Gerald F. Schroeder

The case involved Joey Pierce, a roofer injured while working on a school district project for a subcontractor without workers' compensation insurance, who sought benefits from the school district as his statutory employer. The Industrial Commission denied the claim, determining that the school district did not qualify as a statutory employer under Idaho law. The Idaho Supreme Court affirmed this decision, reasoning that the work performed pertained to the business of the direct employer rather than the school district's operations, applying the virtual proprietor test for category two statutory employers as presented by the parties.

labor & employment

The case involved a dispute over loans made by Vanderford Co. for a real estate development project by Pines Townhomes, LLC, where Vanderford sought to recover approximately $500,000 and foreclose on trust deeds signed by the Greifs, amid competing claims of contracts, unjust enrichment, and lien issues between Vanderford, the Greifs, and Knudson following a jury trial. The Idaho Supreme Court held that Vanderford could not foreclose because the notes lacked language granting real property as collateral, upheld the jury's unjust enrichment award to Knudson against the Greifs, and remanded for a new trial on issues including breach of contract, fraudulent conveyance, and oral agreements due to errors in jury instructions. The court also vacated certain verdicts and attorney fee awards pending the outcome on remand, reasoning that the instructions were supported by evidence and law but incomplete, the foreclosure was barred by the document terms, and prevailing party status could not yet be determined.

business & regulatorypropertyprocedure

This case concerns the termination of John Doe's parental rights to his child, who had been placed in foster care after testing positive for drugs at birth; the mother later relinquished her rights, and Doe was identified as the father through DNA testing and given a case plan to regain custody. The magistrate court terminated Doe's rights on grounds of abuse and neglect, applying a presumption under Idaho Code § 16-1629(9) that termination was in the child's best interest after the child had spent 15 of 22 months in state custody, and the district court affirmed. The Idaho Supreme Court vacated the termination order and remanded the case, ruling that the magistrate court had used the wrong legal standard by improperly shifting the burden to Doe to rebut termination rather than requiring the state to prove its allegations by clear and convincing evidence. This approach violated due process requirements from Santosky v. Kramer and Idaho's traditional presumption favoring custody by natural parents. The court held that the statute creates only a presumption for initiating termination proceedings, not for finding termination to be in the child's best interest.

family lawcivil rights

In State v. Smith, the defendant was charged with manufacturing marijuana after police discovered a growing plant during a search of his apartment. The district court suppressed the evidence, ruling that the initial warrantless entries were unjustified after any exigency ended and that the defendant's consent to the search was involuntary. The Idaho Supreme Court reversed, holding that the first firefighter's entry was justified by exigent circumstances from the reported fire, the subsequent police entry was a valid continuation, and the consent was voluntary because officers had probable cause for a warrant and merely explained the options without coercion or false threats. The core reasoning focused on the limited scope of the fire investigation entries and the distinction between valid warnings about obtaining a warrant and improper pressure.

criminal lawprocedure

The case concerned whether Ada County Commissioners violated Idaho's open meeting law (I.C. § 67-2345) by entering an executive session without legal counsel present to discuss strained relations with Boise City that might lead to future litigation, and whether an untranscribed audio recording of the vote to enter the session satisfied the statute's minutes requirement. The State sued for a declaratory judgment and civil penalties, while the Commissioners counterclaimed for an interpretation of the litigation exception. The Idaho Supreme Court affirmed in part, reversed in part, and remanded, holding that the former litigation exception applied only to meetings with legal counsel based on legislative history showing intent to protect attorney-client communications, that an audio recording did not meet the written minutes requirement, and that violations require proof of specific intent for penalties to apply.

procedure

This case concerned the termination of Jane Doe's parental rights to her child by the Idaho Department of Health and Welfare. The magistrate court terminated her rights after finding by clear and convincing evidence that she had neglected the child due to her mental illness, which prevented her from fulfilling parental responsibilities, and that she failed to complete key tasks in her court-approved case plan, such as attending parenting classes, substance abuse education, and following mental health recommendations. The district court affirmed, and the Idaho Supreme Court upheld the decision, holding that substantial competent evidence supported the findings regarding neglect, the impact of her mental health conditions, and the child's best interests.

family law

In Doe v. City of Elk River, the plaintiffs sued the City of Elk River on behalf of two minor children who were sexually assaulted by a fourteen-year-old in an unlocked city storage shed, claiming the city was liable under the doctrine of attractive nuisance for negligently maintaining the premises. The district court granted summary judgment to the city, and the Idaho Supreme Court affirmed. The court held that the claim failed because the shed itself posed no inherent danger or unusual attraction to children, the danger was not concealed from immature minds in the required sense, and the children were lured to the location by the assailant rather than by any condition on the property. The decision rested on the established four-element test for attractive nuisance claims under Idaho law, with no material facts in dispute.

torts & liability

Taya Hope Grazian was convicted of three counts of attempted procurement of prostitution and two counts of procurement of prostitution arising from her role managing an adult entertainment referral business where entertainers sometimes engaged in illegal sexual contact during tip sessions. The Idaho Supreme Court affirmed the convictions in full, holding that the general attempt statute could be combined with the procurement of prostitution statute to criminalize attempted procurement despite the 1994 repeal of attempt-specific language in the procurement statute. The court further ruled that evidentiary decisions were proper, the charges were appropriately joined as part of a common scheme, and no other trial errors warranted reversal.

criminal lawprocedure

This case is a quiet title action concerning a triangular parcel of real property in Bonner County, Idaho. The Kieberts filed suit claiming record ownership or title by adverse possession, but the Quirins answered asserting their own ownership and moved for summary judgment. The district court treated the Quirins' answer as a counterclaim under Idaho procedural rules and granted summary judgment quieting title in their favor after finding the Kieberts had disavowed any interest in the parcel and presented no genuine issue of material fact. On appeal, the Idaho Supreme Court affirmed, holding that a party seeking to quiet title must succeed on the strength of its own title and that the Kieberts lacked standing to challenge the judgment. The court also upheld the award of attorney fees to the Quirins both at trial and on appeal under I.C. § 12-121.

propertyprocedure

This case arose from an accident at Bogus Basin ski area in which Helga Withers fell and was injured after her ski became entangled in a rope that employees had placed near a chairlift unloading ramp to direct passengers. Withers sued the ski operator for negligence, but the district court granted summary judgment to Bogus Basin. The Idaho Supreme Court affirmed, holding that the Ski Area Liability Act (I.C. §§ 6-1101 et seq.) bars recovery because the rope addressed an inherent risk of skiing under I.C. § 6-1103(10) and the operator's duties are limited to those expressly set forth in §§ 6-1103 and 6-1104. The Court further found no causal violation of the chairlift safety standards in § 6-1104, as the hazard stemmed from the rope itself rather than the lift's construction, operation, or maintenance. The decision rests on statutory interpretation limiting ski-area liability to the enumerated duties and recognizing skier assumption of inherent risks.

torts & liability

In State v. Lewis, the State appealed the district court's suppression of evidence regarding the defendant's alleged confession to possessing methamphetamine, which was granted because police lost audio recordings of the traffic stop and interrogation. The Supreme Court of Idaho reversed the district court, holding that the loss of the recordings did not violate the defendant's due process rights. The court reasoned that the exculpatory value of the recordings was unknown and that the officer had not acted in bad faith, as the loss was inadvertent and not a calculated effort to circumvent disclosure. It also rejected arguments for a new rule requiring all custodial confessions to be recorded, either under the Idaho Constitution or the court's supervisory powers, consistent with prior precedent. The decision directly reviewed and overturned the trial court's findings on constitutional requirements.

criminal lawprocedurecivil rights

The case involved the Idaho State Police's civil forfeiture action under I.C. § 37-2744A against real property and a mobile home owned by Eunice Bautista, where her ex-husband had been found in possession of controlled substances. After neither party responded to the complaint, the district court entered a default judgment forfeiting the property. Bautista later moved under I.R.C.P. 60(b) to set aside the default, asserting excusable neglect because she believed counsel had been retained, but the district court denied the motion on the ground that she had not pleaded facts constituting a meritorious defense. The Idaho Supreme Court affirmed, holding that while mistake or excusable neglect was shown, the absence of any defense pleading meant the district court did not abuse its discretion in refusing relief.

criminal lawpropertyprocedure

Hopper v. Hopper involved a child custody dispute arising from the divorce of Christopher and Suzanne Hopper, who had one infant son. After Suzanne secretly relocated with the child from Idaho to Montana and filed a false domestic violence claim there, the case proceeded in Idaho; the magistrate court awarded sole legal and physical custody to Suzanne, citing the child's need for stability with his primary caregiver and the impracticality of joint custody due to distance. The Idaho Supreme Court vacated the district court's decision and remanded the case, determining that the lower court had not adequately considered the impact of the mother's misconduct or properly applied the presumption favoring joint custody. The majority emphasized that both parents' conduct and the child's best interests required reevaluation without deference to the initial temporary orders. A dissent argued that the magistrate had properly weighed the evidence and that the remand would disrupt the child's established living situation.

family law

This case concerned ownership of water rights in the Snake River Basin Adjudication, pitting the United States Bureau of Reclamation against multiple irrigation districts and companies. The SRBA court held that the United States possesses only nominal legal title while the irrigation entities hold equitable title in trust for their landowners, and it denied requests to list specific user identities and quantities in the decree. The Idaho Supreme Court affirmed those rulings in part, reasoning that the rights derive from state law based on appropriation and beneficial use rather than solely from federal contracts, and that the Boise Project had operated effectively for decades without the additional specificity. It remanded in part for the lower court to substitute a different remark in the decree regarding administration.

propertyfederal power

This case involved a medical malpractice claim by the Weeks family against Eastern Idaho Regional Medical Center after Evelyn Weeks suffered harm when medications intended for intravenous use were mistakenly infused into her brain catheter. The hospital admitted the nursing error breached the standard of care, leaving causation and damages as the key issues. The district court granted summary judgment for the hospital, ruling that the plaintiffs' expert witness, a neurosurgeon, was not qualified to testify on causation. On appeal, the Idaho Supreme Court reversed, holding that the expert's testimony on the mechanical and chemical effects of the infusion was admissible under Idaho Rule of Evidence 702, as it was based on his qualifications and sound scientific principles, including differential diagnosis where necessary.

torts & liabilityhealthcare

This case involved the Idaho Lottery Commission's revocation of bingo licenses held by two nonprofit organizations, Sons & Daughters of Idaho and USA Boxing Snake River, due to alleged violations of state bingo laws. The organizations operated bingo games at a facility rented from a for-profit company owned by individuals who also served on the organizations' bingo committees, and they failed to provide certain financial records during an inspection. The Supreme Court of Idaho affirmed the revocations, holding that the arrangements violated prohibitions on indirect compensation to officers and directors and on contracting with outsiders to conduct bingo games, as well as record-keeping requirements under the statutes. The court also rejected constitutional challenges to the relevant statutes regarding vagueness and subject-title unity.

business & regulatoryprocedure

This case involved a worker's compensation claim by John Wichterman against his employer J.H. Kelly, Inc., and its surety, seeking benefits for alleged respiratory and gastrointestinal injuries from two incidents of exposure to hazardous substances in September 1998 while working as a pipe fitter. The Industrial Commission denied the claim, finding that the request for additional income benefits was time-barred under Idaho Code § 72-706 and that Wichterman failed to prove his ongoing impairments were caused by the workplace exposures. The Idaho Supreme Court affirmed the denial, holding that the claim was properly barred by the five-year limitation period since payments had been discontinued within four years of the accident, and that substantial evidence supported the finding of no causal link between the exposures and the claimed conditions.

labor & employmentprocedure

In State v. Heredia, the defendant pled guilty to misdemeanor vehicular manslaughter after a fatal car accident but was not advised before the plea that he could be ordered to pay child support for the victim's minor children under Idaho Code § 18-4007(3)(d). The magistrate court imposed child support at sentencing along with other penalties and later denied Heredia's post-sentencing motion to withdraw the plea, finding the obligation was a collateral consequence and that manifest injustice had not been shown. The district court reversed, and the Idaho Supreme Court affirmed that reversal, holding that child support is a direct consequence that must be disclosed to ensure a guilty plea is entered voluntarily, knowingly, and intelligently under due process standards and I.C.R. 11. The Court noted the record lacked any pre-plea advisement of this penalty, so the plea did not meet constitutional requirements and Heredia could withdraw it.

criminal lawfamily lawprocedure

The case was a contract dispute between Clear Lakes Trout Co., a fish hatchery, and Rodney and Carla Griffith, trout growers, over an agreement in which Griffith would buy small trout from Clear Lakes and sell them back once grown to "market size," with the contract running from 1998 to 2004 (later extended). The district court interpreted "market size" as fish approximating one pound live weight, found that Clear Lakes breached by delaying and reducing acceptances after market changes in 2001, and awarded Griffith damages for increased production costs and mortality losses in years four and five while denying further lost-profit claims as speculative. On appeal, the Idaho Supreme Court affirmed the contract interpretation, breach finding, and partial damages award, but vacated the denial of damages for the remaining contract years and remanded for recalculation, reasoning that the breach deprived Griffith of the opportunity to complete performance under an output contract where quantities could be determined in good faith; the court also affirmed the award of attorney fees to Griffith as the prevailing party.

business & regulatory

The case involved the Abells, through their corporation Country Cove, suing the Mays (sister and brother-in-law) to rescind a 1993 contract in which the Abells bought out the Mays' interest in a motel partnership, claiming duress from threats and a false suicide statement, fraud, and breach of fiduciary duty. The district court granted summary judgment to the Mays, finding no valid duress or fraud claim (the latter also time-barred), that the written contract controlled under the parol evidence rule, and no ongoing fiduciary duty after the partnership ended. The Idaho Supreme Court affirmed, holding that the Abells ratified the contract, the fraud claim was untimely, and the parties became debtor-creditors with no fiduciary relationship based on kinship or post-agreement dealings. The court also awarded attorney fees to the Mays under the contract.

business & regulatorypropertyprocedure