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

The case involved a lawsuit by the Ransoms against Garden City after they were injured in a head-on collision with a vehicle driven by an intoxicated passenger who had been given the keys by a police officer. The officer had arrested the vehicle's owner for DUI, declined to impound the car under I.C. § 49-692, and left the keys with the passenger after instructing him not to drive. The trial court granted summary judgment to the city, ruling that the officer's actions fell within the discretionary function exception of the Idaho Tort Claims Act (I.C. § 6-904(1)). The Idaho Supreme Court reversed, holding that the decision was an operational act implementing policy rather than a planning or policy-formation decision, and therefore the city was not immune from liability under the planning/operational test established in Sterling v. Bloom.

torts & liability

Tusch Enterprises, a partnership, purchased residential duplexes from the Vander Boeghs that had been constructed by Coffin and later discovered major structural problems caused by settling due to fill dirt on the site. The buyers sued the sellers and builder on theories of negligence, misrepresentation, express warranty, and implied warranty of habitability. The Idaho Supreme Court reversed the district court's grant of summary judgment in favor of the defendants on the misrepresentation and implied warranty of habitability claims. The court reasoned that those theories could support recovery for the economic losses from the defects, distinguishing them from negligence claims for pure economic loss, and that the implied warranty of habitability extends to the suitability of the structures for living purposes in this context.

propertytorts & liability

The case involved a worker's compensation claim by Helen Mapusaga against her employer Red Lion Riverside Inn and the Industrial Special Indemnity Fund (ISIF) for total and permanent disability benefits after a back injury sustained while making beds, which combined with her pre-existing psychiatric disorder and an arm impairment from a prior self-inflicted gunshot wound. The Industrial Commission found Mapusaga totally and permanently disabled under the odd-lot doctrine, rated her impairments, and apportioned liability 29% to the employer/surety and 71% to the ISIF, treating the psychiatric issues as non-medical factors and the arm injury as a qualifying pre-existing physical impairment. On appeal, the Idaho Supreme Court affirmed in part, reversed in part, and remanded, interpreting I.C. § 72-332 to require a physical (anatomical) pre-existing impairment for ISIF threshold liability while allowing the psychiatric disorder to factor into the overall disability rating under I.C. § 72-430, and upholding the odd-lot finding based on the combined effects.

labor & employment

The case involved Eric Edmonson, who was indicted by a grand jury in Idaho on charges including racketeering, grand theft, conspiracy, and falsification of corporate records. He moved to dismiss the indictment, arguing that the prosecutor's unfettered discretion to proceed by indictment rather than information violated equal protection under the Idaho Constitution, that hearsay evidence and prosecutorial comments were improper, that unauthorized personnel were present, and that one of the statutes was unconstitutional. The district court denied the motions, and the Idaho Supreme Court affirmed. The court reasoned that the state constitution explicitly allows prosecutors to choose between grand jury indictment and information without mandating any systematic criteria or policy for the choice, and that the remaining statutory and constitutional challenges lacked merit based on the text of the relevant provisions and rules.

criminal lawprocedurecivil rights

In State v. Schaffer, Robert and Sara Schaffer were charged with manufacturing and possessing marijuana with intent to deliver under Idaho Code § 37-2732. Prior to trial, they moved to suppress evidence from a search warrant, to automatically disqualify the trial judge under I.C.R. 25(a), and to remove certain jurors for cause; the trial court denied these motions as untimely or without merit, and the jury convicted them. On appeal, the Idaho Supreme Court reversed and remanded, holding that the judge's disqualification motion was timely because the weight of the evidence showed the trial notice was mailed after October 25, 1983, rather than on the earlier certificate date, making denial of the motion erroneous under the rules governing service by mail. The court addressed additional claims regarding the search warrant, juror challenges, and discovery but focused its reversal on the disqualification issue.

criminal lawprocedure

The case concerned Westmont Tractor Co.'s efforts to collect a deficiency judgment on a debt for logging equipment after debtor Chris Westfall defaulted on payments and later died. Following Westfall's death, Westmont obtained a default judgment against him individually without substituting his personal representative as a party, then sought to amend the judgment nunc pro tunc to bind the estate for lien priority in probate proceedings. The district court granted the nunc pro tunc substitution, but the Idaho Supreme Court reversed and remanded, holding that the original judgment was entered as requested against Westfall personally and did not result from judicial error or oversight that could be corrected retroactively against the estate.

procedureproperty

This case involved a wrongful death lawsuit brought by the parents of 17-year-old Michael Walker against Shoshone County after he died by suicide while confined in the county jail under a protective custody order for mental health concerns. The district court granted summary judgment to the county based on immunity under the Idaho Tort Claims Act, I.C. § 6-904(1), while rejecting the county's statute of limitations defense. On appeal, the Idaho Supreme Court held that the six-month statute of limitations in I.C. § 5-221 does not apply to claims under the Tort Claims Act, which instead provides a two-year period, and that summary judgment on the immunity issue was improper because factual allegations of negligent supervision could not be resolved on the pleadings alone. The court reversed the judgment and remanded for further proceedings, addressing both defenses separately.

torts & liabilityprocedure

In Davis v. Moran, plaintiffs sued a doctor, hospital, and cancer clinic alleging that radiation therapy in early 1982 caused later spinal cord damage that manifested as leg spasms and pain in 1983, with the precise cause identified in August 1983. The district court granted summary judgment for defendants on the ground that the suit was time-barred under the two-year professional malpractice statute of limitations, Idaho Code § 5-219(4). The Idaho Supreme Court reviewed whether the specific three-year limitations period for ionizing radiation injuries in § 5-243 should apply instead, but observed that § 5-242 expressly excludes malpractice actions from that provision following the legislature's 1976 amendment responding to Arnold v. Woolley. The court analyzed the resulting statutory classification under equal protection principles to assess whether it rested on a reasonable basis.

healthcareproceduretorts & liability

This case is a divorce proceeding concerning an award of temporary spousal maintenance under I.C. § 32-705 to allow the wife to pursue a college degree. The magistrate awarded maintenance to the wife, and the district court affirmed, but the Idaho Supreme Court vacated the judgment and remanded for additional findings. The court interpreted the statute to permit maintenance only when the innocent spouse lacks sufficient property and cannot support herself through employment that meets her reasonable needs, after considering all relevant factors such as the duration of the marriage and time required for education; it found the magistrate's findings inconsistent on whether the wife's existing clerical skills would suffice and therefore required further analysis before determining the award.

family law

This case involved a divorced father's request to modify child support payments after his ex-wife remarried, arguing her new husband's income constituted a substantial change in circumstances. The Idaho Supreme Court affirmed the district court's ruling that the trial court must consider the financial resources of the new marital community under community property laws when evaluating support modifications, as required by state statutes. The court reasoned that in Idaho, income earned during marriage is community property shared equally, so both parents' resources, including new spouses' contributions, are relevant factors. It also reversed the award of attorney fees to the mother, finding the proceedings were not vexatious, and remanded for further consideration on fees.

family lawproperty

This case involved the termination of John Stanley Dayley's parental rights to his young daughter Alena after the Idaho Department of Health and Welfare petitioned the court under state law allowing termination for reasons including abandonment or neglect. The father appealed the magistrate's termination order, arguing violations of due process due to the petition's failure to specify statutory grounds, insufficient evidence, and the lack of appointed counsel for the child. The Idaho Supreme Court affirmed the termination, holding that although the petition was imprecise, the hearing evidence established neglect through the father's failure to maintain stable support and contact amid repeated incarcerations and instability. The court reasoned that clear and convincing evidence showed both neglect and the unlikelihood of family reunification given the father's decade-long pattern of irresponsible behavior.

family law

The case involved consolidated actions concerning ownership of real property originally held by Oscar Rogstad: one by his estate's personal representative seeking to establish that his son Kenneth and daughter-in-law Doryne held certain parcels in trust and to obtain an accounting of sale proceeds, and another by Oscar's former wife Helen Keller to quiet title to parcels conveyed to her. The district court quieted title in Helen's favor for her share and ruled that Kenneth and Doryne were trustees for Oscar, requiring them to account to the estate. On appeal, the Idaho Supreme Court affirmed, concluding that the March 1970 warranty deed was void, that Kenneth was estopped by a prior quiet-title judgment from relying on the April 1972 quitclaim deed, and that a resulting trust arose in favor of Oscar's estate because the trust instrument failed to dispose of the entire beneficial interest; title to unsold parcels was therefore quieted in the estate and Kenneth was ordered to account for retained proceeds. The court also awarded attorney fees to the respondents under Idaho law.

propertyfamily lawprocedure

This case arose from a conflict between Nez Perce County District Court Clerk Donna Crooks and Administrative District Judge John Maynard over the judge's authority to supervise deputy clerks performing judicial functions. Crooks petitioned the Idaho Supreme Court for a writ of prohibition to block Maynard's administrative orders restricting a newly hired deputy and his contempt finding against her and the deputy. The court, following a masters' hearing and recommendation, denied the writ. It held that the April 23 order had been rescinded and thus moot, that the judge possessed supervisory authority over judicial functions of court clerks under statutes and inherent judicial power, and that a writ of prohibition was not warranted to restrain the judge from enforcing proper administrative orders in this area.

procedure

The case involved a developer, Intermountain West, that obtained county permits and began constructing an apartment complex on land outside Boise city limits in 1974, only for the City to annex the property and issue stop-work orders for lack of a city building permit. After the developer obtained a court order lifting the orders and prevailed on appeal in 1977 on vested rights grounds, it filed a 1978 notice of claim and 1979 lawsuit seeking damages for delay and lost income under tort and inverse condemnation theories. The district court granted summary judgment to the City, and the Idaho Supreme Court affirmed, holding that the tort claim was untimely because the cause of action accrued no later than September 1975 when the stop-work orders were lifted, missing the 120-day filing deadline under I.C. § 6-906, and that the inverse condemnation claim was barred by the four-year statute of limitations under I.C. § 5-224 as well as by the absence of a compensable taking given residual property value. The court rejected arguments that the City's appeal created a continuing wrong or that the actions amounted to a regulatory taking.

propertyproceduretorts & liability