Justia Civil Procedure Opinion Summaries

In 2013, Tech Landing, LLC leased a building to JLH Ventures, LLC (“JLH”) to operate a paintball business. After the building burned down in 2017, Tech Landing sued JLH, alleging breach of contract, breach of the covenant of good faith and fair dealing, and negligence. The breach of contract and breach of the covenant of good faith and fair dealing claims involved payment of rent after the building was destroyed and the failure to insure the building against fire loss. Those claims were dismissed by stipulation of the parties and were not at issue here. With respect to its negligence claim, Tech Landing alleged the fire was caused by the negligence of JLH. After ruling certain opinions of Tech Landing’s expert witnesses were inadmissible, the district court granted summary judgment to JLH. After review, the Idaho Supreme Court affirmed the district court’s ruling on the admissibility of the expert opinions, but reversed its grant of summary judgment because there were genuine issues of material fact that had to be decided by a jury. View "Tech Landing LLC v. JLH Ventures LLC" on Justia Law

In this case, the Idaho Supreme Court was asked to revisit its decision in Idaho v. Clarke, 446 P.3d 451 (2019), and determine whether its holding was applicable in an administrative proceeding regarding the suspension of driving privileges based on an alleged case of driving under the influence (“DUI”). The Idaho Transportation Department (“ITD”) appealed a district court’s decision overturning its one-year suspension of Jasmine Reagan’s driving privileges. ITD based the administrative license suspension (“ALS”) on Reagan’s arrest for misdemeanor driving under the influence of alcohol and the results of subsequent testing of her blood alcohol content (“BAC”). The arresting officer, acting on a citizen’s report of a possible intoxicated driver, did not personally witness Reagan operating or in control of a vehicle. Reagan failed field sobriety tests administered at her home and, after being arrested, failed a breathalyzer test. Reagan received notice that her driver’s license was suspended for one year, which she appealed. An administrative hearing officer for ITD, relying on Idaho Code section 49-1405, upheld the license suspension. However, on appeal the district court overturned the suspension pursuant to Clarke, reasoning that because the misdemeanor DUI was completed outside the officer’s presence, the arrest required a warrant. On certiorari review, the issues presented were: (1) whether the breathalyzer test was administered pursuant to a lawful arrest; and (2) if the arrest was unlawful, whether test results obtained pursuant to an unlawful arrest are admissible in an ALS hearing before the ITD. The SupremeCourt concluded Idaho Code section 49-1405, as applied in this case, violated the Idaho Constitution. Accordingly, the Court affirmed the district court's decision to overturn ITD's suspension of Reagan's license. View "Reagan v. Idaho Transportation Department" on Justia Law

This case arose from an Idaho company’s attempt to bring an action in Idaho against a resident of Oklahoma and a business located in Oklahoma. Brockett Company, LLC appealed a district court order setting aside a default judgment entered against Scott Crain and Texoma MFG., LLC (collectively, Respondents). The district court set aside the default judgment after determining that it did not have personal jurisdiction over Crain or Texoma. On appeal, Brockett Co. argued that the district court erred in setting aside the default judgment by inappropriately considering an affidavit submitted by Crain, failing to consider facts in the record, and determining that it did not have personal jurisdiction over Crain and Texoma. After review of the trial court record, the Idaho Supreme Court determined he district court erred in granting Respondents’ motion to set aside the default judgment. Accordingly, the Court reversed the district court’s order granting Crain and Texoma’s motion to set aside the default judgment, vacated the district court’s judgment dismissing Brockett Co.’s claims, and remanded with instruction to reinstate the previously entered default judgment against Crain and Texoma. View "Brockett Company LLC v. Crain" on Justia Law

Plaintiff-appellant Cassie Secol and her four minor children (collectively “the Secols”) challenged several evidentiary rulings, jury instructions, and the denial of their motion for a new trial. In late 2016, Damian Secol passed away from a rare form of cancer, T-cell lymphoblastic lymphoma (“T-LBL”). Following his death, the Secols brought a medical malpractice action against Damian’s primary care providers: Kelly Dustin, D.O., Austin Gillette, M.D., and Fall River Medical, PLLC (collectively “Fall River”). At trial, the district court questioned Dr. Jeffery Hancock, Damian’s treating oncologist, in front of the jury concerning the treatment and diagnosis of T-LBL. The Secols moved the district court for a mistrial, arguing the questioning prevented a fair trial. The district court denied the motion. After the jury returned a verdict in Fall River’s favor, the Secols moved the district court for a new trial, which was also denied. The Secols appealed, challenging the district court’s evidentiary rulings, delivery of jury instructions, and the denial of their motion for a new trial. After review, the Idaho Supreme Court reversed the district court, vacated the judgment following the jury verdict, and remanded for a new trial to be conducted by a new district judge. Specifically, the Court determined the district court abused its discretion in denying the Secols’ motion for a new trial because its questioning of Dr. Hancock denied the Secols a fair trial. "Such questioning was an abuse of discretion and necessitates a new trial." Further, the district court abused its discretion in permitting Dr. Hancock to testify as to matters for which no foundation was laid and which were outside the scope of his expertise. And in addition, the district court erred in admitting irrelevant testimony about Dr. Gillette’s and Dr. Dustin’s families and hobbies, and the district court erred in delivering a modified jury instruction on medical negligence, which included prejudicially confusing language concerning direct expert testimony as compared to expert testimony. The district court was affirmed as to the admission of Fall River two experts' testimony on the standard of care because its decision on Fall River’s motion for reconsideration was not part of the record. View "Secol v. Fall River Medical PLLC" on Justia Law

In 2007 and 2008, AgStar Financial Services (AgStar), now Compeer Financial FLCA (Compeer), loaned substantial sums of money to Northwest Sand and Gravel, Inc., Gordon Paving Company, Inc., and Blackrock Land Holdings, LLC (collectively, "Gordon Paving.") As a result of financing these loans, AgStar became a secured creditor of Gordon Paving. In 2012, Gordon Paving defaulted on its $10 million obligation to AgStar, which then resulted in AgStar obtaining a judgment of foreclosure on various parcels of real property Gordon Paving owned. The district court also entered an order allowing the sale of virtually all of Gordon Paving’s business equipment to further satisfy the debt. Gordon Paving appealed the district court’s decision which allowed AgStar to sell the business equipment. In "AgStar I," the Idaho Supreme Court reversed the district court’s order allowing AgStar to liquidate Gordon Paving’s business equipment, but this decision came long after the business equipment had already been sold at auction. On remand, the district court determined that the correct remedy for Gordon Paving was an award of restitution in the amount of the gross proceeds of the sale plus interest from the date of the sale based on its interpretation of Idaho Code section 28-22-104. Compeer appealed the district court’s order denying it an offset for expenses its predecessor, AgStar, incurred in liquidating Gordon Paving’s business equipment. Compeer also appealed the district court’s order awarding Gordon Paving prejudgment interest on the restitution award from the date the collateral was sold. After review, the Supreme Court reversed the district court’s order denying Compeer an offset for the auctioneer’s expenses incurred which were never received by AgStar. The Court affirmed the district court’s order awarding Gordon Paving prejudgment interest; however, the district court’s decision allowing prejudgment interest to run from the date of the sale was vacated. View "Agstar Financial Services v. Northwest Sand & Gravel" on Justia Law

Greg and Cyndi Gomersall filed suit on behalf of their minor child, W.G.G., claiming he received negligent medical treatment at St. Luke’s Regional Medical Center (SLRMC) in Boise when he was injured in December 2010. W.G.G. was 6 years old at the time of the incident. The Gomersalls filed suit against SLRMC on January 25, 2019, more than eight years after W.G.G. was alleged to have been injured. SLRMC moved for summary judgment on the basis that the Gomersalls’ medical malpractice action was time-barred under Idaho Code sections 5-219(4) and 5-230. The district court granted SLRMC’s motion and dismissed the complaint with prejudice. The Gomersalls contended on appeal to the Idaho Supreme Court that the district court erred because Idaho Code section 5-230 was unconstitutional. Specifically, they argued that section 5-230 violated W.G.G.’s due process and equal protection rights by failing to toll the statute of limitations for medical malpractice claims until the age of majority. They also contended the district court erred when it held that the doctrine of equitable estoppel did not preclude SLRMC’s statute of limitations defense. Finding no reversible error, the Supreme Court affirmed the district court’s decision granting summary judgment in favor of SLRMC. View "Gomersall v. St. Luke's Regional Medical Center" on Justia Law

This case arose from an Idaho Industrial Commission determination denying an application for unemployment benefits. William Wittkopf appealed pro se the Commission’s determination that he was ineligible for unemployment benefits because he voluntarily quit his job without good cause and he willfully made a false statement or willfully failed to report a material fact in his unemployment application. On appeal, Wittkopf challenged the factual findings made by the Commission and argued it violated his right to due process by taking into consideration the fact that he voluntarily terminated his employment approximately two and a half years prior to applying for unemployment benefits. After review, the Idaho Supreme Court concluded: (1) Wittkopf failed to provide a cogent argument on appeal regarding whether his right to due process was violated; (2) the Commission’s determination that Wittkopf voluntarily terminated his employment at Stewart’s Firefighter without good cause and without exhausting all reasonable alternatives was supported by substantial and competent evidence; and (3) the Commission’s determination that Wittkopf willfully made a false statement or willfully failed to report a material fact in order to obtain benefits was supported by substantial and competent evidence. Accordingly, the Commission’s decision and order denying Wittkopf’s application for unemployment benefits was affirmed. View "Wittkopf v. Stewart's Firefighter Food Catering, Inc." on Justia Law

At issue in this appeal was whether claimant Curtis Stanley filed a timely complaint against the Industrial Special Indemnity Fund ("ISIF") when Stanley filed his complaint more than five years after his industrial accident and more than one year after receiving his last payment of income benefits. The Idaho Industrial Commission (“Commission”) held it did not have continuing jurisdiction to entertain Stanley’s complaint against ISIF for non-medical benefits. The Commission found Idaho Code section 72-706 barred Stanley’s complaint and dismissed it. Stanley appealed, arguing continuing jurisdiction over medical benefits alone was sufficient to confer jurisdiction over complaints against ISIF and that the Commission erred in determining section 72-706 barred his complaint. Finding the Commission erred in determining section 72-706 barred Stanley's complaint, the Idaho Supreme Court reversed the Commission’s decision. View "Stanley v. Idaho Industrial Special Indemnity Fund" on Justia Law

Holly Cook appealed an administrative order entered by an Administrative District Judge (“ADJ”) declaring her to be a vexatious litigant pursuant to Idaho Court Administrative Rule 59. The order prohibited Cook from filing any new litigation pro se in Idaho without first obtaining leave of the court where the litigation was proposed to be filed. Ms. Cook petitioned for a divorce from her husband (“Mr. Cook”) in 2015. During the lengthy and contentious divorce proceedings, Ms. Cook had assistance of counsel for portions of the proceedings, but represented herself pro se when she did not. Some aspects of the divorce proceedings were appealed to the district court. Mr. Cook filed a moved that Ms. Cook declared a vexatious litigant. Neither party requested a hearing on Mr. Cook’s motion. The district judge presiding over the appeal referred the matter to the ADJ. The ADJ found that Ms. Cook largely failed to appear at dates set in scheduling orders that she (with and without counsel) agreed to. She failed at obtaining continuances, at having the trial judge disqualified, and to move the court for reconsideration of many intermediate decisions. She attempted to collaterally attack the default judgment of divorce, and at some point, was held in contempt for failing to respond to court orders during the divorce proceedings. Separate from the divorce proceedings, the ADJ noted Ms. Cook had filed nine pro se civil protection orders, all of which had been dismissed in favor of the parties from whom she sought protection. The Idaho Supreme Court determined the ADJ abused its discretion in declaring Ms. Cook a vexatious litigant; the ADJ did not review the merits and reason for dismissal in the nine civil protection actions, causing the ADJ to conclude incorrectly the final determinations were adverse to her. Furthermore, with respect to the divorce proceedings, the Court determined the ADJ abused its discretion by failing to make factual findings that Ms. Cook repeatedly attempted to relitigate issues already finally decided by the magistrate court. The Supreme Court concluded the ADJ did not make sufficient findings to support the conclusion that Ms. Cook’s filings were frivolous, unmeritorious, or filed with the intent to cause unnecessary delay. Accordingly, the Court reversed the prefiling order and remanded to allow the ADJ the opportunity to reconsider this matter. View "Cook v. Wiebe" on Justia Law

Choice Feed, Inc. sued Ray and Susan Montierth, alleging that Ray breached an oral agreement to sell his feedlot property to Choice Feed once he arranged a 1031 tax deferred agreement. Although Ray collected money from Choice Feed that was to go toward the purchase of the feedlot property, he never arranged the 1031 exchange. Instead, without notice to Choice Feed, Ray sold the feedlot property to someone else while continuing to accept monthly payments from Choice Feed. At the conclusion of the trial, the jury found in favor of Choice Feed on one count of fraud against Ray, awarded compensatory damages, and assessed $250,000 in punitive damages. Ray moved for judgment notwithstanding the verdict, which the district court granted in part, thereby reducing the jury’s awards of both the compensatory and punitive damages. Ray appealed the jury’s verdict, including the compensatory and punitive damages that were reduced by the district court. Choice Feed cross-appealed the district court’s decision granting Ray’s motion for judgment notwithstanding the verdict and the resulting reduction in damages. After its review, the Idaho Supreme Court affirmed the district court on all issues raised in Ray’s direct appeal: (1) to deny Ray’s motion to dismiss for Choice Feed’s failure to plead fraud with particularity; (2) to give jury instructions that conformed with the evidence presented at trial; (3) to allow Choice Feed to seek improvement expenses as damages at trial; (4) to allow the jury to consider punitive damages; and, (5) to consider punitive damages in its prevailing party analysis and its conclusion that Choice Feed was the prevailing party. The Supreme Court also rejected Ray’s argument that Choice Feed did not have standing to bring suit or that it was not the real party in interest and the Court declined to add a tenth element of a transfer or sale of property to common law fraud. On Choice Feed’s cross-appeal, the Supreme Court reversed the district court’s decision to grant Ray’s JNOV motion and reduce the compensatory damage and punitive damage awards as raised in Choice Feed’s cross-appeal. However, the Court affirmed the district court on Choice Feed’s remaining issue raised in its cross-appeal concerning the award of prejudgment interest to Ray on his open account hay claim. Costs and attorney fees are awarded to Choice Feed as the overall prevailing party on appeal. View "Choice Feed Inc. v. Montierth" on Justia Law