Justia Civil Procedure Opinion Summaries

Four former employees of Litster Frost Injury Lawyers (LFIL) filed a lawsuit against LFIL and its former sole shareholder, Martha Frost, for unpaid wages and breach of an employment agreement. They claimed LFIL owed them compensation in the form of wages, bonuses, profit sharing, and other expenses incurred while employed. The district court granted summary judgment in favor of LFIL, concluding that the employees' claims were time-barred by the one-year statute of limitations under Idaho Code section 45-614 and that the employment agreement was an unenforceable "agreement to agree."The employees appealed, arguing that the district court erred in determining that the provisions of the employment agreement were not severable or enforceable and that the court should have supplied a "reasonable time" for performance. LFIL cross-appealed, arguing that the district court erred in denying their request for attorney fees following summary judgment.The Supreme Court of Idaho reviewed the case and held that the district court did not err in granting summary judgment on the employees' breach of contract claims because the employment agreement was unenforceable. The court found that the agreement's essential terms were too indefinite and subject to future negotiations. However, the court reversed the district court's decision regarding Sarah's reimbursement claim, finding that issues of material fact existed as to whether her claim fell within Idaho's Wage Claim Act. The court affirmed the district court's grant of summary judgment on all other claims.The Supreme Court also reversed the district court's decision on attorney fees, holding that the district court did not apply the correct legal standard. The court remanded the case for further proceedings consistent with its opinion. Attorney fees on appeal were awarded to LFIL for the time spent responding to certain claims, and costs were awarded to LFIL. View "Litster v. Litster Frost Injury Lawyers PLLC" on Justia Law

Amanda Mitchell filed for a civil protection order against Nicholas Ramlow in October 2020, alleging that he was stalking her by tracking her movements and placing a tracking device on her car. The magistrate court issued a temporary ex parte protection order and scheduled a hearing. Due to COVID-19 mask mandates, Ramlow was denied entry to the courthouse for refusing to wear a mask, leading to the hearing being rescheduled. At the rescheduled hearing, Ramlow was again absent, and the magistrate court issued a one-year protection order requiring him to attend a 52-week domestic violence course and review hearings.Ramlow filed a motion for reconsideration, which was denied. He then appealed to the district court. The protection order was extended but expired before the district court heard the appeal. The district court requested supplemental briefing on mootness and ultimately dismissed the appeal as moot, finding no applicable exceptions to the mootness doctrine. Ramlow appealed the district court's decision, arguing that his appeal still presented justiciable issues and fell within exceptions to the mootness doctrine.The Supreme Court of Idaho reviewed the case and affirmed the district court's dismissal. The court held that the appeal was moot because the protection order had expired, and no exceptions to the mootness doctrine applied. The court found that the issues were too fact-specific to be capable of repetition yet evading review, there were no collateral legal consequences, and the case did not raise issues of substantial public interest. The court also declined to vacate the expired protection order and denied attorney fees to both parties, awarding costs to Mitchell as the prevailing party. View "Mitchell v. Ramlow" on Justia Law

The case involves the Schrivers, who sought damages after their cat, Gypsy, died following a veterinary procedure and was subjected to an unauthorized necropsy by Dr. Raptosh and Lakeshore Animal Hospital. The Schrivers claimed non-economic damages for emotional distress and loss of companionship, arguing that the emotional bond between pet and owner should be compensable. They also sought economic damages based on the pet's value to them.The District Court of the Third Judicial District of Idaho granted summary judgment in favor of Dr. Raptosh and Lakeshore on several claims, including negligent infliction of emotional distress, intentional infliction of emotional distress, and lack of informed consent. The court denied the Schrivers' claim for emotional distress damages related to trespass to chattels/conversion but allowed the "value to owner" measure of economic damages for the loss of Gypsy.The Supreme Court of Idaho affirmed the district court's decision in part and reversed in part. The court upheld the denial of emotional distress damages for trespass to chattels/conversion, agreeing that such damages are limited to independent torts of negligent or intentional infliction of emotional distress. The court also affirmed the summary judgment on the negligent infliction of emotional distress claim, holding that veterinarians do not have a duty to prevent emotional harm to pet owners. However, the court reversed the summary judgment on the intentional infliction of emotional distress claim related to the unauthorized necropsy, finding that a jury should decide if the conduct was extreme and outrageous. The court affirmed the use of the "value to owner" measure of damages, excluding sentimental value.The case was remanded for further proceedings on the intentional infliction of emotional distress claim. The Schrivers were awarded costs on appeal, but attorney fees were not granted to Dr. Raptosh and Lakeshore, as the primary issue of liability remains unresolved. View "Schriver v. Raptosh" on Justia Law

Roberta Evans underwent a total hip replacement surgery performed by Dr. Mark B. Wright at St. Luke’s Magic Valley Regional Medical Center. Post-surgery, Evans experienced persistent pain and discomfort, which led her to seek a second opinion. Another doctor confirmed that her hip bone socket was abnormally anteverted, and subsequent revision surgery revealed a periprosthetic joint infection. Evans filed a lawsuit against Dr. Wright and St. Luke’s, alleging negligence in their follow-up care and treatment.The District Court of the Fifth Judicial District of Idaho dismissed Evans’s case, ruling that her claim was barred by the two-year statute of limitations under Idaho Code section 5-219(4). The court found that Evans’s surgical complications were objectively ascertainable by March 4, 2019, indicating that some damage was present. Her motion for reconsideration was denied.The Supreme Court of Idaho affirmed the district court’s decision. The court held that Evans’s medical malpractice claim was time-barred, as the statute of limitations began when her symptoms indicated some damage, which was before April 6, 2019. The court also found that the district court did not err in dismissing Evans’s complaint and that her equitable estoppel argument was without merit. The court denied attorney fees to both parties but awarded costs to Dr. Wright and St. Luke’s as the prevailing parties. View "Evans v. Wright" on Justia Law

Kerry Angelos filed a defamation lawsuit against Greg and Susan Schatzel, alleging they created a website that published defamatory comments about him. During the lawsuit, Angelos faced financial difficulties, leading to his interests in the lawsuit being auctioned at a sheriff’s sale to satisfy a preexisting judgment. Greg Schatzel purchased Angelos’s interests and substituted himself as the plaintiff, subsequently dismissing the lawsuit with prejudice. Angelos appealed, arguing that his defamation claims were personal and could not be deemed “property” subject to execution under Idaho law.The District Court of the Fourth Judicial District of Idaho granted Schatzel’s motion to substitute as the plaintiff and denied a motion by another creditor, Pacific Global Investment, Inc. (PGI), to intervene. The court found no legal basis to support Angelos’s contention that the sheriff’s sale was invalid or that substituting Schatzel violated public policy. Consequently, the court dismissed the lawsuit with prejudice.The Supreme Court of Idaho reviewed the case and held that defamation claims are personal and not assignable under Idaho law, referencing the precedent set in MacLeod v. Stelle. The court concluded that Angelos’s defamation claims could not be subject to execution as “other property” under Idaho Code section 11-201. The court vacated the district court’s order granting Schatzel’s motion to substitute and the judgment dismissing the case with prejudice. The case was remanded to determine which of Angelos’s remaining claims, if any, were properly transferred to Schatzel through the sheriff’s sale. The court also denied Schatzel’s request for attorney fees, awarding costs to Angelos as the prevailing party. View "Angelos v. Schatzel" on Justia Law

Samuel Hickman was electrocuted while working on a construction site when a boom crane contacted overhead power lines. Hickman and his wife filed a personal injury lawsuit against Boomers, LLC, its owner Michael Landon, and employee Colter James Johnson, alleging negligence and recklessness. Boomers moved for summary judgment, claiming immunity under Idaho’s Worker’s Compensation Law. Hickman argued that the accident fell under the “willful or unprovoked physical aggression” exception to the exclusive remedy rule. The district court granted summary judgment for Boomers and denied Hickman’s motion for reconsideration.The district court applied the 2020 amended version of Idaho Code section 72-209(3), which clarified the “willful or unprovoked physical aggression” exception, and concluded that Boomers did not intend to harm Hickman or have actual knowledge that injury was substantially likely. Hickman appealed, arguing that the district court should have applied the pre-amendment version of the statute and the standard from Gomez v. Crookham Co., which interpreted the exception to include conscious disregard of knowledge that an injury would result.The Supreme Court of Idaho reversed the district court’s decision, holding that the pre-amendment version of section 72-209(3) and the Gomez standard should apply. The court found that the additional evidence submitted by Hickman in his motion for reconsideration created a genuine issue of material fact regarding whether Johnson consciously disregarded the known risk of injury from the power lines. The case was remanded for further proceedings consistent with this opinion. View "Hickman v. Boomers, LLC" on Justia Law

The Idaho Attorney General filed a petition seeking to prevent an initiative from appearing on the 2024 general election ballot. The initiative, proposed by Idahoans for Open Primaries, aims to replace Idaho’s closed party primary system with a non-partisan “top four primary” and implement ranked-choice voting for the general election. The Attorney General argued that the signatures supporting the initiative were obtained through false statements and material omissions, violating Idaho Code section 34-1815, and that the initiative violated the single-subject rule of the Idaho Constitution by proposing two distinct changes to election laws.The Idaho Supreme Court dismissed the Attorney General’s petition on procedural grounds. The court held that allegations of fraud in the signature-gathering process must first be adjudicated in the district court. The court emphasized that its original jurisdiction to issue writs of prohibition and mandamus is limited and that such writs are proper only when a state actor has a clear legal duty to act. The court found that the Secretary of State had no clear legal duty to invalidate the signatures based on the Attorney General’s allegations and that the Secretary’s role in the initiative process is ministerial, not adjudicatory.The court also addressed the Attorney General’s claim that the initiative violated the single-subject rule. It concluded that this issue was not ripe for review because the initiative had not yet been approved by voters. The court stated that substantive challenges to an initiative’s constitutionality are not justiciable before the initiative becomes law. The court’s decision does not preclude the Attorney General from pursuing his claims in the district court. View "Labrador v. Idahoans for Open Primaries" on Justia Law

Jessica Wiseman and her children sued Dr. Nathan Rencher and others for the wrongful death of Eric Wiseman, alleging medical malpractice and gross negligence. Rencher, the only defendant subject to Idaho's prelitigation screening panel requirement, moved for summary judgment, arguing that the Wisemans failed to comply with this requirement. He supported his motion with the panel’s advisory decision, filed under seal. The district court granted Rencher’s motion, concluding that the Wisemans did not meet the prelitigation requirement based on the advisory decision. The Wisemans also sought to disqualify the district judge, which was denied.The district court, part of the Seventh Judicial District of Idaho, ruled that the advisory decision could be considered to determine compliance with the prelitigation requirement. The court found the statutes ambiguous and concluded that they allowed limited review of the advisory decision. The court also ruled that the statutes controlled over conflicting Idaho Rules of Evidence. Consequently, the district court granted summary judgment in favor of Rencher, finding no genuine issue of material fact regarding the Wisemans' compliance with the prelitigation requirement.The Supreme Court of Idaho reversed the district court’s decision, holding that the prelitigation screening statutes unequivocally precluded judicial review of the advisory decision for any purpose. The court emphasized that the statutes clearly stated there should be no judicial review and that parties should not be affected by the panel’s conclusions. The Supreme Court remanded the case for further proceedings. Additionally, the court declined to disqualify the district judge on remand, distinguishing this case from precedent and finding no appearance of bias. Neither party was awarded attorney fees on appeal, as both prevailed in part. View "Wiseman v. Rencher" on Justia Law

The case involves a dispute between Brian L. Porter, trustee of the Brian L. Porter Revocable Trust, and Marvin A. Remmich, manager of McMillan Storage LLC, an Idaho limited liability company. The conflict centers on the management of the LLC and the conduct of its members. Remmich initially filed a complaint in California against Porter, alleging various breaches related to the construction of the LLC’s storage facility. Porter later filed a complaint in Idaho, accusing Remmich of mismanaging the LLC. Both parties reside in California, and the LLC’s principal place of business is also in California.In the California action, the court denied Porter’s motion to dismiss on grounds of forum non conveniens, retaining jurisdiction over the case. Subsequently, the Idaho District Court dismissed Porter’s claims without prejudice under Idaho Rule of Civil Procedure 12(b)(8), which allows for dismissal when another action between the same parties for the same cause is pending. The district court reasoned that the California court could adjudicate the entire controversy, and concurrent litigation would lead to increased costs and potentially inconsistent judgments.The Supreme Court of Idaho affirmed the district court’s decision. It held that the district court did not abuse its discretion in dismissing the Idaho action. The court found that the parties and claims in both actions were essentially the same, and the California court was in a position to resolve the entire dispute. The court emphasized considerations of judicial economy, minimizing litigation costs, and avoiding inconsistent judgments. Consequently, the Idaho action was dismissed without prejudice, and Porter was directed to pursue his claims in the California court. View "Porter v. Remmich" on Justia Law

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