Justia Idaho Supreme Court Opinion Summaries

In this case, Laurie Barton, a third-year law student at the University of Idaho, was accused of violating the university's honor code by committing academic misconduct during a final examination. Despite denying the allegations, she was sanctioned with degree denial after a series of Honor Court proceedings. Barton exhausted her administrative review options, including an appeal to the Idaho State Board of Education, and then petitioned for judicial review. The district court denied her petition. Instead of appealing this decision, Barton sued the Board of Regents of the University of Idaho and Idaho State Board of Education, alleging nine causes of action, all of which the district court dismissed at summary judgment.The district court's judgment was affirmed by the Supreme Court of the State of Idaho. The Supreme Court found that Barton had failed to raise a genuine issue of material fact that the University violated its duty of good faith and fair dealing or that it made a specific promise that induced her action. The court also found that Barton's motion for a protective order was implicitly denied and moot, as the case was resolved on summary judgment. The court concluded that Barton's appeal was pursued frivolously, unreasonably, and without foundation, and awarded attorney fees and costs to the University. View "Barton v. Board of Regents" on Justia Law

Peyton Gifford and Mollie Gabaldon (“Parents”) filed a complaint as individuals, guardians ad litem for their son, and putative class representatives, alleging that the West Ada Joint School District #2 (“West Ada”) illegally charged tuition fees for the second half-day of kindergarten instruction. The district court dismissed Parents’ complaint for lack of standing because Parents did not pay the allegedly illegal fees. On appeal, the Idaho Supreme Court held that although the district court properly concluded that Parents lacked standing to pursue a claim based solely on an economic injury, it failed to consider whether Parents had standing to assert a second, discrete injury: loss of educational opportunity for their son. Accordingly, the Court concluded Parents had standing to pursue their educational claims. View "Gifford v. West Ada Joint School District #2" on Justia Law

The issue this appeal presented for the Idaho Supreme Court's review centered on whether Shelaina Neimeyer’s argument concerning judicial notice of a municipal ordinance was properly preserved for appeal. An employee at a gas station in Twin Falls, Idaho, contacted the police about a vehicle that had been parked at the gas station for over an hour. The employee reported that a woman who had previously purchased alcohol at the gas station (later identified as Neimeyer) had not moved from the vehicle for over 30 minutes. Consequently, Officers Tracy Thompson and Candace Comeau were dispatched at approximately 2 a.m. to conduct a welfare check. When the officers approached Neimeyer's vehicle, Officer Comeau then asked Neimeyer about a small, closed container on the passenger seat. Neimeyer initially refused to allow the officers to search the container, but she acquiesced, and the officers smelled the odor of marijuana inside. After Officer Thompson asked Neimeyer to exit her vehicle, she complied and took her purse with her. Neimeyer was placed in handcuffs and told she was being detained because of the alcohol found in her vehicle, the marijuana found in the container, and the possibility that she may be under the influence of drugs or alcohol. Officer Thompson then searched Neimeyer’s purse and discovered incriminating evidence, including methamphetamine, marijuana, and drug paraphernalia. After Neimeyer was charged with possession of methamphetamine, marijuana, and drug paraphernalia, she filed a motion to suppress evidence, contending the district court erred when it denied her motion because: (1) the State did not prove the existence of a City of Twin Falls ordinance; and (2) the district court was precluded from taking judicial notice of a municipal ordinance. Because Neimeyer raised her argument concerning judicial notice for the first time on appeal, the Idaho Supreme Court affirmed the district court’s decision. View "Idaho v. Neimeyer" on Justia Law

Appellant Derrick Lingnaw, a registered sex offender, sought declaratory relief from the district court asking whether he could legally reside on his property. The district court found Lingnaw’s residence was within five hundred feet of property on which a school was located, as that term was used in Idaho Code section 18-8329(1)(d). The court thus denied Lingnaw’s request to enjoin the Custer County Sheriff, Stuart Lumpkin, from interfering with Lingnaw’s ability to reside on his property. The court also denied Sheriff Lumpkin’s request for attorney fees and costs. On appeal, the parties mainly disputed the district court’s finding that Lingnaw’s residence was within five hundred feet of a school. After review, the Idaho Supreme Court affirmed the district court's ruling that Lingnaw's property was within five hundred feet of property on which a school was located. Lingnaw raised a question of fact as to whether the building, ruled as a "school," was simply a gymnasium and building leased by the Bureau of Land Management (“BLM”); Lingnaw argued the plain meaning of “school” required some form of traditional educational instruction. The trial court found “that the gymnasium, as contemplated by the statute, is a school building utilized by the school for school functions on a regular basis . . . for sporting events and other school activities. And children are coming and going from that building on a regular basis.” Because it was “clear from the evidence” that Lingnaw’s property fell “well within” five hundred feet or the buildings’ property line, the district court found that Lingnaw lived within five hundred feet of a school. To this, the Supreme Court concurred. The district court's judgment was affirmed in all other respects. View "Lingnaw v. Lumpkin" on Justia Law

Petitioner Sherri Ybarra, the Idaho Superintendent of Public Instruction, petitioned the Idaho Supreme Court for a declaratory judgment, writ of mandamus, or writ of prohibition to remedy various alleged constitutional violations by the Idaho Legislature and the Idaho State Board of Education related to the funding and supervision of eighteen employees currently working in the Idaho Department of Education. During the 2020 legislative session, the Idaho Legislature passed two appropriation bills - Senate Bills 1409 and 1410 - which transferred supervision of eighteen full-time job positions within the Department’s Technology Group to the Board along with approximately $2.7 million in funding for those positions. The Superintendent argues that “by splitting eighteen employees away from three other workers and eliminating all funding for the office space, rent, and the maintenance and upgrading of the Department’s computers, this line item appropriation decentralizes and damages operations.” She also claimed these bills were the Legislature’s attempt to “strip the Superintendent of her authority through the budget process,” in retaliation for her failure to support a 2019 revised school funding formula. To effectuate such relief, the Superintendent invoked the Supreme Court's original jurisdiction, seeking a declaratory judgment that the Appropriation Bills were unconstitutional. The Superintendent sought a writ of mandamus and/or prohibition that would allow SB 1409's funding appropriation to the Board remain intact, but would restore the Superintendent's full management authority over the Technology Group. The Supreme Court found the Appropriations Bills constitutional, thereby declining to address requests for writs of mandamus and/or prohibition. View "Ybarra v. Legislature of the State of Idaho" on Justia Law

The State appealed a district court decision to grant defendant David Pool’s motion to suppress the results of a warrantless blood draw on the grounds that it was an unreasonable search under the Fourth Amendment to the U.S. Constitution. In 2016, a police officer came upon the scene of an automobile accident involving two vehicles, one of which was driven by Pool. Pool had failed to negotiate a turn and his vehicle was hit by oncoming traffic. He was not wearing a seatbelt and his airbag deployed in the crash. As a result, he sustained a head injury and was unconscious when the officer arrived at the scene. Pool’s son, a passenger in the vehicle, informed the officer that Pool had not been staying in his traffic lane prior to the crash. He also asserted that the doctors who had prescribed medication to Pool never told him that he could not drive while taking his medications. When Pool regained consciousness, the officer questioned him and noted that he appeared “very lethargic” and “had a presentation similar to a drunk driver . . . slurred speech and thick tongue and obviously disoriented.” Pool told the officer that he believed he had taken his prescription medications that day. Shortly thereafter, a large “baggy” containing seven bottles of prescription medication was recovered from Pool’s vehicle. The officer recognized several of the medications and suspected that they had caused Pool to be impaired. Around that time, Pool and his son were taken to the hospital. The officer followed to question Pool further. At the hospital, the officer ruled out alcohol as a cause of Pool’s impairment based upon the results of a horizontal gaze nystagmus test. The officer did not conduct other field sobriety tests, as he believed Pool’s medical condition rendered it improper for him to do so. Instead, he obtained a blood sample to be used for evidentiary testing. The issue this appeal presented for the Idaho Supreme Court's review centered on the officer’s justification for obtaining the blood sample without a warrant. The State maintained that pursuant to Idaho’s implied consent law, I.C. 18-8002(1), the search was reasonable and the district court erred in requiring proof of exigency. The Supreme Court concurred and reversed the district court. View "Idaho v. Pool" on Justia Law

The named plaintiff, Mike Zeyen sought declaratory relief and recovery of damages from Pocatello/Chubbuck School District No. 25 on behalf of all students currently enrolled in the district and their guardians. Zeyen alleged that School District 25’s practice of charging fees violated Article IX, section 1, of the Idaho Constitution. Zeyen first sought to certify the class to include all students within School District 25. Zeyen’s later motion to amend sought to add a takings claim under both the Idaho and U.S. Constitutions. The district court denied Zeyen’s motion for class certification based on lack of standing and denied his motion to amend both as untimely and prejudicial to School District 25. The Idaho Supreme Court determined Zeyen failed to show that the district court abused its discretion by denying his second motion for leave to amend the complaint. Furthermore, the Court determined Zeyen lacked standing to bring his class action suit. The Court therefore affirmed the district court's denial of Zeyen's motion to certify the class and denial of his motion for leave to amend the first amended complaint. View "Zeyen v. Pocatello/Chubbuck School Dist 25" on Justia Law

Jun Yu appealed the dismissal of his claims for alleged violations of 42 U.S.C. section 1983 and breach of contract. Idaho State University dismissed Yu from its doctoral program in clinical psychology in May 2013, with his final administrative appeal denied on October 2, 2013. Yu, a citizen of the People’s Republic of China, was completing his Ph.D. in clinical psychology at Idaho State University. He completed all the requisite coursework, wrote and defended his dissertation, but still had to complete a one-year clinical internship. After not matching any programs with the Association of Psychology Postdoctoral and Internship Centers, Yu set up an alternative internship with the Cleveland Clinic Center for Autism in Ohio. However, he was dismissed from the Ohio internship early due to performance concerns and subsequently dismissed from Idaho State University’s doctoral program. After exhausting his appeals with the university, Yu received a final letter on October 2 that denied his appeal and immediately made his dismissal effective. In March 2014, Yu filed a notice of tort claim against ISU pursuant to the Idaho Tort Claims Act (ITCA), alleging negligent infliction of emotional distress and a violation of Title VI of the 1964 Civil Right Act. Eighteen months later he filed a lawsuit in the U.S. District Court for the District of Idaho alleging violations of Title VI of the Civil Rights Act, deprivation of constitutional rights under 42 U.S.C. section 1983, and negligent infliction of emotional distress. Yu later amended his complaint to include allegations of denial of procedural and substantive due process, promissory estoppel, and breach of contract, totaling 18 claims against ISU. No individual defendants were named in the notice of claim or in his federal action. The Idaho Supreme Court affirmed the district court’s dismissal of Yu’s claims because they were untimely. View "Yu v. ID State University" on Justia Law

The Idaho Supreme Court concluded the district court did not err in dismissing the State Defendants under the Constitutionally Based Educational Claims Act (“CBECA”). This appeal arose from Russell Joki’s action challenging the constitutionality of: (1) fees charged to students of Meridian Joint District #21 ; and (2) the statewide system of funding Idaho’s public schools. Joki and sixteen other individuals (collectively referred to as “Joki”) initiated the suit against the State, the Idaho Legislature, the Idaho State Board of Education, and the Superintendent of Public Instruction (collectively referred to as the “State Defendants”), all 114 Idaho public school districts, and one charter school. The district court granted the State Defendants’ motion to dismiss. Joki argued the CBECA did not apply here, but the Supreme Court disagreed, finding: (1) the CBECA was constitutional, “it is not unreasonable for the legislature to also declare that allegations that the required educational services are not being furnished should first be addressed to the local school districts which have been given the responsibility and authority to provide those services;” and (2) Joki’s claims relating to the fees levied by the school districts fell squarely within the definition of a constitutionally based educational claim because the legislature’s duty was to provide free common schools. View "Joki v. Idaho Bd of Education" on Justia Law

Kara Alexander sued Vianna Stibal for fraud, breach of contract, and punitive damages. A jury awarded Alexander $111,000 on her contract claim, $17,000 on the fraud claim, and $500,000 in punitive damages. Stibal is the owner and operator of Nature Path, Inc. and the ThetaHealing Institute of Knowledge (THInK). In the beginning of 2008, THInK announced that it would offer a newly-created doctoral degree in ThetaHealing. students of ThetaHealing, including Alexander, began to question the validity of her doctoral degrees. In November of 2011, Alexander filed a complaint against Stibal, alleging breach of contract and fraud. During the trial, the district court denied Stibal’s motion for a directed verdict on the fraud and breach of contract claims. Following trial, Stibal moved for a new trial and for judgment notwithstanding the verdict (JNOV). The district court denied these post-trial motions, but reduced the punitive damages award to $384,000. On appeal, Stibal challenges the district court’s rulings on the contract, fraud, and punitive damages issues. After review, the Supreme Court reversed the district court’s order denying Stibal’s motion for JNOV on the contract claim. The Court vacated the district court’s judgment and remanded with directions for the district court to enter a new judgment reflecting our ruling on the contract claim and the reduction in punitive damages to $100,000. The Court affirmed in all other respects. View "Alexander v. Stibal" on Justia Law