Charles R. Donaldson

The case involved a dispute over payment for trucking services provided by Davidson to Beco Corp., where Beco raised an accord and satisfaction defense based on an alleged agreement to transfer a tractor in lieu of the remaining debt. At trial, Davidson sought to impeach Beco's president with a statement from a settlement offer letter indicating that a prior offer had been refused, which conflicted with the president's testimony. The Supreme Court of Idaho held that statements from settlement negotiations may be admitted for impeachment purposes under I.R.E. 408 when offered for a purpose other than proving liability or the amount of a claim, provided the trial court determines that the probative value outweighs the prejudicial effect. The court concluded that the trial judge properly admitted the evidence after balancing these factors, reversing the judgment only on unrelated issues regarding corporate liability and attorney fees as decided by the Court of Appeals.

procedure

This case involved a legal malpractice claim brought by plaintiffs against their former attorney, Lloyd Walker, alleging failures in handling an earlier antitrust counterclaim, including not responding to interrogatories and not filing an appeal. On the first day of trial, after the plaintiffs' sole expert witness on breach of duty declined to testify, the trial court dismissed the case with prejudice, finding no valid excuse or compelling circumstances and noting the plaintiffs' lack of a prima facie case without expert testimony. The court later denied relief under Idaho Rule of Civil Procedure 60(b). On appeal, the Idaho Supreme Court affirmed the dismissal, holding that the trial court did not abuse its discretion given the plaintiffs' failure to prepare their expert, comply with pretrial orders, and exercise diligence, while recognizing the court's inherent authority to dismiss for want of prosecution and to enforce scheduling orders to ensure efficient case management.

proceduretorts & liability

This case was a medical malpractice lawsuit in which plaintiff Larry Rook sued defendant Dr. Eugene Trout after a first rib resection surgery for thoracic outlet syndrome failed to help and instead caused permanent nerve damage and increased pain. Rook claimed the doctor failed to inform him of the specific risks to the long thoracic nerve and of non-surgical alternatives such as exercise or anti-inflammatory drugs. The district court granted summary judgment for the defendant, but the Idaho Supreme Court reversed and remanded, concluding that a genuine issue of material fact remained on whether informed consent had been given. The decision rested on the patient's affidavit denying any discussion of risks or alternatives, the doctor's uncertain deposition testimony, and the requirements of Idaho's informed consent statutes, even though a consent form had been signed.

torts & liabilityhealthcare

The case involved Roy Peone, an employee of logging contractor Haynes Logging, who was injured by a falling tree while performing work under a contract with Regulus Stud Mills and became a paraplegic. Peone sued Regulus in federal court alleging negligence in hiring an incompetent contractor and vicarious liability for the contractor's failure to take safety precautions, based on exceptions in Restatement (Second) of Torts §§ 413 and 416 for inherently dangerous work. The U.S. District Court granted summary judgment to Regulus, and the Ninth Circuit certified the question of whether those Restatement sections create liability under Idaho law to the contractor's employees. The Idaho Supreme Court held that §§ 413 and 416 do not apply to employees of the independent contractor, as those provisions address risks to the general public rather than the contractor's own workers, who are protected by workers' compensation instead.

torts & liabilitylabor & employment

This case involved the suspension of Monty W. Griffiths' driver's license after he refused a blood test following his arrest for driving under the influence. The Idaho Supreme Court addressed multiple issues raised by the defendant, including the authority of officers to request the test, probable cause, proper advisements, whether his refusal was valid, and whether fear of needles could justify refusal. The court affirmed the suspension but vacated the magistrate's ruling that fear of needles could not, as a matter of law, constitute cause for refusal, allowing that issue to be reconsidered on its facts.

criminal lawprocedure

This case involves a workers' compensation claim by Patricia Vernon against her employer Omark Industries and the State Insurance Fund for a herniated disk injury she attributed to lifting heavy wooden trays over several days in June 1983. The Industrial Commission denied benefits, concluding in a single sentence that Vernon had not met her burden to prove the injury arose out of and in the course of employment. On appeal, the Idaho Supreme Court vacated the decision and remanded, holding that the Commission failed to explain the factual findings, credibility determinations, or legal standard applied, preventing meaningful review. The Court noted that workers' compensation law must be liberally construed to provide relief for injured workers and emphasized the need for the Commission to articulate its reasoning, particularly in cases involving gradual-onset injuries without a single identifiable incident.

labor & employmentprocedure