Justia Civil Procedure Opinion Summaries

Thomas Lanham appealed the dismissal of his legal malpractice action against his former attorney, Douglas Fleenor. Fleenor represented Thomas in a will contest regarding Thomas’s father. After the magistrate court ruled against Lanham at the summary judgment stage, Fleenor filed an untimely appeal, which was rejected on that basis. Because the appeal brought by Fleenor was untimely, Lanham brought a legal malpractice action against Fleenor in district court, alleging that the failure to timely appeal the magistrate’s ruling proximately caused him financial loss because he had a meritorious appeal that he never got to pursue due to Fleenor’s negligence. The district court dismissed Lanham’s legal malpractice claim, reasoning that a timely appeal by Fleenor would have been unsuccessful on the merits; hence, Lanham did not suffer any injury as a result of Fleenor’s alleged malpractice. Lanham argued on appeal to the Idaho Supreme Court that the interpretation of the will, in which the deceased attempted to disinherit Lanham, did not properly dispose of all of the estate because it did not contain a residuary clause. Lanham argued these failures should have resulted in various assets passing to him through intestate succession. Finding no reversible error, the Supreme Court affirmed the district court’s dismissal of Lanham’s malpractice case. View "Lanham v. Fleenor" on Justia Law

The underlying dispute in this case involved a commercial transaction between H2O Environmental, Inc. (H2O) and Farm Supply Distributors, Inc. (Farm Supply). Following a bench trial, H2O was awarded $7,354.64 for Farm Supply’s breach of an express oral contract. The magistrate court subsequently awarded attorney’s fees to H2O pursuant to Idaho Code section 12-120(3), but limited its award to the amount in controversy. H2O appealed to the district court, claiming that the magistrate court abused its discretion. The district court affirmed and awarded attorney’s fees to Farm Supply. H2O timely appealed. The Idaho Supreme Court determined the district court erred when it affirmed the magistrate court’s award of attorney fees: nothing in the record explained the relationship between the magistrate court’s evaluation of the Idaho Rule of Civil Procedure 54(e)(3) factors and its decision regarding the amount to award for attorney’s fees. “It is not enough for a trial court to acknowledge the existence of the Rule 54(e)(3) factors; rather, it must appear that there is a reasoned application of those factors in the trial court’s decision regarding the amount of attorney’s fees to be awarded.” The Supreme Court reversed and remanded for further proceedings. View "H20 Environmental v. Farm Supply" on Justia Law

This was an action arising out of a failed golf course and residential development project known as the “Idaho Club.” North Idaho Resorts, LLC (“NIR”) appealed an award of discretionary costs and costs as a matter of right awarded against it, contending the district court abused its discretion by awarding discretionary costs, and that the court’s award of some costs as a matter of right was erroneous. After review of the district court record, the Idaho Supreme Court determined the district court abused its discretion by using a formulaic analysis in this case, and by awarding some costs as a matter of right against NIR. The district court judgment was reversed and remanded for further proceedings. View "Valiant Idaho v. No. Idaho Resorts" on Justia Law

The humans in the events giving rise to this lawsuit were related by blood or marriage: Stephen Boswell was married to Karena Boswell; Karena is Mary Steele’s daughter; Amber was Mary Steele’s granddaughter and owned a Scottish terrier named Zoey. Amber and Zoey lived in Mary’s home. Stephen and Karena Boswell appealed a judgment entered in favor of Amber Steele and the Estate of Mary Steele. The Boswells sought to recover damages for injuries suffered by Stephen after he was bitten by Zoey. Before the case was submitted to the jury, the district court ruled that all of the Boswells’ claims sounded in negligence and so instructed the jury, rejecting the Boswells’ proposed jury instructions on common law and statutory strict liability. The jury found that the Steeles were not negligent and the district court entered judgment consistent with that verdict. The Idaho Supreme Court found that the Boswells were entitled to have the jury instructed on theories other than negligence. The instructions given by the trial court did not accurately convey the elements of a common law dog bite case in Idaho, nor did they contemplate a cause of action arising from the Pocatello Municipal Code. As such, the Supreme Court vacated the judgment and remanded for a new trial. View "Boswell v. Steele" on Justia Law

St. Luke’s Magic Valley Regional Medical Center appealed a jury verdict awarding Rodney and Joyce Herrett $3,775,864.21 in a medical malpractice action wherein St. Luke’s admitted liability. On appeal, St. Luke’s argued that the district court erred by denying its motion for mistrial, admitting certain expert testimony, and improperly instructing the jury as to recklessness. Finding no reversible error, the Idaho Supreme Court affirmed. View "Herrett v. St. Luke's Magic Valley RMC" on Justia Law

This appeal involved an Idaho district court’s denial of a jury trial under Rule 39(b) of the Idaho Rules of Civil Procedure and the decision to pierce the corporate veil. The dispute stemmed from a transaction between Kym Nelson, who acted on behalf of KDN Management Inc., (“KDN”), and WinCo, Foods, LLC (“WinCo”), for concrete floor work that KDN performed in several WinCo stores. The district court found that KDN had overcharged WinCo for the work, and awarded WinCo $2,929,383.31 in damages, including attorney fees. The district court also held Nelson and two entities associated with her, SealSource International, LLC, and KD3 Flooring LLC, jointly and severally liable for WinCo’s damages. Nelson, SealSource and KD3 argued on appeal to the Idaho Supreme Court that the trial court erred in concluding: (1) Nelson was personally liable for damages relating to this dispute; and (2) that KDN, SealSource and KD3 were alter egos of one another. Nelson and the corporate co-defendants also argued the district court abused its discretion by denying their motion for a jury trial under Rule of Civil Procedure 39(b). Finding no reversible error in the district court’s judgment, the Idaho Supreme Court affirmed the judgment and award of attorney fees to WinCo. View "KDN Management, Inc. v. WinCo" on Justia Law

On July 11, 2013, the Idaho Department of Labor (“IDOL”) mailed an eligibility determination for unemployment benefits (the “2013 determination”) to William Wittkopf. This determination found Wittkopf underreported his wages for several weeks, which resulted in an overpayment in unemployment benefits. As a result, Wittkopf was: (1) ordered to repay the overpayment; (2) ineligible for any unemployment benefits for a fifty-two week period; and (3) assessed a civil penalty. Additionally, Wittkopf was told that he would remain ineligible for unemployment benefits until all amounts were repaid. Pursuant to Idaho Code section 72– 1368(3) the last day for Wittkopf to file a protest to the 2013 determination was July 25, 2013, which he failed to do. IDOL attempted to collect on the 2013 determination over the next year without success. Subsequently in early 2016, Wittkopf filed for Chapter 7 bankruptcy. The debt he owed to the state of Idaho was included in his bankruptcy and was discharged by order of the Bankruptcy Court. In September 2016, Wittkopf began filing new claims for unemployment benefits with IDOL because he worked a seasonal job and was not receiving any income in the winter months. After not receiving benefits for several weeks, Wittkopf called IDOL which informed him he was ineligible for unemployment benefits because he had failed to pay back his overpayment, civil penalty, and interest he owed IDOL, even though those amounts were discharged in bankruptcy. Wittkopf mailed a letter to IDOL protesting the denial of his unemployment benefits. Wittkopf claimed in this letter that he was eligible for unemployment benefits because his bankruptcy discharged any amount he owed to IDOL. An Appeals Examiner construed Wittkopf’s 2016 letter as a protest of the 2013 determination. Two days later the Appeals Examiner issued a written decision finding there was no jurisdiction to hear Wittkopf’s protest because it was not filed within fourteen days of when it was issued on July 25, 2013, as required by Idaho Code section 72-1368. On November 3, 2016, Wittkopf appealed the Appeals Examiner’s decision to the Industrial Commission. On January 27, 2017, the Industrial Commission affirmed the Appeals Examiner’s decision. The Idaho Supreme Court determined the Industrial Commission erred in affirming the examiner without having determined first whether: (1) the bankruptcy discharge voided IDOL's 2013 determination; (2) whether the discharge operated as an injunction against any effort to collect, recover or offset the 2013 debt; and if yes, (3) why the Department's denial of current benefits on the basis of the 2013 debt wasn't a violation of the injunction. The matter was remanded back to the Industrial Commission for further proceedings. View "Wittkopf v. Idaho Dept of Labor" on Justia Law

Both of ten-year-old Jane Doe II’s parents passed away in 2017. A family friend with whom Jane and her mother had been living (“Friend”) petitioned for guardianship of Jane. Jane’s father’s twin sister (“Aunt”) also petitioned for guardianship. During proceedings the magistrate court appointed a local attorney, Auriana Clapp-Younggren (“Clapp-Younggren”), to serve as both the attorney and the guardian ad litem for Jane. After trial the magistrate court followed Clapp-Younggren’s recommendation and awarded temporary guardianship to Friend so that Jane could finish the school year, but appointed Aunt as Jane’s permanent guardian. Friend appealed the magistrate court decision. The Idaho Supreme Court determined the magistrate court abused its discretion by failing to conduct a reasonable inquiry into whether Jane possessed sufficient maturity to direct her own attorney. The final decree appointing Aunt as Jane’s permanent guardian was vacated and the case was remanded so that the magistrate court can conduct a hearing to determine whether Jane possessed sufficient maturity to direct her own attorney prior to a new trial. View "In the Interest of Jane Doe II (under 18)" on Justia Law

In January 2017, a jury found that an enforceable contract bound Mike Von Jones to pay Safaris Unlimited, LLC, (Safaris) $26,040 for a 2012 big game hunt Jones went on in Zimbabwe, Africa (2012 hunt). After the jury’s verdict, Safaris was awarded attorney fees plus interest on the judgment, bringing the judgment against Jones to $122,984.82. Safaris obtained a writ of execution in June 2017 and attended the sheriff sale as the only bidder. At the sale, Safaris purchased a pending lawsuit arising from Jones’s business venture by making a $2,500 credit bid. Jones was later successful in moving to vacate the sale. Jones appealed three issues from the jury trial: (1) the admission of a handwriting exemplar; (2) certain statements made by the district court concerning the handwriting exemplar; and (3) a jury instruction on agency law. Safaris cross appealed the district court’s decision to vacate the sheriff sale. After review, the Idaho Supreme Court determined: (1) the district court did not abuse its discretion by admitting the handwriting exemplar; (2) the district court did not violate Jones’s procedural due process rights by instructing Jones to answer whether he signed a particular document after viewing the exemplar; and (3) the Court did not reach the merits of Jones’s argument that the district court erred by giving jury instruction 13 since Jones failed to object to the instruction below. Thus, the Court affirmed in part, reversed in part and remanded the case for further proceedings. View "Safaris Unlimited v. Jones" on Justia Law

Ibrahim and Halida Ekic (the Ekics) and the estate of Aldina Ekic appealed district court decisions to grant summary judgment to Geico Indemnity Company (Geico) on their claims of breach of contract, misrepresentations in the inducement, breach of the duty of good faith and fair dealing, and promissory estoppel and to award attorney fees to Geico. Aldina was killed in an automobile accident caused by the negligence of a third party. The Ekics recovered the total policy proceeds of $25,000 from the third party’s insurance carrier. The Ekics demanded payment from Geico for the payment of $25,000 under Aldina’s underinsured motorist policy. Geico refused to issue a payment under the language of the policy. The Ekics filed suit. Sometime after Geico filed an answer, Geico filed a motion for summary judgment with a supporting affidavit from Geico’s counsel that included a copy of the Ekics’ answers to several interrogatories, a copy of Aldina’s Geico policy, and the vehicle collision report for the accident involving Aldina and the third party. The district court granted summary judgment for Geico on each of these claims. The Ekics then amended their complaint, with the permission of the district court, to add the additional claim of promissory estoppel and Geico filed an amended answer. Counsel for Geico advised the district court during a scheduling conference that Geico would be filing a motion for summary judgment on the additional claim. At the hearing, the district court granted Geico’s motion for summary judgment because the court found that “even viewing all the facts in light most favorable to the Plaintiff, there was no admissible evidence to support” their claim. The Ekics filed a motion to set aside the judgment which was denied by the district court. Geico requested attorney fees and the district court awarded them pursuant to Idaho Code section 41- 1839(4). The Ekics argued the district court erred in granting summary judgment in favor of Geico, but finding no such error, the Idaho Supreme Court affirmed the district court's judgments. View "Ekic v. Geico" on Justia Law