Darwin W. Thomas

The case involved a dispute over a 1974 farm lease in which Joe and Priscilla Lamb leased about 800 acres of previously uncultivated Idaho land to J.T. and Marguerite Robinson for growing potatoes and wheat, with Lamb obligated to supply irrigation equipment including efforts to obtain pivot systems. Mechanical failures and delays in irrigation caused Robinson's potato yield to fall short of expectations, prompting Lamb to sue for unpaid rent and related costs while Robinson counterclaimed for crop damages. The trial court found Lamb breached the lease by failing to provide adequate irrigation, awarded Robinson net damages of $193,751 for lost potato profits based on evidence of expected versus actual yields, and the Idaho Supreme Court affirmed, holding that such damages were recoverable with reasonable certainty even on new land and were within the parties' contemplation at contracting.

propertybusiness & regulatory

The case involved property owners Harold and Virginia Tibbs suing the City of Sandpoint and Bonner County for compensation after an airport runway extension in 1972 brought larger, noisier aircraft flying at lower altitudes over their adjacent land, allegedly reducing its value and usability for farming, livestock, and residential purposes. A jury returned a verdict for the defendants, but the trial court granted a new trial on the grounds that the verdict was against the weight of the evidence. On appeal, the Idaho Supreme Court affirmed the order for a new trial, holding that trial courts have broad discretion to grant new trials when a verdict conflicts with the clear weight of the evidence and explaining that in inverse condemnation actions based on overflights, a taking occurs when interference becomes substantial, with damages measured by the difference in property value before and after the impairment at its highest and best use.

propertyprocedure

The case involved claimant Gabriel Ortiz, who was discharged from his job at Armour & Company after a workplace argument involving profanity, yelling, and an invitation to fight, and who sought unemployment benefits under the Idaho Employment Security Law. An appeals examiner initially found him eligible, but the Industrial Commission reversed that decision after additional hearings and concluded he had been discharged for misconduct connected to his employment. The Idaho Supreme Court affirmed the Commission's denial of benefits, holding that its review is limited to questions of law and that the evidence supported the finding of misconduct. The Court noted that proceedings before the appeals examiner and Commission are trials de novo, allowing additional evidence, and that the basic facts regarding the argument were not substantially disputed.

labor & employment

In this tort case, Swift & Company sued Gutierez for damages after its property was destroyed in a truck collision caused by the defendant's vehicle. The defendant answered with a general denial and an affirmative defense attributing the accident to the negligence of the private carrier transporting the plaintiff's goods. After the plaintiff presented its case, the trial court granted a nonsuit on the ground that evidence showed the plaintiff had already been fully compensated for its loss. On appeal, the Idaho Supreme Court reversed, holding that in a tort action evidence of payment or compensation is not admissible under a general denial because nonpayment need not be pleaded or proved by the plaintiff; any such defense must instead be affirmatively pleaded and shown to come from the defendant or a connected source rather than a collateral one.

torts & liabilityprocedure

This case involved a divorce action between spouses married in 1951 with no children, where the wife sued for divorce on grounds of extreme cruelty and sought division of community property, and the husband filed a cross-complaint on the same ground. The trial court granted the wife a divorce, denied the husband relief, divided the property, and later ordered the husband to pay attorney fees, costs, and support pending appeal. On appeal, the Idaho Supreme Court affirmed the divorce decree, finding substantial evidence of the husband's course of conduct inflicting mental suffering on the wife sufficient under state law, with the trial court properly resolving conflicts in testimony. It modified the property division to award the wife her separate contributions plus one-half of community assets after tracing funds from premarital accounts and sales, while affirming the order for appellate attorney fees based on the parties' financial circumstances and need for the wife to defend the appeal.

family lawproperty

The case involved a worker who developed acute dermatitis venenata from exposure to oils, greases, and related substances while employed as an automotive mechanic for over seven years. After the condition repeatedly reactivated upon returning to mechanic duties but resolved in other roles like dock labor, the Industrial Accident Board denied total and permanent disability benefits under the Occupational Disease Law but awarded compensation for partial permanent disability residual from the disease and retained jurisdiction to determine its extent. The Idaho Supreme Court affirmed, interpreting the statute to define disablement as actual and total incapacity from the claimant's specific occupation or trade skill (mechanic work) where he was last exposed, rather than general employability or the broader industry, and holding that the recurring nature of dermatitis did not bar recovery for the permanent effect on that occupation. The court rejected arguments that no compensation was due beyond temporary total disability periods or that the Board lacked jurisdiction for a partial award.

labor & employment

The case involved a dispute over monthly sick benefit payments under a 1945 insurance policy after the plaintiff, a farmer, suffered a heart attack in 1952 and was hospitalized then confined at home. The trial court awarded the plaintiff $1,700 in benefits plus $500 in attorneys' fees, and the defendant appealed. The Idaho Supreme Court affirmed the benefits award, finding that the plaintiff satisfied the policy's house-confining sickness provisions based on undisputed facts and physician orders restricting his activities. However, it reversed the attorneys' fees, holding that the 1951 statute authorizing them could not apply retroactively to the pre-existing policy without impairing the contract. The court interpreted the policy's confinement and convalescence clauses strictly according to their terms and physician attendance requirements.

business & regulatory

The case concerned a contract dated April 27, 1953, under which National Produce Distributors, Inc. agreed to buy potatoes from Miles & Meyer, Inc. After the seller allegedly refused delivery and another defendant took possession of the potatoes, the buyer sued the various parties for conversion. The trial court sustained a demurrer by Idaho Falls-Bonded Produce & Supply Co. and dismissed the claim against it. The Idaho Supreme Court affirmed, holding that the contract was executory because it required further acts such as demand, inspection, grading, segregation, and appropriation before title or a right to immediate possession could pass to the buyer. As a result, the buyer had not alleged the ownership or possessory interest necessary to maintain an action for conversion at the time the potatoes were taken.

business & regulatorypropertytorts & liability

The case involved the conviction of appellant Weise for involuntary manslaughter after she allegedly drove under the influence of alcohol, crossed into oncoming traffic on a four-lane highway, and caused a collision that killed a passenger in another vehicle. The trial court sentenced her to up to ten years in prison and a $1,000 fine. On appeal, the Idaho Supreme Court held that the evidence was sufficient to support the verdict based on violations of traffic laws and intoxication statutes, affirming the conviction and prison term while remitting the fine as an abuse of discretion due to lack of aggravating circumstances. A partial dissent agreed on the conviction but argued the overall sentence was excessive given contributing factors and the appellant's lack of criminal intent.

criminal law

In this case, creditors sued a seller (vendor) and buyer (vendee) after the vendee purchased the vendor's business assets in bulk for $33,500, alleging that the parties failed to comply with Idaho's Bulk Sales Law (I.C. § 64-701 et seq.) because not all creditors were listed on the required sworn statement and the purchase price was not distributed directly to listed creditors, rendering the sale fraudulent and void and making the vendee personally liable for the creditors' proportionate share. The trial court entered judgment for the creditors against the vendee after the vendor confessed judgment. On appeal, the Idaho Supreme Court reversed, holding that the vendee substantially complied with the statute by depositing the full purchase price into escrow for pro rata distribution to all bona fide creditors (listed and unlisted) once additional claims surfaced, which satisfied the law's requirement to apply the proceeds to creditors' claims without material departure from its terms.

business & regulatory

The case involved a workers' compensation claim arising from the death of Roy W. Jaynes, who was fatally injured when his son's car was struck by a train at a railroad crossing on or adjacent to the premises of his employer, Potlatch Forests, Inc., while the two were leaving work after a maintenance shift. The Industrial Accident Board denied benefits on the ground that the accident did not arise out of and in the course of employment under the going-and-coming rule. The Idaho Supreme Court reversed, holding that the claim was compensable because the hazardous crossing constituted a special risk inherent in the employment that employees were required to traverse, even though the precise location was at the boundary of the employer's property. The court applied an exception to the general rule that injuries sustained while traveling to or from work are not compensable, emphasizing that the employer's knowledge and the customary use of the crossing by employees made the danger part of the employment.

labor & employment

This case involved Robert T. Miller, who was convicted in Boise municipal court of driving while intoxicated under a city ordinance and appealed to district court, where his demand for a jury trial was denied. Miller sought a writ of prohibition and mandate from the Idaho Supreme Court to prevent a non-jury trial and compel a jury trial on appeal. The court held that the defendant was entitled to a jury trial in district court, making the writs permanent. The core reasoning was that an appeal from a municipal court conviction is tried de novo as if commenced in district court, where jury trials are required by statute, and this follows prior precedent rejecting arguments that such violations are petty offenses or local regulations triable only summarily without a jury.

criminal lawprocedure

The case involved a wage dispute in which Davis sued Parkin and Ellis, alleged co-owners of a wrecking business, for $49 in unpaid wages plus statutory penalties and fees under Idaho Code sections 45-605 and 45-606. The probate court awarded Davis partial recovery against Parkin but dismissed Ellis; Davis appealed only the dismissal, leading the district court after a trial de novo to enter a $300 judgment against Ellis alone. The Idaho Supreme Court reversed and remanded for a new trial, holding that an appeal from a lower-court judgment based on alleged joint liability transfers the entire controversy—including all parties and issues—to the appellate court for a full trial de novo without altering the original claims. The court reasoned that the appeal annuls the probate judgment in full and that instructions must address possible joint or several liabilities supported by the evidence on partnership or similar relationships.

labor & employmentprocedurebusiness & regulatory

The case involved a defendant convicted of lewd and lascivious conduct with a minor under sixteen, who was sentenced to up to fourteen years in prison. After the conviction was affirmed on appeal, the defendant applied for probation under Idaho Code section 19-2601, but the district court denied the request, leading to this appeal. The Idaho Supreme Court held that the district court lacked jurisdiction to consider probation after the judgment and sentence had been affirmed on appeal. The core reasoning relied on the statute's requirement that any probation or suspension of sentence must occur at the time of the original judgment, as established in State v. Ensign, and that affirmance on appeal ends the trial court's authority over the matter, transferring execution to the State Board of Correction.

criminal lawprocedure

This case concerns an original proceeding in which R. M. Farmer sought writs of prohibition and mandate to prevent a district judge from scheduling a bench trial and to compel a jury trial in a contract dispute. In the underlying action, a plumbing contractor sued Farmer and his wife for $4,511 allegedly due under building contracts for labor and materials; Farmer denied owing more than $1,378, asserted credits and damages for inferior work and materials, and requested an accounting. The Idaho Supreme Court held that the action was one at law for recovery of a debt, making the right to a jury trial under the state constitution available, and that any accounting sought was merely incidental. The court further ruled that Farmer had not validly waived a jury trial because no waiver was properly entered in the court minutes as required by statute, and it would not imply a waiver from ambiguous later proceedings. Accordingly, the court made the writs permanent to ensure a jury trial.

procedurecivil rights

This case involved a claim for unemployment benefits under Idaho's Employment Security Law by a claimant who had traveled from Boise to Shelbyville, Illinois, to visit his mother and sought work there during a five-week period in late 1952 and early 1953. The Employment Security Agency denied benefits for two weeks due to late filing and sought repayment of benefits already paid, arguing the claimant was ineligible because he was not available for suitable work in a small labor market during winter. The Industrial Accident Board upheld the denial and ordered repayment. The Idaho Supreme Court affirmed the denial of benefits for the late-filed weeks on the ground that the claimant had not shown attachment to a labor market and thus was unavailable for work, but reversed the repayment order because the claim had been made and benefits received in good faith without misrepresentation of material facts. The decision turned on statutory requirements for eligibility, including the meaning of availability for suitable work, and provisions limiting repayment absent bad faith.

labor & employmentprocedure

The case concerned a husband's petition to modify a divorce decree by eliminating annual support payments to his ex-wife that were required under a prior property settlement and separation agreement. The trial court granted the modification based on changed circumstances, but the Idaho Supreme Court reversed. The court held that the agreement's terms had not been incorporated into the divorce decree and thus remained purely contractual obligations rather than court orders subject to modification under Idaho Code section 32-706. Because the agreement stood independent of the decree, the trial court lacked jurisdiction to alter the payment provisions.

family lawprocedure

The case involved a farmer who purchased a pump from the defendants to irrigate his crops, with the contract specifying delivery of a pump capable of providing 200 miner's inches of water from the Snake River. When the installed pump failed to deliver adequate water, resulting in crop damage, the plaintiff sued for damages while the defendants counterclaimed for the unpaid balance of the purchase price. A jury awarded the plaintiff partial damages and the defendants most of their counterclaim, but the trial court granted the plaintiff's motion for a new trial on the ground that the evidence was insufficient to support the verdict. The Idaho Supreme Court reversed that order, holding that the trial court abused its discretion because the jury's verdict was supported by substantial competent evidence and the determination of damages was within the jury's province absent passion, prejudice, or legal error.

procedurebusiness & regulatory

The case involved the State of Idaho seeking to recover approximately $7,310 in license fees that the City of Gooding had collected from operators of coin-operated amusement devices (slot machines) under the 1947 Local License Act but failed to remit to the state treasurer as required. The city defended on the ground that the act was unconstitutional under the Idaho Constitution's prohibition on lotteries, and the trial court agreed, entering judgment for the city. The Supreme Court reversed, ruling that the city could not challenge the statute's validity because it had voluntarily accepted the benefits of the licensing scheme by collecting fees pursuant to it, and therefore had to pay the state's share.

criminal lawbusiness & regulatory

This case concerned a dispute over possession of a tractor sold under an oral conditional sales contract, in which the buyer made a partial payment but failed to pay the balance, prompting the seller to repossess the tractor; the buyer then filed a claim and delivery action, and the seller responded with a cross-complaint asserting ownership and seeking damages. The trial court awarded the seller ownership of the tractor along with $2,000 in damages for wrongful deprivation of possession. On appeal, the Idaho Supreme Court affirmed the seller's ownership and right to immediate possession but reversed the damages award. The court reasoned that the evidence did not show the buyer had ever taken possession of the tractor after the seller's repossession or deprived the seller of its use, as the seller had posted a redelivery bond but left the tractor in the sheriff's custody without attempting to retrieve it.

propertyprocedure