Justia Constitutional Law Opinion Summaries

The issue in this case came from an appeal of a decision of the Industrial Commission which found that claimant Joseph Henry failed to prove that the heart attack he suffered while at work was an industrial accident because his cardiologist could not determine whether the plaque rupture that caused the heart attack was triggered by events occurring before or after the claimant arrived at work. Upon review, the Supreme Court held that the Commission’s findings of fact were not clearly erroneous and affirmed its order denying compensation. View "Henry v. Dept of Corrections" on Justia Law

The issue before the Supreme Court in this case arose from a commercial lease dispute. Boise Mode, LLC leased space in its building to Donahoe Pace & Partners, Ltd. (DPP). Timothy Pace executed a personal guarantee for the lease. During the term of the lease, Boise Mode remodeled part of the building for another tenant. After raising concerns to Boise Mode about the adverse effects of the construction to its business, DPP eventually stopped paying rent and vacated the premises prior to the end of the lease. Boise Mode then brought an action against DPP, alleging breach of contract, and against Pace for breaching the guarantee. DPP counterclaimed, alleging that the disruption caused by the construction constituted breach of contract and constructive eviction. After Boise Mode moved for summary judgment on all claims and counterclaims, DPP requested a continuance to complete discovery. The district court denied DPP's motion and ultimately granted Boise Mode's motion for summary judgment. DPP appealed the grant of summary judgment as well as the district court's denial of its request for a continuance. Upon review, and finding no error, the Supreme Court affirmed. View "Boise Mode, LLC v. Donahoe Pace" on Justia Law

A bail bond company challenged the district court's decision affirming an order of the Director of the Idaho Department of Insurance. That order, which was based on I.C. 41-1042, prohibited a bail bond company from contemporaneously writing a bail bond and contracting with a client to indemnify the company for the cost of apprehending a bail jumper. It also prohibited a bail bond company from later requiring a client to agree to such indemnification as a condition of the bond's continuing validity. While the proceedings before the district court were pending, the Director promulgated I.D.A.P.A. 18.01.04.016.02, which by rule expressed the Final Order. Upon review of the applicable statutory authority and the trial court record below, the Supreme Court concluded that: (1) the plain text of I.C. 41-1042 permits a bail bond company to contemporaneously write a bail bond and contract with a client to indemnify the company for the cost of apprehending a defendant who jumps bail; and (2) the Director's interpretation of I.C. 41-1042 prejudiced PetitionerTwo Jinn's substantial rights. The Court reversed the district court's memorandum decision and remanded the case for further review. View "Two Jinn, Inc. v. Idaho Dept of Insurance" on Justia Law

Appellant Camas County appealed an injunction granted by the district court against the enforcement of Camas County Ordinances 150 and 153, and Resolutions 96 and 103 (2007 zoning amendments). Plaintiff-Respondent George Martin opposed the zoning amendments at a public hearing of the Camas County Board of Commissioners. In late 2008 while this case was still being adjudicated, Martin filed a complaint for declaratory judgment against 2008 zoning amendments. Camas County removed the case to the federal district court, which ultimately granted Martin's requested relief to the 2007 amendments. The federal district court then remanded the case to the state district court. Martin was granted attorney fees and costs as a result of the federal district court's order; the court held that Camas County acted without a reasonable basis in fact or law. Camas County appealed, maintaining that the district court abused its discretion in ordering the injunction and should have awarded the County attorney fees. Upon review, the Supreme Court found that the 2007 and 2008 zoning amendments were practically identical. Both cases involved the same property owned by Martin in Camas County. Thus, the facts between this case and the underlying case "Martin I" (concerning the 2007 amendments) were nearly identical. . . . as such, Martin properly conceded that the district court's injunction against the 2007 zoning amendments should have been reversed. Martin also properly conceded that his award of attorney fees by the district court also should have been reversed. The County was not entitled to a fee award. View "Martin v. Smith" on Justia Law

Plaintiff-Appellant Jerry Doherty appealed a district court order that dismissed him as a party in the medical malpractice action against respondents Dr. Gordon Dixon and Blackfoot Medical Clinic. The district court, on September 16, 2010, ruled that because Doherty failed to disclose this claim as an asset in his Chapter 13 bankruptcy proceeding, he was judicially estopped from pursuing this claim against Respondents. The district court further ordered that Doherty take nothing from Respondents, and that the bankruptcy trustee be substituted as the party-plaintiff. On appeal, Plaintiff argued that the district court abused its discretion in granting summary judgment. Finding no abuse of discretion, the Supreme Court affirmed. View "McCallister v. Dixon" on Justia Law

Appellant Habib Sadid, a former tenured professor of civil engineering at Idaho State University, appealed an Industrial Commission Order that reversed the Department of Labor Appeals Examiner's grant of unemployment benefits to Appellant after he was terminated by Idaho State University. Upon review, the Supreme Court concluded that the Commission's finding of misconduct was supported by substantial and competent evidence. As such, the Court affirmed the Industrial Commission's order. View "Sadid v. Idaho State University" on Justia Law

The Idaho Supreme Court was asked in a certified question of law from the United States District Court for the District of Idaho whether a legal malpractice claim that is transferred to an assignee in a commercial transaction, along with other business assets and liabilities, is assignable. The question arose from a a wrongful termination and False Claims Act action brought by former hospital employees against their employer. Magic Valley Medical Center was the entity being sued. Twin Falls County owned Magic Valley. Twin Falls County (on behalf of itself and Magic Valley), Twin Falls Health Initiatives Trust, Ltd. (TFHIT), and St. Luke’s Health System, Ltd., St. Luke’s Regional Medical Center, Ltd., and St. Luke’s Magic Valley Regional Medical Center (St. Luke's) entered into a Sale and Lease Agreement for the Creation of a New Health System (Agreement). The sale closed, and St. Luke's carried the burden of the employee litigation, ultimately settling with the plaintiffs. After the transaction closed, Magic Valley no longer existed. Though technically not a merger, the operation and management of the center was taken over by St. Luke's. St. Luke's then sued Magic Valley's former legal counsel for legal malpractice in connection with the employee litigation. The firm moved for summary judgment, arguing that St. Luke's could not pursue a malpractice claim because the purported assignment of such a claim was invalid in Idaho as a matter of law. Upon review, the Idaho Supreme Court answered the district court's certified question in the affirmative: although legal malpractice claims are generally not assignable in Idaho, where the legal malpractice claim is transferred to an assignee in a commercial transaction, along with other business assets and liabilities, such a claim is assignable. View "RE: Order Certifying Question - St. Lukes Magic Valley RMC v. Luciani, et al." 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

The issue in this case came from an appeal of a decision of the Industrial Commission which found that claimant Joseph Henry failed to prove that the heart attack he suffered while at work was an industrial accident because his cardiologist could not determine whether the plaque rupture that caused the heart attack was triggered by events occurring before or after the claimant arrived at work. Upon review, the Supreme Court held that the Commission’s findings of fact were not clearly erroneous and affirmed its order denying compensation. View "Henry v. Dept of Corrections" on Justia Law

A bail bond company challenged the district court's decision affirming an order of the Director of the Idaho Department of Insurance. That order, which was based on I.C. 41-1042, prohibited a bail bond company from contemporaneously writing a bail bond and contracting with a client to indemnify the company for the cost of apprehending a bail jumper. It also prohibited a bail bond company from later requiring a client to agree to such indemnification as a condition of the bond's continuing validity. While the proceedings before the district court were pending, the Director promulgated I.D.A.P.A. 18.01.04.016.02, which by rule expressed the Final Order. Upon review of the applicable statutory authority and the trial court record below, the Supreme Court concluded that: (1) the plain text of I.C. 41-1042 permits a bail bond company to contemporaneously write a bail bond and contract with a client to indemnify the company for the cost of apprehending a defendant who jumps bail; and (2) the Director's interpretation of I.C. 41-1042 prejudiced PetitionerTwo Jinn's substantial rights. The Court reversed the district court's memorandum decision and remanded the case for further review. View "Two Jinn, Inc. v. Idaho Dept of Insurance" on Justia Law