Crafton
Crafton v. Blaine Larsen Farms, Inc.
Opinion
Lead Opinion
Plaintiff Stan Crafton sued Defendant Blaine Larsen Farms, Inc., for breach of contract after his employment ended. Defendant timely appeals from a judgment in Plaintiffs favor for more than $400,000, and Plaintiff timely cross-appeals with respect to attorney fees.
1. We review de novo the district court’s application of Idaho law in this diversity case, Prieto v. Paul Revere Life Ins. Co., 354 F.3d 1005, 1010 (9th Cir. 2004), and likewise review de novo the grant of partial summary judgment, Morrison v. Hall, 261 F.3d 896, 900 (9th Cir. 2001). The district court correctly ruled that, as a matter of Idaho law, Defendant breached Plaintiffs written employment contract when it significantly impaired an agreed benefit. The contract promised Plaintiff a particular position for a term of five years. Defendant admitted that Plaintiff was removed from that position just seven months into the term of the contract. A material change in duties or a significant reduction in rank constitutes a breach of contract under Idaho law. Metcalf v. Intermountain Gas Co., 116 Idaho 622 , 778 P.2d 744, 748-49 (1989), modified on other grounds by Sorensen v. Comm Tek, Inc., 118 Idaho 664 , 799 P.2d 70,…