Justia Injury Law Opinion Summaries

Boise Baseball, LLC, Boise Hawks Baseball Club, LLC, and Home Plate Food Services, LLC, (collectively "Boise Baseball") sought, and the Supreme Court granted, a permissive appeal of a district court's order. Plaintiff-Respondent Bud Roundtree Rountree was a Boise Hawks season ticket holder. In 2008, he took his wife and two grandchildren to a Boise Hawks game at Memorial Stadium in Garden City. "Most" portions of the stadium are protected by vertical mesh netting approximately 30 feet high, and several areas are protected from above by horizontal netting. Rountree's tickets were in the "Viper" section, which is protected by netting. The stadium also has an area known as the "Hawks Nest," which is a dining area along the third base line covered by both vertical and horizontal netting. Adjacent to the Hawks Nest, at the "very end of the third base line," is the "Executive Club." The Executive Club, while covered by horizontal netting, "is one of the only areas in the whole stadium not covered by vertical netting." At some point during the game, Rountree and his family went to the Hawks Nest to eat. After eating, they went to the Executive Club. While in the Executive Club, Rountree started talking to someone and stopped paying attention to the game. Approximately ten minutes later, Rountree heard the roar of the crowd and turned his head back to the game. He was struck by a foul ball and, as a result, lost an eye. Rountree brought suit alleging that their negligence caused the loss of his eye. Boise Baseball moved for summary judgment, arguing that the district court should adopt the Baseball Rule, which limits the duty of stadium operators to spectators hit by foul balls, and find that Boise Baseball complied with it. Alternatively, Boise Baseball argued that Rountree impliedly "consented to the risk of being hit by a foul ball." The district court denied the motion on both grounds. Upon review, the Supreme Court found no compelling public policy requiring it to adopt the "Baseball Rule." Based on that analysis, the Court was not persuaded that primary implied assumption of the risk should be treated any differently. "Allowing assumption of risk as an absolute bar is inconsistent with our comparative negligence system, whether the risks are inherent in an activity, or not. We decline to adopt the Baseball Rule. We further hold that, apart from express written and oral consent, assumption of the risk, whether primary or secondary, is not a valid defense in Idaho." View "Rountree v. Boise Baseball" on Justia Law

Plaintiff-Appellant Jerry Doherty appealed a district court order that dismissed him as a party in the medical malpractice action against respondents Dr. Gordon Dixon and Blackfoot Medical Clinic. The district court, on September 16, 2010, ruled that because Doherty failed to disclose this claim as an asset in his Chapter 13 bankruptcy proceeding, he was judicially estopped from pursuing this claim against Respondents. The district court further ordered that Doherty take nothing from Respondents, and that the bankruptcy trustee be substituted as the party-plaintiff. On appeal, Plaintiff argued that the district court abused its discretion in granting summary judgment. Finding no abuse of discretion, the Supreme Court affirmed. View "McCallister v. Dixon" on Justia Law

This issue before the Supreme Court in this case centered on an action to recover damages from a well driller who drilled a well that later caved in. The district court granted the well driller's motion for summary judgment on the ground that the alleged claims of negligence and breach of contract were barred by the applicable statutes of limitations, and the court dismissed the action. Upon review, the Supreme Court held that that the breach of contract claim was indeed barred by the statute of limitations and that the negligence claim was barred by the economic loss rule. The Court affirmed the district court's dismissal of the case. View "Stapleton v. Jack Cushman Drilling" on Justia Law

At issue in this case was the definition of the width of an easement for an irrigation pipeline. Dalton Gardens Irrigation District (the District) owned pipeline and intended to replace an existing four-inch pipe with a ten-inch pipe. A portion of the pipeline crosses Diane Ruddy-Lamarca's property. The parties agreed that an easement of some kind existed in favor of the District. However, they disagreed regarding the nature and width of that easement. The district court held that the District had an express easement and an easement by prescription that were identical in location and sixteen feet wide. The District appealed, claiming that the district court erred by restricting the easement to sixteen feet in width and requiring it to make every effort to preserve trees and a drain field on Ruddy-Lamarca's property. Upon review of the district court order, and finding no error in its decision, the Supreme Court affirmed. View "Ruddy-Lamarca v. Dalton Gardens" on Justia Law

The issue before the Supreme Court in this case stemmed from the grant of summary judgment in favor of an insurance company. The insureds contended that the liability coverage provision in their homeowner's policy required the insurer to defend a lawsuit brought by a contractor they hired to repair fire damage to their home and to remodel the home, and that the insurer was required to indemnify against any recovery by the contractor. Upon review of the policy underlying this case, the Supreme Court found no such duties as the insureds contended and affirmed the district court's judgment. View "Linford v. State Farm Fire & Casualty" on Justia Law

The issue before the Supreme Court in this case centered on an appeal from several district court rulings in an ongoing dispute between Kyle Athay (Athay) and Rich County, Utah (Rich County). Athay was injured in a motor vehicle collision with Daryl Ervin (Ervin), who was fleeing police pursuit. Subsequently, Athay filed a civil suit against the pursuing law enforcement officers from Bear Lake County, Idaho and Rich County. After "Athay II," a jury trial commenced with Rich County as the sole remaining defendant. The jury returned a special verdict for Athay and awarded him $2,720,126.00 in economic damages and $1,000,000 in non-economic damages. The jury found that Ervin was 70% responsible for Athay’s injuries, and that Rich County was responsible for the remaining 30%. On appeal, Rich County argued that the district court made multiple errors: that the district court abused its discretion when it declined to disqualify the presiding judge for the limited purpose of deciding Rich County’s First Motion for a New Trial; that the district court erred by denying Rich County’s first and second motions for new trial; and that the district court erred when it denied Rich County’s Motion for Judgment Notwithstanding the Verdict. Finding no error, the Supreme Court affirmed the decisions of the district court. View "Athay v. Rich County, Utah" on Justia Law

Randy and Trudi Poole filed an action against Darin Davis, dba Darin Davis Construction (Davis), alleging breach of contract, breach of warranty, and fraud. Davis counterclaimed for breach of contract, unjust enrichment, and promissory estoppel. The jury found that the Pooles had prevailed only on the fraud claim and that Davis had not proved any of his counterclaims. The district court entered judgment in favor of the Pooles for damages on the fraud claim. The Pooles moved for attorney fees and costs, claiming that as the prevailing party in a dispute over a commercial transaction, they were entitled to fees pursuant to Idaho Code 12-120(3). The court determined that there was no prevailing party and denied the motion. The Pooles timely appealed, asking the Supreme Court to reverse the decision of the district court and find, as a matter of law, that the Pooles were the prevailing party and are entitled to attorney fees. Finding no error, the Supreme Court affirmed. View "Poole v. Davis" on Justia Law

After the roof collapsed on Lakeland True Value Hardware, LLC's (Lakeland) store, Lakeland sought payment for business personal property and business income losses from its insurer, The Hartford Fire Insurance Co. (Hartford). Lakeland filed suit, asserting bad faith and breach of contract. The district court granted summary judgment dismissing the bad faith claim for lack of evidence. The breach of contract claim proceeded to trial, and the jury returned a verdict in favor of Hartford. On appeal, Lakeland challenged the order granting summary judgment. Lakeland also asserted: (1) the jury was confused as to the period of coverage and the district court's evidentiary rulings and jury instructions relevant to that issue were erroneous; (2) the jury verdict was not supported by substantial and competent evidence; and (3) that the district court erred by awarding discretionary costs to Hartford. Finding no error, the Supreme Court affirmed. View "Lakeland True Value Hardware v. The Hartford Fire Insurance Co." on Justia Law

This appeal came before the Supreme Court from a declaratory judgment action brought by Farm Bureau Mutual Insurance Company of Idaho (Farm Bureau). Farm Bureau brought suit in response to a claim for insurance benefits filed by the personal representatives of the estate of a deceased policyholder (the Estate). Farm Bureau requested a judgment declaring that the Estate was not an "insured" under the decedent's insurance policy and was therefore not entitled to payment of wrongful death damages under the Policy's underinsured motorist coverage. The district court granted the Estate's motion for summary judgment, determining that Idaho's wrongful death statute, entitled the insured's Estate to recover damages for wrongful death and that the Policy provided coverage for those damages. Farm Bureau appealed. Upon review, the Supreme Court reversed: as to the Estate, the Court determined that under the plain language of the wrongful death statute, the Estate was not legally entitled to recover damages for itself, but only to bring an action on behalf of the heirs to recover their damages. "The Estate stepped into [the decedent's] shoes for those claims, and Farm Bureau made those payments to the Estate. Farm Bureau's payment of these legitimate claims under the insurance contract does not constitute a change of position or an admission that coverage exists for other claims. We hold that these payments do not prevent Farm Bureau from arguing that it is not required to pay the Estate for damages that [the decedent] was not legally entitled to recover." View "Farm Bureau v. Estate of Eisenman" on Justia Law

Plaintiff Christina Brooksby demanded payment from Defendant GEICO General Insurance Company, her father's liability insurer, alleging that he negligently injured her by crashing the car in which she was riding. After GEICO refused Plaintiff's demand pursuant to an exclusion in its insurance policy with Father, she sued GEICO for a declaratory judgment establishing coverage. The district court dismissed Plaintiff's complaint for lack of standing, holding that Idaho has no common-law direct-action rule that would give an injured third party standing to sue her tortfeasor’s insurer absent some statutory or contractual authorization, and that Idaho's Uniform Declaratory Judgment Act does not confer standing where it does not otherwise exist. Plaintiff appealed. Upon review, the Supreme Court affirmed the district court’s grant of GEICO’s Motion to Dismiss pursuant to Idaho Rule of Civil Procedure 12(b)(6) because the Court concluded Plaintiff lacked standing to seek a declaratory judgment against GEICO. View "Brooksby v. GEICO" on Justia Law