Justia Injury Law Opinion Summaries

Articles Posted in Idaho Supreme Court - Civil
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Appellant Lesia Knowlton appealed the Industrial Commission's determination that she was not entitled to workers' compensation benefits. Appellant was employed as a secretary at Respondent Wood River Medical Center. In 2000, Appellant was working at her assigned station when a drain in a nearby patient's bathroom became clogged. One of the maintenance workers used a chemical cleaner to clear the drain. The chemical produced a foul odor. Workers placed fans at the doorway of the room for ventilation. The air blew past Appellant's station from morning until her shift ended in the afternoon. That night, Appellant developed a cough and body aches. Her symptoms persisted, allegedly from exposure to the chemical drain cleaner. Over the course of five years, Appellant visited multiple doctors and specialists to treat her "bronchitis-like" symptoms. Appellant filed a complaint with the Industrial Commission seeking reimbursement for her medical expenses and for temporary total disability benefits. At a Commission hearing, the referee ultimately concluded that Appellant failed to demonstrate that her medical symptoms were causally related to the chemical exposure. Although the referee determined that Appellant was not entitled to "time loss" benefits or any form of disability benefits, he did find that because the medical treatment Appellant received during the six weeks following the incident was a "reasonable precautionary step" taken in response to the exposure, she was entitled to compensation for those expenses. The Commission adopted the referee's findings of fact and conclusions of law. The Commission denied Appellant's motion for reconsideration. Subsequently Appellant appealed to the Supreme Court. The Supreme Court agreed that Appellant failed to demonstrate her medical symptoms were related to the chemical exposure. Accordingly the Court affirmed the Commission's determination.

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Plaintiff-Appellants Franz and Betty Suhadolnik appealed the district courtâs grant of summary judgment in favor of their doctor, Defendant-Respondent Scott Pressman. Mr. Suhadolnik argued that his cataract surgeon, Dr. Pressman, failed to adequately inquire about his prior use of a prescription drug that resulted in increased risks during surgery. Mr. Suhadolnik presented expert testimony to demonstrate that Dr. Pressman was negligent when he performed the surgery. The district court determined that Mr. Suhadolnikâs expert failed to address any knowledge of the local standard of care, which was necessary to avoid having the testimony stricken from the trial record. Mr. Suhadolnik appealed to the Supreme Court arguing that the district court erred by dismissing his expertâs testimony. The Supreme Court found that the district court acted within its discretion in holding the expertâs testimony to be inadmissible. Accordingly the Court affirmed the lower courtâs holding.

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Defendants Milt and Mary Erhart owned a commercial building in Meridian that contained offices that they rented to various lessees. The building had external stairs that consisted of carpet-covered, wooden steps from a ground level landing to the second floor. Mr. Erhart determined that rot made the steps a hazard, and he replaced them with concrete steps in October 2003. Plaintiff Jim Phillips had an office on the second floor. In 2006, Mr. Phillips walked down the stairs to take out the trash when he tripped. He was found lying face-down on the concrete landing at the bottom of the stairs. He suffered various injuries including a closed head injury that caused permanent brain damage and a loss of memory. The Phillipses filed suit against the Erharts in 2007 to recover damages resulting from the fall. A jury returned a verdict for over $1.5 million, finding Mr. Erhart solely at fault for the accident. The Erharts filed motions for a judgment notwithstanding the verdict, for a new trial, and for a remittitur. The district court granted only the remittitur, ordering a new trial unless the Phillipses accepted a reduction in economic damages. The Phillipses accepted the reduction, and the Erharts timely appealed. On appeal to the Supreme Court, the Erharts challenged the sufficiency of the evidence to support finding Mr. Erhart solely at fault for the accident. The Supreme Court found the evidence presented at trial supported the decision of the court and the damages awarded in the case. The Court affirmed the decision of the district court.

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Plaintiffs-Appellants James and Lori Mareci brought suit on behalf of their minor son Tristen against Defendant-Respondent Coer D'Alene School District and Defendants Scott and Stevie Kamara. Tristen was injured at school by his classmate Quinton Kamara. On the School District's motion for summary judgment, the Marecis' claims against it were dismissed, and the Marecis appealed. The Marecis' asserted that the School District's staff members were reckless, wanton and willful in how they treated their visibly injured son, and negligent in their supervision of Quinton, who was in their custody. State law limits the liability of a school district when a claim arises out of an injury caused by a person under its supervision, custody or care. On review, the Supreme Court agreed with the lower court's finding insufficient evidence to establish the school district's liability under state law, and affirmed the lower court's decision.