Justia Idaho Supreme Court Opinion Summaries

In 1992, Todd Rich was indicted for felony rape, allegedly committed between November 1991 and January 1992; he pled guilty on August 19, 1992; and on October 23, 1992, the district court sentenced him to six years in the custody of the Idaho Board of Correction. The district court retained jurisdiction for 120 days, and ultimately suspended the remainder of Rich’s sentence and placed him on probation. Rich successfully completed his probation on or about March 2, 2004. The following day, Rich filed a motion asking the district court in his criminal case for relief pursuant to Idaho Code section 19-2604(2), which was granted. The district court reduced Rich’s charge to a misdemeanor. The order reducing the charge stated that “the Judgment is hereby deemed a misdemeanor conviction, thereby restoring [Rich] to his civil rights.” At some point, Rich moved to Pennsylvania. He apparently applied for permission to possess a firearm in Pennsylvania. His request was denied by an administrative law judge who ordered: “It appearing that under Idaho law, I.C. 18-310(2), final discharge for a conviction of rape does not restore the right to ship, transport, possess or receive a firearm, the determination of the Pennsylvania State Police that Todd Rich is prohibited under the Uniform Firearms Act, 18 Pa. C.S. 6101 et seq., is upheld.” Rich filed this action seeking a declaratory judgment that he “may lawfully purchase, own, possess or have under his custody or control a firearm under the laws of the State of Idaho.” The State responded by contending that Rich had no standing to seek such relief. The district court dismissed the case on two alternative grounds: (1) Rich did not have standing because no real, substantial, and concrete controversy then existed; and (2) “Idaho Code 18-310(3) provides the mechanism for the restoration of civil rights is through application to the commission of pardons and parole, not through the District Court.” The district court entered a judgment dismissing this action with prejudice. Finding no reversible error, the Idaho Supreme Court affirmed. View "Rich v. Idaho" on Justia Law

This appeal arose from the termination of Jeffry Black, the former Executive Director of the Idaho Peace Officer Standards and Training Council (POST). Black asserted that the Idaho State Police (ISP) violated two provisions of the Idaho Protection of Public Employees Act ("the "Whistleblower Act") when it terminated him. The district court granted summary judgment in favor of ISP, holding that Black failed to engage in activity protected under the Act. Black appealed the district court's decision to the Supreme Court. Finding no reversible error, the Supreme Court affirmed. View "Black v. Idaho State Police" on Justia Law

Plaintiff Wade Frogley appealed the district court's grant of summary judgment in favor of Respondents Meridian Joint School District No. 2, Aaron Maybon, and Linda Clark, on Frogley's complaint of retaliation in violation of Title VII of the Civil Rights Act and the Idaho Human Rights Act. Plaintiff also appealed the district court's grant of summary judgment in favor of Respondents on his claim of negligent infliction of emotional distress. Plaintiff's claims stemmed from his work as an Assistant Principal at Mountain View High School within the Meridian School District. He alleged that within weeks of his hire, he was subject to continuous sexual harassment at the school from the principal and other assistant principals. Upon review, the Supreme Court concluded genuine issues of material facts existed with regard to both of Plaintiff's claims. As a result, the Supreme Court reversed the district court's judgment and remanded the case for further proceedings. View "Frogley v. Meridian Joint School Dist 2" on Justia Law

Appellant Lillian Hatheway appealed a district court's grant of summary judgment in favor of the Board of Regents of the University of Idaho and the University of Idaho. Appellant worked for the University as an administrative assistant for nine years before she resigned. She sued for age discrimination, hostile work environment, retaliation, constructive discharge and negligent infliction of emotional distress. Upon review, the Supreme Court concluded the district court correctly dismissed all of Appellant's claims. View "Hatheway v. Bd of Regents - UI" on Justia Law

At issue before the Supreme Court in this case was appeal and cross-appeal of summary judgments dismissing claims against Defendants Ada County, Deputy Jeremy Wroblewski, Kate Pape, and James Johnson in a 42 U.S.C. 1983 civil rights action brought by Rita Hoagland on behalf of herself and the estate of her deceased son, Bradley Munroe ("Munroe"), claiming a violation of a Fourteenth Amendment right to medical care and safety while Munroe was detained at Ada County Jail where he committed suicide. Munroe had a history of incarceration at Ada County Jail ("ACJ"). During the evening of September 28, 2008, Munroe was arrested and charged with the armed robbery of a convenience store. Munroe was intoxicated and uncooperative. During booking, Munroe was screaming and being rowdy. Munroe took a string and wrapped it around his neck. Because of his bizarre behavior throughout the night, Munroe was placed in a holding cell for observation until he was sober. The next morning booking continued. At that time, Munroe requested protective custody. Munroe was placed in a cell by himself and a well-being check was scheduled to occur every thirty minutes. Later that evening during a well-being check, the performing deputy found Munroe hanging from his top bunk by a bed sheet. Munroe was pronounced dead later that evening. Among the issues on appeal were: whether the decedent's estate could assert a 42 U.S.C 1983 action for alleged violations of the decedent's constitutional rights; whether the parent had standing to assert a 42 U.S.C. 1983 action for the death of her adult child while incarcerated; and whether the district court erred in awarding costs to Defendants. Upon review, the Supreme Court concluded that the district court: (1) was affirmed in dismissing Hoagland's 1983 claim on behalf of Munroe's estate; (2) was reversed in finding that Hoagland had a 1983 cause of action for violations of her own constitutional rights; (3) was partially affirmed in its award of costs as a matter of right; (4) was reversed in its award of discretionary costs; and (5) was affirmed in denying attorney fees. The case was remanded for the reconsideration and entry of express findings regarding the district court's award of discretionary costs. View "Hoagland v. Ada County" on Justia Law

Plaintiff-Appellant Victoria Johnson appealed the district court's grant of summary judgment in favor of North Idaho College (NIC) on her claim of discrimination under the Idaho Human Rights Act (IHRA). Plaintiff alleged one of her instructors sexually harassed her, and that NIC was vicariously liable for that harassment. The district court held that NIC's affirmative defense was factually support, and that she failed to establish a genuine issue of material fact. Upon review of the facts of this case, the Supreme Court concluded that the district court did not err in finding that no genuine issue of material fact existed in regard to Plaintiff's claims. Accordingly the Court affirmed the opinion of the district court. View "Johnson v. North Idaho College" on Justia Law

Former engineering professor Plaintiff Habib Sadid appealed the grant of summary judgment in favor of his former employer Defendant Idaho State University which dismissed his retaliation claim. Plaintiff alleged the University retaliated against him because of his comments criticizing the administration that had been published in a local newspaper over several years and that the University had breached his employment contract. Upon review careful review of the issues Plaintiff raised in his appellate brief, the Supreme Court affirmed the judgment of the district court dismissing the amended complaint. The Court vacated the denial of attorney fees to the University and remanded this case for consideration of its request for attorney fees in defending against the breach of employment contract claim. View "Sadid v. Idaho State University" on Justia Law

A State trooper arrested Respondent Jason Miller for DUI. The trooper observed that Respondent’s pupils were dilated and asked that Respondent perform some field sobriety tests, which Respondent ultimately failed. The trooper discovered scissors in Respondent’s pocket that were used for cleaning a marijuana pipe. Respondent admitted to smoking marijuana “every day.” The trooper took respondent to a hospital for a urine test, but at the hospital, Respondent refused to willingly provide a sample. A registered nurse at the hospital then catheterized Respondent at the trooper’s request, and extracted the sample. Respondent later pled guilty to possession of drugs, drug paraphernalia and to DUI. Respondent appealed the trial court’s grant of summary judgment to the State. He argued that his civil rights under 42 U.S.C 1983 and state tort laws were violated when he was “unreasonably” catheterized. The Supreme Court found that because “American search-and-seizure law is undeveloped as to when an officer may administer an involuntary warrantless catheterization on a suspect,” the state trooper was entitled to qualified immunity for both of Respondent’s the federal and state law claims. View "Miller v. Idaho State Patrol" on Justia Law