Justia Idaho Supreme Court Opinion Summaries

On August 13, 2013, the Idaho Department of Labor (IDOL) mailed two Determinations of Overpayment and an Eligibility Determination to Mitchell Kennedy at the address he had provided when filing for unemployment benefits. The Determinations informed Kennedy that he had the right to appeal, or protest, the Determinations and that the last day to do so was August 27, 2013. On August 21, 2013, Kennedy moved to a new residence. He changed his address with the U.S. Postal Service. Kennedy received the Determinations on August 24, 2013, three days before the deadline. He did not read them until either August 26 or 27. The Industrial Commission made no specific finding as to when Kennedy read the letters but did find that “Claimant did not closely review the Determination to realize the applicable appeal dates due to work and other personal priorities.” Kennedy faxed his protest to IDOL on August 29, 2013, two days after the deadline. In the transmission of that protest, Kennedy informed IDOL of his new address. The appeals examiner found that Kennedy’s request for an appeals hearing was not timely and therefore the examiner had no jurisdiction to hear Kennedy’s appeal. Kennedy appealed, and the Commission affirmed the examiner’s decision. Kennedy then requested reconsideration from the Commission. Finding that Kennedy had not presented any further argument on the relevant issues, the Commission denied the motion. Kennedy timely filed this appeal under Idaho Code section 72-1368(9) and Idaho Appellate Rules 11(d) and 14(b). But finding no reversible error in the Commission's decision, the Supreme Court affirmed. View "Kennedy v. Hagadone Hospitality Co." on Justia Law

This case was an appeal of a district court order awarding attorney fees to Ascorp, Inc. d/b/a Debco Construction (Debco) against the Idaho Transportation Department (ITD) in a declaratory judgment action filed by ITD to determine rights of the parties with respect to a contract for highway construction services on a project in Twin Falls. The district court dismissed the action upon Debco’s motion under Idaho Rule of Civil Procedure 12(b)(6) and awarded attorney fees to Debco under Idaho Code section 12-120(3). On appeal ITD argued that the district court erred in determining that the declaratory judgment action qualified as a dispute involving a commercial transaction required for the application of Idaho Code section 12-120(3). Finding no reversible error, the Supreme Court affirmed the district court's order. View "Idaho Transportation v. Ascorp, Inc." on Justia Law

The Coeur d’Alene Tribe (Tribe) petitioned the Idaho Supreme Court for a Writ of Mandamus to compel the Secretary of State to certify Senate Bill 1011 (S.B. 1011) as law. On March 30, 2015, both the Senate and the House of Representatives passed S.B. 1011 with supermajorities. S.B. 1011 had one purpose: to repeal Idaho Code section 54-2512A, a law which allowed wagering on “historical” horse races. The Tribe alleged that the Governor did not return his veto for S.B. 1011 within the five-day deadline under the Idaho Constitution. The Tribe argued that because the veto was untimely, the bill automatically became law and the Secretary of State had a non-discretionary duty to certify it as law. The Supreme Court agreed and granted the Writ. View "Coeur d'Alene Tribe v. Denney" on Justia Law

This case arose out of the claims of several men who joined Boy Scout troops when they were children and were allegedly sexually abused by their scout leaders. The Church of Jesus Christ of Latter Day Saints (LDS Church) sponsored some of the troops at issue in this case. In 2013, Does I–IV filed a complaint (later amended) at the federal district court against Boy Scouts of America and the LDS Church (collectively, Respondents), alleging constructive fraud. The complaint alleged that Respondents knew that boys were in danger of being sexually abused by adult volunteers and that Respondents failed to disclose that danger. The complaint further alleged that Respondents not only remained silent about the dangers of pedophilic scoutmasters, but also affirmatively represented to the boys that each scout leader was a “great guy,” a “wonderful man,” or a “friend to whom you can always turn for advice.” Respondents subsequently moved to certify questions to the Idaho Supreme Court, challenging the constructive fraud claims on several grounds. The United States District Court certified two narrow questions to the Idaho Court regarding the statute of limitations that applied to a constructive fraud claim where the plaintiff alleged a breach of duty resulted in sexual abuse, and when a claim for constructive fraud related to childhood sex abuse accrued. The Idaho Supreme Court found that: (1) Idaho Code section 5-218(4)'s statute of limitations applied to constructive fraud cases; and (2) the "discovery rule" applied to constructive fraud claims for purposes of determining when the cause of action accrued. View "DOE(s) v. Boy Scouts of America" on Justia Law

This appeal from Custer County relates to proposed repairs and improvements to the City of Challis’ (the City) water distribution system. In 2013, the City initiated a judicial confirmation proceeding seeking approval to incur $3.2 million in debt without a public vote. The Consent of the Governed Caucus (the Caucus) challenged the constitutionality of the City’s request based upon Article VIII, section 3 of the Idaho Constitution. The district court granted the City’s request and the Caucus appealed. Upon review, the Supreme Court reversed. The Court found that the district court erred in failing to apply the legal standard for determining what constituted a "necessary" expense under the Idaho Constitution (Article III), articulated in recent case law. As such, the Supreme Court concluded the district court erred in finding the project "necessary" under the tests articulated by case law. The Court therefore reversed the district court's judgment in Challis' favor, and remanded the case for further proceedings. View "City of Challis v. Consent of the Governed Caucus" on Justia Law

Appellant, Stilwyn, Inc., brought suit against the Respondents stating nine claims for relief arising out of a failed transaction to purchase an interest in a loan. The district court dismissed those claims, holding that they were barred by prior federal litigation involving Stilwyn, two of the Respondents, and the same failed transaction. It held the claims were barred by claim preclusion and because the claims were compulsory counterclaims in the federal litigation that were not asserted there. Stilwyn argued on appeal to the Idaho Supreme Court that the district court erred in both respects. Respondents cross-appealed to argue that the district court erred in failing to grant their requests for attorney fees. Respondents also requested attorney fees on appeal. Upon review, the Supreme Court concluded: (1) the district court erred in its conclusion that Stilwyn's claims were barred by claim preclusion; (2) the district court erred in concluding that Stilwyn's claims were compulsory in the federal litigation; and (3) the district court did not err in refusing to grant attorney fees. View "Stilwyn, Inc. v. Rokan Corporation" on Justia Law

John Doe, a Washington resident and registered sex offender in Washington, sought a declaratory judgment in Idaho as to whether he could be required to register with the Idaho Sex Offender Registry because of his Washington offenses. Doe’s work opportunities required him to spend more than 30 days a year in Idaho, but he had been spending less time than that in Idaho so as not to trigger a registration requirement. Doe was contemplating relocating to Idaho. Doe sought the court’s determination of whether his Washington offenses were “substantially equivalent” to an Idaho sex offense that required registration when an out-of-state offender moves to or is employed in Idaho. The district court, following a hearing, dismissed the Petition, finding that Doe did not have standing, as he demonstrated no injury in fact and his claim was based on hypothetical facts because he did not yet live here. Additionally, the court found there was also no injury because Doe had not been required to register, nor was there any threatened harm because Doe had not been threatened with prosecution for failing to register. Upon review, the Idaho Supreme Court concluded the district court erred in dismissing Doe's case for lack of standing. Furthermore, the Court ruled that the Washington statutes were "substantially equivalent." View "Doe v. Idaho Sex Offender Registry" on Justia Law

Judy and Dennis Charney were divorced in March 2012. In May, Dennis commenced proceedings against Judy alleging multiple counts of contempt for allegedly violating provisions of the property settlement agreement, which was incorporated into the divorce judgment. Judy denied the allegations and the matter was set for an evidentiary hearing to commence on April 11, 2013. On March 28, 2013, Dennis filed a motion to dismiss the contempt proceedings, which was heard April 9, 2013. The magistrate court asked Judy's attorney whether there was any objection to the motion, and he stated that there was not, but it should be dismissed with prejudice. The court stated that the dismissal would be without prejudice unless the parties agreed that it was with prejudice. Dennis's attorney stated that he did not anticipate the contempt proceedings being refiled, but did not have the authority to agree to a dismissal with prejudice. The court then stated that the dismissal would be without prejudice. The court entered an order dismissing the contempt proceedings the following day. Several days later, Judy moved for attorney fees and costs. Dennis objected, and the matter was argued in July. The magistrate court entered a judgment finding that Judy was the prevailing party in the contempt proceedings and awarded her attorney fees. Dennis challenged the award of attorney fees. The district court ultimately affirmed the award of attorney fees. Approximately two years after Dennis first brought proceedings against Judy, he appealed the affirmance of fees to the Supreme Court. Finding no abuse of discretion in the award of fees, the Supreme Court affirmed. View "Charney v. Charney" on Justia Law

The State of Idaho appealed a district court judgment denying its motion to vacate portions of a Stipulated Partial Settlement and Award entered by an arbitration panel. This case stemmed from the 1998 Tobacco Master Settlement Agreement, wherein certain cigarette manufacturers entered into an agreement with the State to pay damages for the cost of treating smoking-related illnesses. A dispute arose between the parties as to the amount owed in 2003 and the district court entered an order compelling arbitration. The arbitration panel entered a Stipulated Partial Settlement and Award in March of 2013. In June of 2013, the State moved the district court to vacate, modify, or correct the award. The district court concluded the State did not have standing to move to vacate or modify the award. The State appealed. Finding no reversible error, the Supreme Court affirmed. View "Idaho v. Philip Morris, Inc." on Justia Law

Plaintiff-appellant Gary Holdaway filed suit against Broulim’s Supermarket, alleging that a titanium screw implanted in his leg was fractured when an automatic door at Broulim’s malfunctioned and closed on the leg. Broulim’s filed a motion for summary judgment arguing that Holdaway failed to provide admissible evidence that the malfunctioning door fractured the screw and caused the resulting medical complications. The district court agreed, granted the motion, and Holdaway appealed. Finding no reversible error, the Supreme Court affirmed. View "Holdaway v. Broulim's Supermarket" on Justia Law