Justia Idaho Supreme Court Opinion Summaries

The Idaho Legislature established the Community Partner Grant Program in 2021, using funds from the American Rescue Plan Act (ARPA) to address the impact of the COVID-19 pandemic on school-aged children. The funds were to be used exclusively for in-person educational and enrichment activities for children aged 5 to 13. In 2023, the Idaho Attorney General received information suggesting that some grant recipients had misused the funds to serve children under the age of five. Consequently, the Attorney General issued civil investigative demands (CIDs) to 34 grant recipients, requesting documentation related to the grant program. The recipients did not comply and instead sought a preliminary injunction in district court to set aside the CIDs.The District Court of the Fourth Judicial District of Idaho denied the preliminary injunction for 15 grant recipients, requiring them to respond to the CIDs, but granted it for 19 others, concluding that the Attorney General had not shown sufficient reason to believe these recipients had misused the funds. The court also reviewed two declarations in camera and provided redacted versions to the recipients' counsel.The Supreme Court of Idaho reviewed the case and held that both the Idaho Charitable Assets Protection Act (ICAPA) and the Idaho Charitable Solicitation Act (ICSA) applied to the grant funds, giving the Attorney General authority to issue CIDs. The court determined that the "reason to believe" standard, not probable cause, was sufficient for issuing CIDs. The court found that the district court erred in granting the preliminary injunction to the 19 recipients and remanded the case for further proceedings. Additionally, the court held that the CID issued to Elizabeth Oppenheimer was overly broad and violated her First Amendment right to freedom of association, requiring the district court to reconsider this CID. The court declined to award attorney fees to either party. View "Children's Home Society v. Labrador" on Justia Law

Several local taxing districts within Kootenai County, Idaho, including East Side Highway District, Post Falls Highway District, Worley Highway District, the City of Coeur d’Alene, and the City of Post Falls, filed claims against Kootenai County and its Treasurer, Steven Matheson. The dispute arose when Matheson decided that the County would retain all late charges and interest from delinquent property taxes to cover collection costs, rather than distributing a proportionate share to the taxing districts. The taxing districts argued that they were entitled to their share of these funds.The District Court of the First Judicial District of Idaho ruled in favor of the taxing districts, granting their motions for summary judgment and judgment on the pleadings. The court determined that Idaho Code sections 63-1015 and 63-1007(1) required the County to distribute the late charges and interest proportionately to the taxing districts. The court also awarded attorney fees to the taxing districts under Idaho Code section 12-117(4).The Supreme Court of the State of Idaho reviewed the case and affirmed the district court's judgment. The Supreme Court held that the statutory language was unambiguous and required the County to apportion late charges and interest among the taxing districts in the same manner as property taxes. The Court also upheld the award of attorney fees to the taxing districts, noting that Idaho Code section 12-117(4) mandates such an award in cases involving adverse governmental entities. The Supreme Court awarded attorney fees and costs on appeal to the taxing districts. View "East Side Hwy Dist v. Kootenai County" on Justia Law

The case involves a dispute over the interpretation and application of Idaho Code section 63-602G, which governs the homestead property tax exemption. In 2020, the Idaho Legislature amended the statute to remove the April 15 application deadline and added that the exemption "shall be effective upon the date of the application." The Idaho State Tax Commission issued guidance stating that the exemption should not be prorated based on the application date, which was supported by an Attorney General Opinion. However, Latah and Lincoln Counties disagreed and prorated the exemption based on the application date.The Counties petitioned for judicial review in their respective district courts, which were consolidated. The district court ruled in favor of the Counties, determining that the Tax Commission exceeded its authority and that the statute was ambiguous, allowing for proration based on legislative intent. The Tax Commission appealed the decision.The Supreme Court of Idaho reviewed the case and held that the plain language of Idaho Code section 63-602G requires the retroactive application of the homestead exemption to January 1 of the tax year during which the application was submitted, regardless of the application submission date. The Court found that the statute was unambiguous and that the exemption applies to the entire tax year, not prorated based on the application date.The Court also determined that the Tax Commission did not exceed its statutory authority when it issued the May 2022 Order directing the Counties to apply the full homestead exemption. The Court concluded that the Tax Commission's order was within its constitutional and statutory powers to ensure uniformity and compliance with property tax laws.The Supreme Court of Idaho reversed the district court's order, vacated the judgment, and remanded the case for entry of an order affirming the Tax Commission’s May 2022 Order. View "Latah County v. Idaho State Tax Commission" on Justia Law

South Hill Meat Lockers Incorporated (South Hill) alleged that the Idaho Transportation Department (ITD) caused damage to its building during a road construction project on U.S. Highway 95 in Bonners Ferry, Idaho. South Hill claimed ITD was liable under seven different causes of action, including negligence and constitutional violations. ITD moved for summary judgment, asserting "plan or design immunity" under Idaho Code section 6-904(7). The district court initially denied ITD's first motion for summary judgment but later granted ITD's second motion for partial summary judgment, dismissing four of South Hill's claims. After a change in judges, the new judge granted ITD's motion for reconsideration, dismissing South Hill's complaint with prejudice.The district court's rulings were mixed. Judge Buchanan initially denied ITD's first motion for summary judgment, finding genuine disputes of material fact. However, she later granted ITD's second motion for partial summary judgment, dismissing several of South Hill's claims. Upon Judge Buchanan's retirement, Judge Berecz reconsidered and granted ITD's first motion for summary judgment, dismissing all of South Hill's claims.The Idaho Supreme Court reviewed the case and vacated the district court's judgment. The court affirmed in part and reversed in part the district court's summary judgment rulings. The Supreme Court found that there were genuine issues of material fact regarding whether ITD's change orders and the gas line relocation were meaningfully reviewed, which precluded summary judgment on the basis of plan or design immunity. The court also reversed the dismissal of South Hill's nuisance claim, holding that a nuisance claim for damages can persist even after the nuisance has abated. The court affirmed the district court's rulings on other claims, including the determination that Idaho Code section 55-310 does not impose strict liability. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "South Hill Meat Lockers Incorp. v. Idaho Transportation Dept." on Justia Law

Petitioners sought to validate a portion of West Fork Pine Creek Road in Shoshone County, Idaho, which runs across private property and into public land managed by the Bureau of Land Management. The road is used by recreationalists to access an area known as "the Roller Coaster." Following disputes between local landowners and recreationalists, a petition was filed with the Shoshone County Board of Commissioners to validate the road. The Board denied the petition, citing concerns about environmental impacts, safety, and costs to taxpayers.The petitioners then sought judicial review in the District Court of the First Judicial District of Idaho, arguing that the Board erred in its decision. The district court affirmed the Board's decision, concluding that the Board's findings were supported by substantial and competent evidence. The petitioners appealed to the Supreme Court of Idaho, arguing that the district court erred in affirming the Board's conclusions.The Supreme Court of Idaho reviewed the case and determined that the Board erred in concluding that the 1909 meeting minutes did not establish the road as a public highway. However, the Court found no error in the Board's determination that validating the road was not in the public interest. The Court noted that the Board had considered various factors, including the availability of alternative access routes, the costs of surveying and maintaining the road, and the concerns of private property owners.Ultimately, the Supreme Court of Idaho affirmed the district court's decision, holding that while the road was established as a public highway in 1909, the Board did not abuse its discretion in determining that validation was not in the public interest. Neither party was awarded attorney fees on appeal. View "Jutila v. County of Shoshone" on Justia Law

A group called Idahoans United for Women and Families filed an original action in the Idaho Supreme Court seeking writs of certiorari and mandamus. They challenged the fiscal impact statement (FIS) and ballot titles prepared for a citizen initiative titled the “Reproductive Freedom and Privacy Act.” The group argued that the FIS and ballot titles did not comply with Idaho law and requested the court to either certify their versions or order the Idaho Division of Financial Management (DFM) and the Attorney General to prepare new ones.The Idaho Supreme Court dismissed the petition against the Secretary of State, as Idahoans United failed to specify the writ or what they sought to compel. The court partially granted the writ of mandamus against DFM, finding that the FIS did not substantially comply with Idaho Code section 34-1812 due to a lack of a reasonable basis for its estimated fiscal impact, unclear language, and unnecessary legal terms. The court also partially granted the writ of mandamus against the Attorney General, concluding that the short ballot title did not substantially comply with Idaho Code section 34-1809 because it failed to capture all distinctive features of the initiative. However, the court found that the long ballot title substantially complied with the statutory requirements.The Idaho Supreme Court retained jurisdiction and ordered DFM to provide a new FIS and the Attorney General to provide a new short ballot title by a specified deadline. The court declined to certify the versions provided by Idahoans United and did not award attorney fees to any party. Upon submission, the court reviewed the new FIS and short ballot title, concluding that both substantially complied with the statutory requirements and certified the new short ballot title to the Idaho Secretary of State. View "Idahoans United for Women and Families v. Labrador" on Justia Law

Lisa Sánchez, a member of the Boise City Council, moved her residence outside of the district she represented. She was informed by the mayor and city council that she had automatically vacated her seat due to this move. The mayor subsequently appointed a new council member to fill her seat. Sánchez sued the City of Boise, claiming improper removal and seeking reinstatement, along with damages for lost salary and benefits. The City moved for judgment on the pleadings, which the district court granted, dismissing her case with prejudice. Sánchez appealed, questioning whether a city council member automatically vacates their seat under Idaho Code section 59-901(1)(e) when they unintentionally move out of their district.The district court concluded that Idaho Code section 59-901(1)(e) applies to city council members and that Sánchez's intent to remain a resident of her district was irrelevant. The court held that the statute's plain language indicated an automatic vacancy upon moving out of the district, regardless of intent. The court also found that Sánchez received all due process required under the statute.The Supreme Court of Idaho affirmed the district court's decision. The court held that Idaho Code section 59-901(1)(e) applies to city council members and that the statute's plain language does not require an inquiry into the official's intent. The court also concluded that no additional due process was required because any potential property interest in Sánchez’s elected position was forfeited when she moved out of her district. Thus, the district court's judgment on the pleadings in favor of the City was affirmed. View "Sanchez v. City of Boise" on Justia Law

A group called Idahoans United for Women and Families filed a petition seeking writs of certiorari and mandamus against the Idaho Division of Financial Management (DFM), the Idaho Attorney General, and the Idaho Secretary of State. The petition concerns the fiscal impact statement (FIS) and ballot titles for a citizen initiative titled the “Reproductive Freedom and Privacy Act.” Idahoans United argued that the FIS and ballot titles did not comply with Idaho law and requested the court to either certify their proposed versions or order the respondents to prepare new compliant versions.The Idaho Supreme Court reviewed the case. The court dismissed the petition against the Secretary of State, finding that Idahoans United failed to properly invoke the court's original jurisdiction against him. However, the court partially granted the writ of mandamus against DFM, concluding that the FIS did not substantially comply with Idaho Code section 34-1812 due to a lack of a reasonable basis for its estimated fiscal impacts, unclear and conflicting statements, and unnecessary legal terms. The court also partially granted the writ of mandamus against the Attorney General, finding that the short ballot title did not substantially comply with Idaho Code section 34-1809 because it failed to capture all distinctive features of the initiative. However, the court found that the long ballot title substantially complied with the statutory requirements.The Idaho Supreme Court retained jurisdiction and ordered DFM to provide a new FIS and the Attorney General to provide a new short ballot title by June 23, 2025. The court denied the request for attorney fees, noting that both parties prevailed in part. View "Idahoans United for Women and Families v. Labrador" on Justia Law

The case involves the City of Lava Hot Springs, which regulates short-term rentals based on whether they are occupied by an owner or manager. Non-owner-occupied short-term rentals are prohibited in residential zones and only allowed in commercial zones. John and Michelle Taylor applied for a business license to operate a non-owner-occupied short-term rental in a residential zone, but the City denied their application. The Taylors, along with the Idaho Association of Realtors, sued the City, claiming that its regulations violated the Short-term Rental and Vacation Rental Act, which limits municipal regulations on short-term rentals.The district court granted summary judgment in favor of the City, finding that the City's regulations did not have the express or practical effect of prohibiting short-term rentals and were permissible under the health, safety, and welfare exception in the Act. The court concluded that because at least one type of short-term rental (owner-occupied) was allowed in residential zones, the City had not violated the Act. The Taylors and the Realtors appealed this decision.The Supreme Court of Idaho reviewed the case and reversed the district court's decision. The Court held that the City's ordinance, which prohibited non-owner-occupied short-term rentals in residential zones, violated the Short-term Rental and Vacation Rental Act. The Act prohibits any city ordinance that has the express or practical effect of prohibiting short-term rentals. The Court found that the City's ordinance amounted to a prohibition rather than a regulation and thus invalidated the ordinance. The Court awarded costs on appeal to the Petitioners but did not grant attorney fees to either party. View "Idaho Association of Realtors, Inc. v. City of Lava Hot Springs" on Justia Law

Sean C. Flynn was laid off from his full-time job at Sun Valley Brewing Company during the COVID-19 pandemic and applied for unemployment benefits from the Idaho Department of Labor (IDOL) on March 25, 2020. Flynn received unemployment benefits from March 29, 2020, through June 27, 2020, while he was still employed part-time as a French teacher for the Community School, Inc. Flynn did not report his earnings from the Community School on the weekly certification forms required by IDOL. Additionally, when Flynn returned to full-time work at Sun Valley Brewing, he inaccurately reported his income for the week ending June 27, 2020.Flynn's claim for unemployment benefits was audited two years later, revealing discrepancies in his reported income. IDOL issued an eligibility determination letter retroactively denying Flynn's unemployment benefits and imposing civil penalties for willfully making false statements or failing to report material facts. Flynn appealed to the Idaho Department of Labor Appeals Bureau, arguing that his omissions were honest mistakes. The Appeals Examiner modified IDOL’s determination, finding Flynn misunderstood the reporting requirements for his part-time job but willfully misreported his income from Sun Valley Brewing for one week.IDOL appealed to the Idaho Industrial Commission, which conducted a de novo review and reversed the Appeals Examiner’s decision. The Commission reinstated IDOL’s original eligibility and overpayment determinations, concluding that Flynn’s omissions were willful based on the explicit instructions provided by IDOL and Flynn’s repeated failure to accurately report his income.The Supreme Court of Idaho affirmed the Commission’s decision, holding that Flynn’s omissions constituted a willful misstatement or concealment of material facts under Idaho Code section 72-1366(12). The Court determined that Flynn knew or should have known the necessity of reporting all income, and his failure to do so was intentional. Neither party was awarded attorney fees on appeal. View "Flynn v. Sun Valley Brewing Company" on Justia Law