Latest 5 Cases: Bliss v. Minidoka Irrigation District (Business Law), Williams v. St. Alphonsus Medical Center (Civil Procedure), Ferguson v. ...

The Ministerial Exception Allows Racial Discrimination by Religions

LESLIE C. GRIFFIN

UNLV Boyd School of Law professor Leslie C. Griffin describes the ministerial exception—a First Amendment rule created by courts that bars the application of anti-discrimination laws to religious organizations’ employment relationships with its “ministers”—and enumerates some of the cases in which the exception led to dismissal of a lawsuit. Griffin argues that we as a society cannot achieve full justice as long as courts interpret religious freedom to include a ministerial exception that condones racial discrimination lawsuits.

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Bliss v. Minidoka Irrigation District

Docket: 46374

Opinion Date: July 15, 2020

Judge: Roger S. Burdick

Areas of Law: Business Law, Contracts, Real Estate & Property Law, Zoning, Planning & Land Use

Victor Bliss appealed the grant of summary judgment in favor of the Minidoka Irrigation District (“MID”). Bliss filed a complaint against MID in April 2017, alleging: (1) breach of contract; (2) breach of fiduciary duty; (3) trespass; (4) declaratory relief; and (5) wrongful prosecution/infliction of extreme emotional distress. The complaint encompassed multiple events stemming from his decades-long relationship with MID. The district court granted MID’s motion for summary judgment on all claims, dismissing Bliss’s complaint for lack of notice under the Idaho Tort Claims Act, lack of standing, and failure to produce evidence. Bliss timely appealed, but finding no reversible error, the Idaho Supreme Court affirmed summary judgment.

Williams v. St. Alphonsus Medical Center

Docket: 46741

Opinion Date: July 15, 2020

Judge: Bevan

Areas of Law: Civil Procedure, Contracts, Health Law

Appellants-patients Nathaniel Valencia and Emily Williams were self-pay patients who received emergency medical services at Saint Alphonsus Medical Center—Nampa, Inc. (“Saint Alphonsus”) in 2015. During their respective visits, Patients agreed to pay for “all charges incurred” for services rendered to them. Patients were billed in accordance with Saint Alphonsus’ “chargemaster” rates. Patients sought declaratory relief requesting the district court to rule Saint Alphonsus was only entitled to bill and seek collection of the reasonable value of the treatment provided to self-pay patients. Saint Alphonsus moved the district court to dismiss the complaint pursuant to Idaho Rule of Civil Procedure 12(b)(6). The district court treated the motion to dismiss as a motion for summary judgment pursuant to I.R.C.P. 12(d). Ultimately, the district court granted summary judgment for Saint Alphonsus, and Patients timely appealed. Finding no reversible error, the Idaho Supreme Court affirmed.

Ferguson v. Ferguson

Docket: 46731

Opinion Date: July 15, 2020

Judge: Brody

Areas of Law: Civil Procedure, Trusts & Estates

Michael D. Ferguson was initially excluded as a beneficiary from his parents’ marital trust (the Original Trust). Years later, Michael's mother, Sybil Ferguson, essentially reversed Michael's exclusion by exercising a power of appointment in her will, designating Michael Ferguson as a beneficiary of the Survivor’s Trust - a sub-trust of the Original Trust. When Sybil died, Michael petitioned the magistrate court for financial records, including records from the Original Trust, to determine whether he would receive his full share of the Survivor’s Trust. The parties filed cross-motions for summary judgment, which the magistrate court denied in part and granted in part. Both parties appealed to the district court. The district court affirmed the magistrate court’s decision in part and reversed in part. The district court held that the magistrate court erred in concluding that Michael did not become a beneficiary of the Survivor’s Trust until his mother’s death, concluding that he became a beneficiary the moment his mother named him as a beneficiary more than one year before her death. Further, the district court held that the magistrate court erred in refusing to apply the Original Trust’s no-contest provision, removing Michael as a beneficiary. The issues this case presented for the Idaho Supreme Court's review centered on: the fiduciary duties of a trustee who had discretion to spend the trust’s principal, the scope of records available to a trust beneficiary under Idaho Code section 15-7-303, and the enforceability of a trust instrument’s no-contest provision. The Supreme Court concluded the district court erred: (1) in holding Sybil Ferguson did not owe Michael a fiduciary duty under the Trust Agreement; (2) in failing to address whether Michael was entitled to Original Trust allocation records pursuant to Idaho Code section 15-7-303; (3) in enforcing the forfeiture provision before addressing whether the Successor Trustees breached their fiduciary duties in administering the Survivor’s Trust; and (4) in failing to address the magistrate court's ruling denying Michael's motion to compel discovery. Judgment was reversed and the matter remanded for further proceedings.

Gregory v. Stallings

Docket: 46818

Opinion Date: July 15, 2020

Judge: Roger S. Burdick

Areas of Law: Contracts, Real Estate & Property Law

Jonathon Gregory appealed a district court’s award of summary judgment in favor of Richard and Eileen Stallings (collectively, “the Stallings”) in a breach-of-contract action stemming from the parties’ oral agreement to develop real property in Rexburg, Idaho. The property was sold in December 2012. Gregory, believing the Stallings wrongfully withheld a portion of the proceeds, filed a complaint in September 2017. The district court granted the Stallings’ subsequent motion for summary judgment, concluding that Gregory’s cause of action was barred by Idaho Code section 5-217’s four-year statute of limitations. After review, the Idaho Supreme Court determined the district court properly granted summary judgment to the Stallings because Gregory's cause of action was indeed barred by the statute of limitations in Idaho Code 5-217. Further, Gregory’s equitable-estoppel claim failed because he could not show that he pursued his claim in a reasonable amount of time.

Cazier Revocable Trust v. Cazier

Docket: 46852

Opinion Date: July 15, 2020

Judge: Bevan

Areas of Law: Real Estate & Property Law

The Lola L. Cazier Revocable Trust (“Trust”) brought a quiet title action against Charles Drake Cazier (“Drake”) and Land Renewal Management, Inc. (“LRM”) pursuant to Idaho Code section 6-401. Drake answered separately from LRM and asserted a counterclaim against the Trust. The Trust moved to dismiss Drake’s counterclaim under Idaho Rule of Civil Procedure 12(b)(6), then filed a motion for summary judgment against both defendants. LRM also filed a motion under I.R.C.P. 12(b)(6) to dismiss the Trust’s cause of action against it. The district court granted summary judgment to the Trust and dismissed Drake’s counterclaim, awarding attorney fees against both defendants in the process. Drake and LRM appealed, arguing the district court erroneously dismissed Drake’s counterclaim and failed to properly dismiss LRM from the case. Drake and LRM also appealed the district court’s award of fees and costs, arguing several evidentiary errors and that the district court abused its discretion in awarding attorney fees. After review, the Idaho Supreme Court affirmed the district court’s grant of summary judgment for the Trust and affirmed the district court’s evidentiary rulings.