Allan G. Shepard

The case involved Bon Appetit Gourmet Foods challenging a requirement to pay unemployment compensation taxes on its door-to-door sales agents, who were independent contractors but classified as covered employees under Idaho statute I.C. § 72-1316(d)(2) because they distributed food products. The Industrial Commission upheld the tax obligation despite finding the agents to be independent contractors. The Idaho Supreme Court reversed, holding the statute unconstitutional under equal protection clauses because it arbitrarily singled out certain types of door-to-door distributors for employee status without a rational basis related to a legitimate government purpose.

labor & employmenttaxesbusiness & regulatorycivil rights

The case involves a workers' compensation claim by Paul E. Frank against his employer, The Bunker Hill Company, following a severe injury in a mining accident in 1980 that caused multiple fractures and long-term impairments. The Industrial Commission initially awarded Frank total and permanent disability benefits after classifying him as an odd-lot worker unable to find employment, but modified the award to 55 percent total permanent disability (35 percent whole-man impairment plus 20 percent for non-medical factors) following the employer's petitions for rehearing and modification alleging fraud, manifest injustice, and other issues. The Idaho Supreme Court affirmed the modified award, holding that the Commission properly evaluated conflicting evidence on the claimant's physical condition, employability, and lack of interest in retraining, and that no procedural errors required reversal.

labor & employmentprocedure

The case involved plaintiffs Zehm, who joined a nonprofit logging contractors association solely to access its optional group health insurance plan, suing the association after a carrier change resulted in their denial of coverage due to preexisting medical conditions; they claimed breach of fiduciary duty through inadequate notice of the change, failure to maintain comparable benefits, and self-interested decision-making. The Idaho Supreme Court affirmed the trial court's grant of summary judgment to the defendant association. The court assumed arguendo that a fiduciary duty existed but held that the Zehms failed to present evidence contradicting the association's showing that the carrier switch was driven solely by member cost concerns with no financial benefit to the association, that the Zehms received written notices but did not read or rely on them (breaking any causation), and that no duty or representation existed to guarantee continuous identical coverage.

business & regulatoryhealthcare

This case involved the appeal of Richard Leavitt's conviction for first-degree murder and death sentence in the 1984 killing of a Blackfoot, Idaho woman, whose body was found mutilated in her home after multiple stab wounds. The prosecution relied on circumstantial evidence including the defendant's type O blood mixed with the victim's at the scene, an unexplained wound on his finger, his inconsistent explanations for the injury, his unusual post-murder behavior and phone calls, and other testimony. The Idaho Supreme Court affirmed the conviction after reviewing the record for prejudicial errors such as pretrial publicity, the admission of gruesome photographs, a seized letter, and testimony about the defendant's knife use and prior acts, finding the evidence sufficient to support the jury's verdict. However, the court reversed the death sentence and remanded for further consideration of the penalty phase.

criminal lawprocedure

In State v. Sindak, the defendant was convicted in magistrate court of the misdemeanor offense of enticing children under Idaho Code § 18-1509 after his trial began more than six months following his not-guilty plea, due to repeated vacating of trial dates from magistrate court calendar overcrowding. The district court affirmed the conviction, but the Court of Appeals reversed, finding a violation of the statutory speedy-trial right under I.C. § 19-3501(3). The Idaho Supreme Court reversed that decision and remanded to reinstate the conviction, holding that the statute's dismissal requirement is not triggered by court congestion alone when the defendant did not object to the postponements, request no delay himself, and made no showing of prejudice. The Court distinguished prior precedent and declined to apply constitutional speedy-trial balancing tests, as the claim rested solely on the statute.

criminal lawprocedure

This case involved sellers of farmland (the Osborns) suing a notary public (Ahrens) for negligently or falsely acknowledging a signature on mortgage and promissory note documents that were later found to be forgeries in a prior lawsuit against the purported buyers. The jury awarded the Osborns damages based on the unpaid balance of the note plus interest and attorney fees from the earlier case, finding the notary's act was the proximate cause of their loss when they could not recover from the defaulting parties. The court affirmed the liability finding, the measure of damages tied to the contractual obligation, and the ruling that the statute of limitations did not bar the claim because the plaintiffs lacked knowledge of the harm until the prior adjudication. It reversed only on the award of prejudgment interest, holding that interest must be calculated as simple interest at the contract rate rather than compounded.

torts & liabilityprocedureproperty