Falls" on Justia Law

A landowner in Blaine County, Idaho, John Hastings Jr., made unauthorized alterations to the Big Wood River. The Idaho Department of Water Resources (the Department) issued a notice of violation to Hastings and ordered him to cease all unauthorized work and submit a plan for river restoration. Hastings and the Department entered into a consent order, which required Hastings to pay a civil penalty and submit a restoration plan. However, the Department rejected Hastings' proposed restoration plans. Hastings then filed a petition for a hearing to express his disagreement with the terms of the Department's conditional approval for a permit.The Department initiated an administrative proceeding against Hastings, and later filed a counterclaim in Hastings's district court action seeking specific performance, which would require Hastings to comply with the Consent Order. Hastings asserted that the Department's enforcement action was barred by the two-year statute of limitations set forth in Idaho Code section 42-3809. The district court granted summary judgment to the Department on the statute of limitations issue, and Hastings appealed.The Supreme Court of the State of Idaho affirmed the district court's decision. The court held that the Department's enforcement action was not time-barred by the statute of limitations under Idaho Code section 42-3809. The court found that the earliest possible date that the Department “ought to have reasonably known” that Hastings did not intend to comply with the Consent Order was when he filed the underlying declaratory judgment action. Until then, Hastings was in compliance with the Consent Order and had given every indication that he was attempting to remain in compliance. Therefore, the Department was entitled to summary judgment as a matter of law on this issue. View "Hastings v. IDWR" on Justia Law

The case involves the Idaho Department of Health and Welfare's (the Department) action to set aside a transfer of real property from two Medicaid recipients, Robert Gilbert and Juanita Gilbert, to their five grandchildren. The Department had provided Robert and Juanita with Medicaid benefits totaling over $140,000. In 2005, Robert and Juanita executed two quitclaim deeds transferring their interest in real property to themselves and their grandchildren. After their deaths, the Department filed an action to set aside the two quitclaim deeds, alleging that the estates did not receive adequate consideration for the transfer of their interests in the real property. One of the grandchildren, Earle L. Beason, argued that the Department’s action was barred by the statute of limitations and that Robert and Juanita received adequate consideration for their interests in the property.The District Court of the Seventh Judicial District of the State of Idaho granted the Department’s motion for summary judgment and entered a judgment in favor of the Department setting aside the quitclaim deeds. The court concluded that the Department’s action was timely and that the Department had demonstrated the absence of a genuine issue of material fact regarding adequate consideration. Earle L. Beason appealed the decision.The Supreme Court of the State of Idaho affirmed the district court’s decision. The court held that the Department’s action was timely filed pursuant to Idaho Code section 5-224, the catch-all statute of limitation, which provides a four-year limitation period when an action for relief is not otherwise provided for. The court also affirmed the district court’s grant of summary judgment in favor of the Department because Earle L. Beason did not establish a genuine issue of material fact regarding adequate consideration. View "Idaho Department of Health and Welfare v. Beason" on Justia Law

The case revolves around a premises liability claim filed by Diane Lands against Sunset Manor, LP, and Bingham County Senior Citizens Center, Inc. Lands tripped on an uneven sidewalk outside her apartment building, Sunset Manor, and suffered injuries including a concussion, headaches, chin pain, dizziness, and short-term memory loss. She claimed that her injuries were a result of the fall and sought damages for past and future medical expenses, non-economic damages, and other losses.The District Court of the Seventh Judicial District of the State of Idaho had previously reviewed the case. The court issued a scheduling order setting deadlines for disclosing expert witnesses and completing discovery. Lands failed to meet these deadlines, leading to the exclusion of her expert witnesses at trial. The district court also limited the time period for which non-economic damages could be recovered due to the lack of expert testimony.In the Supreme Court of the State of Idaho, Lands argued that her disclosure deadlines were automatically extended when the trial and pretrial conference were postponed. She also contended that the district court erroneously required non-retained experts to be disclosed at the same time and in the same manner as retained experts. The Supreme Court affirmed the decisions of the district court, ruling that Lands' disclosure deadlines were not extended and that any error in the district court's interpretation of the disclosure requirement for non-retained witnesses was harmless. The court also held that the district court did not err in limiting Lands' non-economic damages. View "Lands v. Sunset Manor, LP" on Justia Law

This case involves a medical debt collection claim between Medical Recovery Services, LLC (MRS), a debt collection service representing Franklin County Medical Center (FCMC), and Cierra Moser, a former FCMC employee. MRS sought to collect debt for medical services provided to Moser at FCMC during her employment. FCMC offered a 50% discount to employees for unpaid medical bills after insurance payments. When Moser's employment ended, FCMC allegedly retracted the discount and assigned the debt to MRS.The magistrate court granted partial summary judgment favoring MRS regarding a minimum principal amount of debt owed by Moser and decided in favor of MRS on the issue of FCMC's right to retract the employee discount. However, the district court reversed the partial grant of summary judgment and remanded all issues for retrial due to disputed facts requiring retrial.On appeal, MRS argued that the district court erred in reversing the partial grant of summary judgment and in remanding all issues for retrial. The Supreme Court of Idaho affirmed the district court's decision, finding that there was a material dispute of fact over the amount of medical debt owed by Moser, which precluded a grant of partial summary judgment. Furthermore, MRS failed to ensure relevant transcripts were included in the record on appeal to the Supreme Court, which was fatal to its position that the district court erred in remanding for a retrial on all issues. View "Medical Recovery Services v. Moser" on Justia Law