Justia Civil Procedure Opinion Summaries

Articles Posted in Idaho Supreme Court - Civil
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In 2019, an Idaho district court granted Respondents Matthew and Bonnie Latvalas’ claim for a prescriptive easement over a road known as “South Camp Bay Road” to reach their property located on the shores of Lake Pend Oreille. Because the prescriptive easement was created by the operations of an active mine, the district court determined that the scope of the easement included the ability to transport labor and materials to build a home on the Latvalas’ property. In Latvala v. Green Enterprises, Inc., 485 P.3d 1129 (2021) (Latvala I), the Idaho Supreme Court affirmed the district court’s determination that the Latvalas had a prescriptive easement over South Camp Bay Road. However, the Court vacated the district court’s judgment after concluding it had impermissibly expanded the scope of that easement. On remand, the parties disputed whether the Supreme Court’s decision prohibited the Latvalas’ proposed residential use of South Camp Bay Road, or only the construction of a residence on the Latvalas’ property. The district court entered a second amended judgment that prohibited the Latvalas from using South Camp Bay Road to construct a residence on their property, but did not restrict the Latvalas from using the road for residential purposes. Appellants Green Enterprises, Inc., James and and Julie Frank, and Larimore and Kathryn Cummins (neighboring landowners) timely appealed. Finding no reversible error in the latter district court judgment, the Supreme Court affirmed: “Because possibly driving across South Camp Bay Road will do nothing to increase the burden on the servient landowners, we affirm the district court’s second and third amended judgments because they are consistent with our holding in Latvala I. The Latvalas may not use South Camp Bay Road to build a residence; they may drive along Camp Bay Road to access a residence. Whether and to what extent that burden may or could change in the future is a question for another day. On the record before us we will not hypothesize on what the outcome would be under those theoretical scenarios.” View "Latvala v. Green Enterprises, Inc." on Justia Law

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This appeal arose from an Idaho district court decision affirming a declaratory ruling issued by Respondent Dave Jeppesen (the Director) in his capacity as Director of the Idaho Department of Health and Welfare (the Department). Appellant Grace at Twin Falls, LLC (Grace), a residential assisted living and memory care facility, partnered with a preferred pharmacy to offset costs associated with a software system that coordinated the tracking and delivery of residents’ prescription medications. Because residents who failed to choose the preferred pharmacy did not receive the offset, Grace sought to charge those residents an additional $10.00 each month to cover the difference. Grace brought a petition for declaratory ruling to the Department, asking the Director to declare that Idaho Code section 39-3316(12)(b) and IDAPA 16.03.22.550.12.b did not prohibit Grace from charging the $10.00 fee to those residents who did not choose the preferred pharmacy. The Director denied the petition, declaring that Grace would not “be permitted to assess a non-preferred-pharmacy fee as such fee violates residents’ right to choose their pharmacy or pharmacist . . . .” Grace sought judicial review before the district court, which affirmed the Director’s declaratory ruling. Grace then appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the district court. View "Grace at Twin Falls, LLC v. Jeppesen" on Justia Law

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Robert Fulfer, while making a delivery, exited his truck and stepped down into a nine-inch-deep pothole, resulting in serious personal injuries. He was working for Ruan Logistics Corporation (“RLC”), which was contracted as a transportation and cargo-hauling provider by Sorrento Lactalis, Inc. (“SLI”). Fulfer filed a personal injury action against SLI seeking damages based on premises liability and negligence. SLI moved to dismiss pursuant to Idaho Rules of Civil Procedure 12(b)(6) and 12(c), arguing that it was immune from a tort action because it was a statutory employer of Fulfer, meaning that Idaho’s Workers’ Compensation laws provided Fulfer’s exclusive remedy. In response, Fulfer argued that an exception to the exclusive remedy rule applied. The district court determined Fulfer’s complaint failed to state a claim upon which relief could be granted because he: (1) failed to comply with Idaho’s notice pleading requirements by not addressing statutory employer immunity; and (2) failed to allege specific facts required for establishing an exception to the exclusive remedy rule based on the Idaho Supreme Court’s decision in Gomez v. Crookham Co., 457 P.3d 901 (2020), which was controlling at the time. Accordingly, the district court dismissed Fulfer’s complaint without prejudice and later denied Fulfer’s motion to reconsider and for leave to file a second amended complaint. Fulfer appealed. The Supreme Court determined the district court erred in dismissing Fulfer’s first amended complaint pursuant to Idaho Rule of Civil Procedure 12(b)(6) because it satisfied Idaho’s pleading requirements. Further, the Supreme Court concluded the exception to the exclusive remedy rule in I.C. 72-209(3) applied to direct and statutory employers. The case was remanded for further proceedings. View "Fulfer v. Sorrento Lactalis, Inc." on Justia Law

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Karen and Keith Hood owned real property in Washington County, near Cambridge, Idaho. The Hoods’ property was near property owned by Gayle and Paul Poorman and Rusty Anderson. The Hoods’ property had three decreed appurtenant water rights; the water from two of these water rights was diverted from Rush Creek and conveyed to the Hoods’ property through an irrigation ditch (“the Hood ditch”). The crux of this case involved that portion of the Hood ditch which ran through the Poormans’ and Anderson’s properties. The Hoods filed a complaint in November 2019, seeking to have the district court: (1) enjoin the Poormans and Anderson from interfering with their maintenance of the Hood ditch right-of-way; (2) declare the Hoods’ rights with respect to the right-of-way; and (3) award damages against the Poormans and Anderson for damage done to the Hood ditch right-of way. Anderson sought to have the Hoods reinstall a bridge over the ditch on Anderson’s property. The Poormans asked the district court to require the Hoods to replace removed culverts on the Poormans’ property, and refrain from removing trees and other vegetation outside the scope of the Hood ditch right-of-way. The Poormans also requested monetary compensation for damage to their property as a result of the Hoods’ ditch maintenance, including the removal of trees and vegetation. The district court issued a written decision granting the Hoods’ motion for partial summary judgment that incorporated the limitations proposed by the Poormans and Anderson. The Idaho Supreme Court affirmed in part and reversed in part the district court's judgment. The Supreme Court found that while the district court did not abuse its discretion in choosing to enjoin the Hoods from excessively accessing the right-of-way, some of the district court’s specific limitations on when the Hoods could access the right-of-way were an abuse of discretion because they were either unsupported by evidence in the record or contradicted by the evidence presented at trial. On remand, the Supreme Court gave the district court a mandate to issue two judgments: one defining the purpose, length, width, and location of the primary easement to run with the land and bind the parties’ successors-in-interest; the second second to identify the injunctive relief limiting the Hoods’ exercise of their secondary easement rights and include the declaratory and monetary relief awarded, not to run with the land or bind the Hoods’ successors-in-interest. View "Hood v. Poorman" on Justia Law

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A dispute over attorney fees arose from the probate proceedings of Eric Milo Hirning’s estate. Appellants challenged the district court’s affirmance of the magistrate court’s decision to allow the personal representatives to recover their legal expenses incurred in the administration of the estate, pursuant to Idaho Code section 15-3-720. The Appellants also challenged the attorney fees awarded to the Respondents on intermediate appeal pursuant to Idaho Code section 12-121. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Uzzle v. Estate of Eric Milo Hirning" on Justia Law

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Christopher Luck, as legal guardian and conservator for Ethel Luck, appealed a district court’s dismissal of Ethel’s negligence claim against Sarah Rohel for injuries Ethel sustained in a car accident. On March 13, 2019, the last day before the applicable statute of limitations ran, Amy Clemmons, Ethel’s daughter, signed and filed a pro se Complaint against Rohel on Ethel’s behalf, alleging a single count of negligence. Ethel did not sign the Complaint. The same day, Ethel signed a durable power of attorney designating Clemmons as her attorney-in-fact. Clemmons was a licensed Washington attorney, who, at the time the Complaint was filed, was not licensed to practice law in Idaho. A little over a month later, Clemmons filed a pro se Amended Complaint, which continued to identify the same plaintiff, “AMY CLEMMONS, as Guardian for ETHEL LUCK.” Both Ethel and Clemmons signed the Amended Complaint. Rohel moved to strike the first complaint, arguing Clemmons, who was not licensed to practice law in Idaho, signed the Complaint. Rohel also moved to dismiss the complaint, arguing Clemmons had not been appointed as Ethel’s guardian, was not admitted to the Idaho State Bar and therefore, lacked authority to file the Complaint on Ethel’s behalf. Clemmons subsequently retained an attorney, who filed a notice of appearance on April 23, 2019. The notice of appearance failed to specify whether counsel appeared on behalf of Clemmons, Ethel or both. Counsel argued that Idaho law allowed Clemmons to act as a general guardian and as such, Clemmons was the real party in interest and could initiate a lawsuit pro se, on behalf of Ethel. Additionally, counsel argued that any deficiencies in the Complaint had been cured pursuant to Rule 11 because Ethel signed the Amended Complaint. The district court granted both of Rohel's motions, and Clemmons appealed. The Idaho Supreme Court vacated the district court's judgment, finding it erred in applying the rule of nullity to strike Clemmons' Complaint. The Supreme Court determined the caselaw the trial court used as grounds for its judgment was no longer applicable in light of subsequent amendments to Idaho Rule of Civil Procedure 11. In light of this holding, the Supreme Court remanded this matter to allow the district court to exercise its discretion and determine whether to allow Plaintiff Luck to cure the improper signature. View "Luck v. Rohel" on Justia Law

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Brandon and Brandi Kelly married on April 20, 2015, and had a child on June 9, 2015. Brandon filed for divorce on May 30, 2017. This appeal primarily concerned their disputes regarding the division of property and attorney fees. Prior to marriage, Brandon and Brandi entered into a prenuptial agreement (“the PNA”) seeking to establish their rights to various items of property. Brandi and Brandon were represented by separate counsel during the negotiation and execution of the PNA. Before signing the PNA, Brandi reviewed Brandon’s 2014 tax return. Brandi’s attorney requested changes to the PNA’s definitions of separate and community property, which were made. Brandi expressly waived her right to review other financial documentation concerning Brandon’s assets and signed the PNA. During the pendency of the divorce action, and relevant to this appeal, Brandon filed four motions for partial summary judgment and Brandi filed two motions for partial summary judgment, each of which required interpretation of various provisions of the PNA. After review, the Idaho Supreme Court affirmed in part, and reversed in part, certain district court decisions with respect to the parties' PNA. The Supreme Court found the district court erred (1) in affirming the magistrate court’s decision that the PNA barred Brandi from requesting attorney fees for child custody, visitation and support matters; (2) in affirming the magistrate court’s summary judgment decision concluding that Brandon’s payments from EIRMC were his separate property; and (3) when it failed to vacate the award of attorney fees to Brandon for his contempt motions, but did not err when it affirmed the magistrate court’s other deductions from Brandi’s separate property award. View "Kelly v. Kelly" on Justia Law

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Access Behavioral Health appeals from the district court’s judgment upholding an order of the Idaho Department of Health and Welfare that demanded recoupment of Medicaid payments made to Access. The Department sought to recoup certain payments made to Access because it failed to meet the Department’s documentation requirements. Following an audit of provider billings, the Department found Access billed Medicaid for two codes for services provided to the same patient on the same day without documentation to support its use of the codes. The Department concluded the documentation deficiencies violated IDAPA Rule 16.03.09.716 and the Handbook. The Idaho Supreme Court determined the Department had legal authority to issue recoupment demands to Access. Access failed to demonstrate an entitlement to payment of those funds sought to be recouped. The False Claims Act's materiality requirement was inapplicable to the Department’s administrative action. Finally, laches did not bar the Department’s administrative actions. Judgment was thus affirmed. View "Access Behavioral Health v. IDHW" on Justia Law

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In October 1998, Andrea and Brad Hall, together with Linda and Frank Exler, purchased real property in Roberts, Idaho. The Halls owned a two-thirds interest in the property and the Exlers owned one-third. In September 2005, Linda deeded all of her interest in the property to Frank. Frank died intestate in March 2006. Travis Exler, Frank’s son and sole heir, was appointed as the personal representative of Frank’s estate (“the Estate”). The parties dispute their relationship in the years between Frank's death and the filing of the underlying lawsuit. Brad testified he received notice from the County rearding unpaid taxes on the property. Travis said he was unable to pay the Estate's portion of the overdue taxes. Brad testified the parties reached an agreement by which Travis would deed the property to the Halls if they paid the outstanding tax balance. Within weeks of their conversation, Brad contacted a law firm to prepare a quitclaim deed. In contrast, Travis stated he would transfer the Estate’s interest in the property if the Halls reimbursed his costs associated with cleaning up the property. Travis testified that in 2009 the parties also agreed the Halls would take care of cleanup costs and taxes. Travis stated that he did not transfer ownership of the property to the Halls and was never presented with a quitclaim or personal representative’s deed. It was undisputed that the Halls had sole control, use, and operation of the property since 2009. The Halls oversaw the administration of the lease and maintenance of the property. Travis did not list any profit or loss from the property on his personal taxes. In addition, the Halls paid the overdue taxes on the property, and made all tax payments on the property since 2009. The Halls and Travis did not communicate between 2009 and 2019. In June 2010, Travis voluntarily filed for Chapter 13 bankruptcy. Travis did not list the property on his bankruptcy petition. The Chapter 13 Bankruptcy Trustee moved to dismiss based on Travis’s failure to list an interest in the property, rental income, and the transfer of an apartment building and 150 cattle. The bankruptcy court dismissed Travis’s petition. After Travis refused the Halls’ request to reopen probate of the Estate, the Halls filed a complaint to quiet title to the property. The district court issued a memorandum decision and order, quieting title to the disputed property in the Halls based on the lost deed doctrine. Travis appealed, but finding no reversible error, the Idaho Supreme Court affirmed the district court's order. View "Hall v. Exler" on Justia Law

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After receiving reminder notices by mail, the insureds failed to pay a renewal premium for a rented home by the due date. Fourteen days after payment was due, the insureds mailed a check to the insurance company for the late renewal premium. Six days later, but before the insurance company reviewed the late payment, a fire occurred at the home. Two days after the fire, the insurance company returned the late payment, denied coverage for the loss, and denied reinstatement of the policy. The insurance company subsequently brought a declaratory judgment action against the insureds. The district court granted summary judgment in favor of the insurance company. Finding no reversible error in that judgment, the Idaho Supreme Court affirmed. View "United Heritage v. Zech" on Justia Law