apparent authority doctrine (Idaho) · Go Syfert
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apparent authority doctrine in Idaho

9 Idaho opinions name it 2 courts 1992–2016 0 in the last five years

The cases below were cited by Idaho courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Illinois v. Rodriguezgreen
scotus · 1990 · cited in 3 Idaho opinions naming this issue, 1999–2010
2 sentences

2010The majority correctly states, “[w]here it is later established that a third party who consented to a search lacked actual authority to consent, the search may still be upheld if the law enforcement officers reasonably believed that actual authority existed.” However, as the United States Supreme Court pointed out in Illinois v. Rodriguez, 497 U.S. 177 (1990), the case setting forth the doctrine of apparent authority, the question regarding the validity of a search always hinges on its reasonableness.

1999Subsequently, the United States Supreme Court considered the doctrine of apparent authority in Illinois v. Rodriguez, 497 U.S. 177 , 110 S.Ct. 2793 , 111 L.Ed.2d 148 (1990).

13
Estate of Cordero v. Christ Hosp.green
njsuperctappdiv · 2008 · cited in 1 Idaho opinions naming this issue, 2009–2009
2 sentences

2009More recently, the Superior Court of New Jersey noted that courts of other jurisdictions recognize hospital liability under the doctrine of apparent authority when the “hospital has established and staffed facilities or departments through which patients receive specialized care from medical professionals with whom they do not have a prior or ongoing relationship-emergency rooms, operating rooms and anesthesiology and radiology departments.” Estate of Cordero v. Christ Hosp., 403 N.J.Super. 306 , 958 A.2d 101, 107 (Ct.App.Div.2008) (emphasis added). *115 TVH raises various arguments in opposit

2009More recently, the Superior Court of New Jersey noted that courts of other jurisdictions recognize hospital liability under the doctrine of apparent authority when the “hospital has established and staffed facilities or departments through which patients receive specialized care from medical professionals with whom they do not have a prior or ongoing relationship-emergency rooms, operating rooms and anesthesiology and radiology departments.” Estate of Cordero v. Christ Hosp., 403 N.J.Super. 306 , 958 A.2d 101, 107 (Ct.App.Div.2008) (emphasis added). *115 TVH raises various arguments in opposit

11
State v. McCaugheygreen
idaho · 1995 · cited in 1 Idaho opinions naming this issue, 1999–1999
2 sentences

1999See Rodríguez, 497 U.S. at 183-88 , 110 S.Ct. at 2798-2801 , 111 L.Ed.2d at 157-61 ; McCaughey, 127 Idaho at 672, 674 , 904 P.2d at 942, 944 .

1999See Rodríguez, 497 U.S. at 183-88 , 110 S.Ct. at 2798-2801 , 111 L.Ed.2d at 157-61 ; McCaughey, 127 Idaho at 672, 674 , 904 P.2d at 942, 944 .

11
United States v. Matlockgreen
scotus · 1974 · cited in 1 Idaho opinions naming this issue, 1999–1999
2 sentences

1999See id. at 177 n. 14, 94 S.Ct. at 996 n. 14, 39 L.Ed.2d at 253 n. 14.

1999See id. at 177 n. 14, 94 S.Ct. at 996 n. 14, 39 L.Ed.2d at 253 n. 14.

11
Hilt v. Drapergreen
idahoctapp · 1992 · cited in 1 Idaho opinions naming this issue, 1997–1997
2 sentences

1997This is consonant with application of the doctrine in the contract context, where “apparent authority involves an element of reliance on the part of the third party.” Hilt v. Draper, 122 Idaho 612, 618 , 836 P.2d 558, 564 (Ct.App.1992).

1997This is consonant with application of the doctrine in the contract context, where “apparent authority involves an element of reliance on the part of the third party.” Hilt v. Draper, 122 Idaho 612, 618 , 836 P.2d 558, 564 (Ct.App.1992).

11
Beckenstein v. Potter & Carrier, Inc.green
conn · 1983 · cited in 1 Idaho opinions naming this issue, 1992–1992
2 sentences

1992See Beckenstein v. Potter & Carrier, Inc., 191 Conn. 120 , 464 A.2d 6 (1983); Kern v. J.L.

1992See Beckenstein v. Potter & Carrier, Inc., 191 Conn. 120 , 464 A.2d 6 (1983); Kern v. J.L.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Jones v. Healthsouth Treasure Valley Hospital green
idaho · 2009
2 sentences

2016On the morning of the surgery, Mr. Wainio signed a fourth form titled “Syringa Surgery Center Consent for Operation, Anesthesia or Other Procedures.” It included a statement, “I am awai'e of my physicians’ [sic] ownership in the surgery center and am aware that I may have surgery or treatment performed at any other facility where my surgeon has privileges.” The first element of the doctrine of apparent authority is “conduct by the principal that would lead a person to reasonably believe that another person acts on the principal’s behalf.” Jones, 147 Idaho at 116 , 206 P.3d at 480 .

2016On the morning of the surgery, Mr. Wainio signed a fourth form titled “Syringa Surgery Center Consent for Operation, Anesthesia or Other Procedures.” It included a statement, “I am awai'e of my physicians’ [sic] ownership in the surgery center and am aware that I may have surgery or treatment performed at any other facility where my surgeon has privileges.” The first element of the doctrine of apparent authority is “conduct by the principal that would lead a person to reasonably believe that another person acts on the principal’s behalf.” Jones, 147 Idaho at 116 , 206 P.3d at 480 .

32011–2016
Bailey v. Ness green
idaho · 1985
2 sentences

2011Jones v. Health-South Treasure Valley Hosp., 147 Idaho 109 , 206 P.3d 473 (2009) (under doctrine of apparent authority, the tort liability of an independent contractor can be imputed to the principal); Bailey v. Ness, 109 Idaho 495 , 708 P.2d 900 (1985) (under doctrine of apparent authority, the tort liability of another can be imputed to the principal where the other had no contractual relationship of any kind with the principal).

2011Jones v. Health-South Treasure Valley Hosp., 147 Idaho 109 , 206 P.3d 473 (2009) (under doctrine of apparent authority, the tort liability of an independent contractor can be imputed to the principal); Bailey v. Ness, 109 Idaho 495 , 708 P.2d 900 (1985) (under doctrine of apparent authority, the tort liability of another can be imputed to the principal where the other had no contractual relationship of any kind with the principal).

12011–2011
Williams v. St. Claire Medical Center green
kyctapp · 1983
1 sentence

2009Id. at 596 .

12009–2009
LANDVIK BY LANDVIK v. Herbert green
idahoctapp · 1997
1 sentence

2009Id.

12009–2009
Jackson v. Righter green
utah · 1995
1 sentence

1997It is stated, for example, in Jackson v. Righter, 891 P.2d at 1392 : “To be vicariously liable for the acts of an employee under a theory of apparent authority, an employer must conduct itself in such a way as to clothe its employee with apparent authority to perform the torts committed and there must be reasonable reliance on that apparent authority on the *60 part of the injured party.” (Emphasis added.) This reliance requirement precluded recovery by the plaintiff in Wilson v. Good Humor Corp., 757 F.2d 1293 (D.C.Cir.1985), a wrongful death action.

11997–1997
John Scowcroft & Sons Co. v. Roselle green
idaho · 1955
2 sentences

1997See Bailey, supra; John Scowcroft & Sons Co. v. Roselle, 77 Idaho 142 , 289 P.2d 621 (1955); Tri-Circle, supra. Neither this Court nor the Idaho Supreme Court has applied the doctrine of apparent authority to a claim that a principal is liable for injuries resulting from the agent’s tortious conduct.

1997See Bailey, supra; John Scowcroft & Sons Co. v. Roselle, 77 Idaho 142 , 289 P.2d 621 (1955); Tri-Circle, supra. Neither this Court nor the Idaho Supreme Court has applied the doctrine of apparent authority to a claim that a principal is liable for injuries resulting from the agent’s tortious conduct.

11997–1997
Willis E. Wilson, Rep., Estate of Tomikia Wilson v. Good Humor Corporation and David A. Williams green
cadc · 1985
1 sentence

1997It is stated, for example, in Jackson v. Righter, 891 P.2d at 1392 : “To be vicariously liable for the acts of an employee under a theory of apparent authority, an employer must conduct itself in such a way as to clothe its employee with apparent authority to perform the torts committed and there must be reasonable reliance on that apparent authority on the *60 part of the injured party.” (Emphasis added.) This reliance requirement precluded recovery by the plaintiff in Wilson v. Good Humor Corp., 757 F.2d 1293 (D.C.Cir.1985), a wrongful death action.

11997–1997

Where else courts name it

IL 88 (1981–2026) TX 34 (1916–2021) LA 25 (1976–2022) CT 24 (1987–2019) PA 22 (1973–2026) IN 17 (1989–2020) OH 15 (1996–2026) CO 13 (1984–2022) NY 12 (1991–2023) MA 12 (1981–2025) NJ 10 (1993–2021) WA 9 (1989–2012) ID 9 (1992–2016) NC 9 (1978–2016) WI 9 (1988–2020) VA 8 (1983–2026) KS 7 (1992–2013) FL 7 (1971–2008) UT 6 (1993–2021) AL 6 (1973–2016) NV 5 (2018–2018) GA 5 (1975–2014) IA 5 (2016–2016) MO 5 (1907–2023) OR 5 (1993–2016) MD 4 (1954–2013) MN 4 (2008–2016) SC 4 (1997–2025) VT 4 (1998–2004) NM 3 (2004–2017) CA 3 (2006–2014) WV 3 (1977–2004) MI 3 (2001–2025) NE 3 (1930–1972) NH 3 (1988–2007) AK 2 (1987–2012) ME 2 (1986–2018) DC 2 (1999–2019) TN 2 (2001–2008) AZ 2 (2015–2015) MT 2 (2000–2009)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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