Justia Constitutional Law Opinion Summaries

This was an action brought by the grantor of a deed of trust to stop nonjudicial foreclosure proceedings based upon the contention that MERS, the Mortgage Electronic Registration Systems, which was the named beneficiary as nominee for the lender, could not legally act as the beneficiary. The defendants moved to dismiss this action on the ground that the complaint did not state a claim upon which relief could be granted. The district court agreed and entered judgment in favor of the defendants. Upon review, the Supreme Court affirmed the district court's judgment. View "Edwards v. MERS" on Justia Law

In 2011, Administrative District Judge Nye issued an Administrative Order Declaring Petitioner Holli Telford a Vexatious Litigant. At the time the pre-filing order was issued, there were no proceedings before Judge Nye to which Telford was a party. Judge Nye issued the pre-filing order after receiving requests from several district court and magistrate judges. The pre-filing order declared Telford a vexatious litigant on the basis that she "has previously been declared to be a vexatious litigant by any federal court of record in any action or proceeding." Telford had been declared vexatious by Utah, Texas, the Federal Ninth Circuit Court of Appeals, the Federal District Court of Idaho, the Federal District Court of Montana, and the United States Supreme Court. The pre-filing order also found Telford to be a vexatious litigant on the additional basis that she has commenced in Idaho three or more pro se litigations that were determined adversely to her in the past seven years. Telford was then served the pre-filing order. On appeal, Telford challenged the order deeming her a vexatious litigant, including attacking the merits of cases underlying the declarations of the other jurisdictions. Upon review, the Idaho Supreme Court found no abuse of discretion, and affirmed Judge Nye's pre-filing order. View "Telford v. Nye" on Justia Law

In 2007, Employers Mutual Casualty Company (EMC) brought a declaratory judgment action against the Donnellys and Rimar Construction, Inc. (RMI) to establish that under its policy of insurance with RCI, EMC had no duty or responsibility to pay damages claimed by the Donnellys in litigation between the Donnellys and RCI. The declaratory judgment action was stayed until a verdict was reached in the underlying action. In the underlying action, the Donnellys were awarded damages, costs and attorney fees against RCI. Subsequently the district court entered summary judgment in the declaratory action, finding that there was no insurance coverage for the damages the Donnellys incurred, but that there was coverage for costs and attorney fees. On appeal, EMC argued that the district court erred in its determination that it had a duty to pay attorney fees and costs when there were no damages awarded to the plaintiff subject to the policy coverage. The Donnellys cross appealed, arguing the district court erred in its conclusion that EMC did not have a duty to cover the damages in this case, and that the Donnellys were entitled to attorney fees. Upon review, the Supreme Court affirmed the district court's decision. View "Employers Mutual Casualty Co v. Donnelly" on Justia Law

Plaintiff-Appellant Larry Hansen was involved in an automobile accident with Defendant-Respondent Matthew Roberts. At trial, Plaintiff sought to recover damages for his injuries and Defendant sought to recover property damage for his vehicle. The jury found Plaintiff to be 90% at fault and awarded Defendant damages for his vehicle. Plaintiff appealed the district court's decision to allow Defendant's experts, an accident reconstructionist and a biomechanical engineer, to testify. Plaintiff also appealed the district court's ruling that he waived his objections to Defendant's deposition testimony. Finally, Plaintiff appealed the district court's decision to grant Defendant's motion in limine so far as it limited him from asking whether prospective jurors or one of their family members were or had ever been employed by an insurance carrier. Finding no abuse of the district court's discretion, the Supreme Court affirmed. View "Hansen v. Roberts" on Justia Law

The issue before the Supreme Court on appeal in this case related to attorney fees incurred in litigation arising from a construction contract for a custom cabin in Island Park, Idaho. There were two issues: (1) whether the district court erred in holding that the Maglebys were entitled to recover only $2,500 from defaulting parties by operation of I.R.C.P. 54(e)(4); and (2) whether the district court erred in its decision regarding the Maglebys' entitlement to post-judgment attorney fees. Upon review, the Supreme Court concluded that I.R.C.P. 54(e)(4) did not limit the Maglebys' fees to the $2,500 pled in their complaint even though defendants did not contest them. The Court vacated the judgments of the district court as they related to attorney fees awards in light of I.C. sec. 12-120(5) and "ITP" and "Jenks." The case was remanded for further proceedings. View "Magleby v. Garn" on Justia Law

Petitioner-Appellant Randall Bottum appealed a district court order which held that a 2009 amendment to the sex offender registration law applied to him. Prior to the amendment, Petitioner could have petitioned the court to be exempted, but the amendment foreclosed that opportunity. Upon review of the district court order, the Supreme Court found that the 2009 amendment applied to Petitioner and affirmed the district court order. View "Bottum v. Idaho State Police" on Justia Law

Pro se plaintiff Martin Bettwieser brought a breach of contract action against the New York Irrigation District and its directors (collectively, the District). Bettwieser alleged that the District breached an oral contract by not timely providing him with a legal opinion regarding whether he could be excluded from the irrigation district without paying statutory exclusion and filing fees. Following a bench trial, the district court issued findings of fact and conclusions of law, ruling that Bettwieser had failed to demonstrate that he was entitled to relief. Bettwieser appealed, alleging the district court made errors of fact and law during the trial and in its decisions regarding Bettwieser's pre- and post-trial motions. As a preliminary matter, the Supreme Court noted that Bettwieser's briefing was, "at best, difficult to follow. In some cases, it is unclear what issue Bettwieser is attempting to raise. And, even where an issue is identifiable, argument, authority, and legal reasoning are often absent." The Court concluded that the district court's findings of fact and conclusions of law were supported by substantial competent evidence. Bettwieser failed to satisfy the requirements for certification of a class action. The district court was not obligated to consider claims not raised by the pleadings. The district court did not abuse its discretion in denying Bettwieser's motion to disqualify counsel. Bettwieser was not entitled to declaratory judgment because he failed to demonstrate the existence of an actual or justiciable controversy. View "Bettwieser v. New York Irrigation Dist." on Justia Law

In 2011, the Idaho Department of Health and Welfare (the Department) initiated this action to terminate the parental rights of John Doe. The matter proceeded to trial where the magistrate court found that Doe had neglected and abandoned his minor child, D.C., and that it was in the best interest of the child that Doe's parental rights be terminated. Doe appealed and the Supreme Court affirmed: Doe failed to show that the magistrate erred in finding that he had abandoned D.C. "Even if the Department failed to implement the case plan in an appropriate fashion, the magistrate's finding of neglect was supported on a prong of neglect essentially independent of case plan performance. Doe has made no effort to show that it is not in the best interest of D.C. to terminate Doe's parental rights. There are no grounds to reverse the termination order." View "Health & Welfare v. Doe" on Justia Law

Michelle Anderson appealed the district court's denial of her motion to dismiss kidnapping charges brought against her for keeping the child she had with Ricky Anderson away. Michelle was obligated to deliver the child to Ricky under a parenting plan issued by a Montana court, but never completed the exchange. In her motion to dismiss, Michelle argued that Ricky is not a custodial parent under I.C. 18-4501 and therefore Michelle could not have committed kidnapping. The district court denied the motion, and the Supreme Court granted permission to appeal that decision. Upon review, the Supreme Court concluded that Ricky was a custodial parent for the purposes of IC 18-4501(2), and that Michelle could be charged with kidnapping based on Ricky's visitation rights that granted him lawful care and control of the child. Accordingly, the Court affirmed the district court's decision. View "Idaho v. Anderson" on Justia Law

Justin S. Reynolds, Kristine Reynolds, and their construction company, Sunrise Development, LLC (Reynolds) brought a malpractice action against their law firm, Trout Jones Gledhill Fuhrman, P.A., and its attorney-employee, David T. Krueck. Reynolds alleged professional negligence in both the drafting of a real estate agreement between Reynolds and Quasar Development, LLC, and in the subsequent handling of the litigation regarding that agreement. The district court granted summary judgment in favor of Trout Jones, holding that the two-year statute of limitations found in Idaho Code section 5-219(4) applied to bar the action and Reynolds timely appealed. Upon review of the matter, the Supreme Court affirmed. View "Reynolds v. Trout, Jones, Gledhill, Fuhrman, P.A." on Justia Law