Justia Idaho Supreme Court Opinion Summaries

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

Sentry Dynamics, Inc. (Sentry) requested a list of all property owners' names and addresses in Ada County from the Ada County Assessor’s Office. Ada County denied the request, suspecting Sentry intended to sell the data for use as a mailing or telephone list, which is prohibited under Idaho Code section 74-120(1). Sentry filed a complaint in district court seeking access to the records. The district court ordered Ada County to release the records in an electronic format of its choosing. Ada County appealed, and Sentry cross-appealed, requesting the records in the shapefile format used by the County.The district court of the Fourth Judicial District of Idaho ruled that the information Sentry sought was a public record and constituted a "list of persons" under Idaho Code section 74-120(1). The court held that Sentry was entitled to the records because it agreed not to use them as a mailing list. However, the court allowed Ada County to choose the electronic format for providing the records. Ada County appealed, arguing that Sentry did not assure the data would not be used for mailing list purposes by third parties. Sentry cross-appealed, seeking the records in their original shapefile format.The Supreme Court of Idaho reviewed the case and held that the records requested by Sentry constituted a "list of persons" and that Ada County could require Sentry to assure that the data would not be used for mailing purposes by its clients and customers. The court affirmed the district court's ruling that paragraphs 3, 4, and 6 of Ada County’s "Acknowledgment and Agreement" form went beyond the permissible inquiry under Idaho Code section 74-102(5)(b). However, the court reversed the district court's order requiring Ada County to provide the records in an electronic format, stating that the PRA does not mandate delivery in any specific format. The court concluded that Ada County was not required to produce the records because Sentry refused to certify that neither it nor its clients would use the records as a mailing list. View "Sentry Dynamics, Inc. v. Ada County" on Justia Law

Samuel and Peggy Edwards, residents of Rexburg, Idaho, refused to allow PacifiCorp, doing business as Rocky Mountain Power Company, to install a smart electrical meter on their property due to health concerns. Rocky Mountain considered this refusal a violation of its terms of service, which required access to electrical meter bases. After negotiations failed, Rocky Mountain informed the Edwards that their electrical service would be terminated unless they allowed the installation. The Edwards filed a formal complaint with the Idaho Public Utilities Commission (PUC), arguing they had not denied access and should be allowed to opt-out of the smart meter installation.The PUC consolidated the Edwards' complaint with similar complaints from other customers and granted Rocky Mountain's motion to dismiss, concluding that the Edwards had not provided evidence that smart meters presented a legitimate safety concern and that Rocky Mountain had the authority to access and replace meters. The Edwards' motion for reconsideration was also dismissed by the PUC, leading them to appeal to the Idaho Supreme Court.The Idaho Supreme Court reviewed whether the PUC properly determined that Rocky Mountain had the authority to access the Edwards' property to replace the existing meter with a smart meter. The Court affirmed the PUC's decision, concluding that the tariff provisions allowed Rocky Mountain to access and replace meters. The Court also found that the Edwards' constitutional arguments were waived due to insufficient support and authority. The PUC's orders dismissing the Edwards' complaint and denying reconsideration were affirmed. View "Edwards v. IPUC" on Justia Law

Sunnyside Park Utilities, Inc. (SPU) provides water and sewer services to commercial properties in Bonneville County, Idaho. Donald Sorrells, the owner of a lot in the Sunnyside Industrial & Professional Park, received a "Will Serve" letter from SPU in 2018, agreeing to provide water and sewer services based on his representation that he would install only two restrooms. However, Sorrells installed additional unauthorized water and sewer connections, leading to repeated excessive discharges into SPU's septic system. Despite multiple notices and requests for remediation from SPU, Sorrells failed to address the issues adequately, resulting in SPU seeking a declaratory judgment against him.The District Court of the Seventh Judicial District of Idaho found that Sorrells was a persistent violator of SPU's Sewer Rules and Regulations but determined that the Idaho Public Utilities Commission (IPUC) retained original jurisdiction over SPU's water system. The court denied SPU's requests for costs and attorney fees, leading to appeals from both parties.The Supreme Court of Idaho reviewed the case and affirmed the district court's judgment. The court held that the district court did not err in granting a declaratory judgment to SPU regarding Sorrells' violations of the sewer rules. However, it also upheld the district court's determination that the IPUC initially had jurisdiction over SPU's water system, as SPU had not established its nonprofit status at the time of filing. The court further affirmed the denial of attorney fees and costs to SPU, concluding that the Rules and Regulations did not expressly provide for such fees.On appeal, the Supreme Court declined to consider the merits of Sorrells' arguments due to his failure to comply with the Idaho Appellate Rules. The court also denied SPU's request for attorney fees and costs on appeal, as SPU did not prevail on its cross-appeal. View "Sunnyside Park Utilities, LLC v. Sorrells" on Justia Law

In 2019, Colby James Bray died while in the custody of the Idaho Department of Juvenile Corrections (IDJC). His parents, Jeffrey and Michelle Bray, acting as personal representatives of his estate, filed a wrongful death suit in federal court one day before the two-year statute of limitations expired. They later voluntarily dismissed the federal case and refiled in state court nearly three years after Colby's death. The defendants moved for summary judgment, arguing the claims were time-barred by the two-year statute of limitations. The district court granted the motions and dismissed the complaint with prejudice.The Brays appealed, arguing that Idaho Code section 5-234 and 28 U.S.C. section 1367(d) tolled the statute of limitations. The district court had concluded that section 5-234 did not toll the time for filing the state complaint and that section 1367(d) did not apply to IDJC due to Eleventh Amendment immunity. The court also awarded costs and attorney fees to the defendants.The Supreme Court of Idaho affirmed the district court's ruling that section 5-234 did not toll the statute of limitations. It also agreed that the claims against Meacham and the Individual Defendants were time-barred under section 1367(d) because the Brays did not file within 30 days after the federal court dismissed those claims. However, the court found that section 1367(d) did toll the time for filing the complaint against IDJC, but IDJC was immune from the claims under Idaho Code section 6-904B(5). The court upheld the district court's award of attorney fees and costs to the defendants and awarded attorney fees and costs on appeal to the respondents. View "Bray v. ID Dept of Juvenile Corrections" on Justia Law

Interfaith Sanctuary Housing Services, Inc. (IFS) applied for a conditional use permit (CUP) to operate a large-scale low-barrier shelter home in Northwest Boise. The Planning and Zoning Commission (PZC) initially denied the application, citing concerns about compatibility with the neighborhood, undue burden on public facilities, adverse effects on nearby properties, and insufficient information on mitigating adverse impacts. IFS appealed to the Boise City Council, which reversed the PZC’s decision and granted the CUP, imposing 30 conditions of approval. The Veterans Park Neighborhood Association, Inc. (VPNA) sought reconsideration, which was denied, and then petitioned the district court for judicial review.The district court upheld the City Council’s decision, finding no error in the Council’s actions. VPNA appealed to the Idaho Supreme Court, arguing that the City Council’s decision was arbitrary and capricious, based on unlawful procedure, and that the Council’s reasoned statement was inadequate under the Local Land Use Planning Act (LLUPA).The Idaho Supreme Court found that the City Council’s decision was arbitrary and capricious and based on unlawful procedure because the PZC’s determination that the CUP could not be conditioned into compliance with the CUP criteria was not an error. The Court also found that the City Council’s reasoned statement was conclusory and failed to adequately resolve pertinent factual disputes, thus violating LLUPA and depriving VPNA of due process. The Court concluded that VPNA demonstrated a prejudice to its substantial rights.The Idaho Supreme Court reversed the district court’s decision and remanded the case with instructions to invalidate the City Council’s approval of the CUP. VPNA was awarded costs but not attorney fees on appeal. View "Veterans Park Neighborhood Association, Inc. v. City of Boise" on Justia Law

Chesla A. Scott challenged the Idaho Department of Labor's service of three determination notices, claiming she did not receive them while temporarily working out-of-state. The Department mailed the notices to her last known address, and Scott missed the fourteen-day appeal period. When she attempted to appeal, the Department's Appeals Examiner dismissed her appeal as untimely. Scott argued that the Department's service by mail did not meet constitutional due process requirements.The Appeals Examiner conducted a hearing and concluded that Scott's appeal was untimely under Idaho Code section 72-1368(3) and (5). The Idaho Industrial Commission affirmed this decision, denying Scott's request for a new hearing and conducting a de novo review of the record. The Commission also concluded that Scott had not timely filed her appeal.Scott appealed to the Idaho Supreme Court, arguing that the Department's service by mail was constitutionally inadequate. The Court reviewed whether Scott exhausted her administrative remedies and preserved her constitutional challenge. The Court held that Scott had exhausted her administrative remedies and preserved her due process claim, allowing it to be reviewed.The Idaho Supreme Court affirmed the Commission's decision, holding that the Department's mailing of the determination notices was reasonable under all the circumstances and did not violate due process. The Court found that the Department's method of service was reasonably calculated to provide notice, and Scott's failure to receive the notices was not due to any fault of the Department. The Court did not award attorney fees to either party but awarded costs to the Department. View "Scott v. Home Depot USA, Inc." on Justia Law

Sherry Cole filed a formal complaint against Rocky Mountain Power (RMP) alleging she had been overbilled due to her power meter being cross-connected with her neighbor’s. Initially, an RMP employee confirmed the cross-connection and credited her account with $1,256.45. However, subsequent tests revealed no cross-connection, leading RMP to remove the credit and instead apply a $450 credit for the inconvenience. Cole then filed a complaint with the Idaho Public Utilities Commission, which dismissed her complaint due to lack of evidence of overcharging. Cole's motion for reconsideration was also denied by the Commission.Cole appealed to the Idaho Supreme Court. The Commission had reviewed Cole’s complaint, RMP’s billing calculations, and an analysis by Jon Kruck, an investigator, which concluded that Cole’s energy usage was consistent and did not indicate a cross-connection. The Commission found no substantial evidence supporting Cole’s claims and dismissed her complaint. Cole’s petition for reconsideration was denied as she failed to present new evidence or demonstrate that the dismissal was unreasonable or unlawful.The Idaho Supreme Court affirmed the Commission’s decision, finding that the Commission’s factual findings were supported by substantial and competent evidence. The Court noted that Cole relied on anecdotal evidence and did not provide sufficient proof to counter the Commission’s findings. Additionally, the Court held that Cole’s constitutional arguments were waived as they were raised for the first time on appeal and were not supported by sufficient legal authority. The Court also denied Cole’s request for attorney fees, as pro se litigants are not entitled to such fees.The Idaho Supreme Court affirmed the orders of the Idaho Public Utilities Commission dismissing Cole’s complaint and denying her petition for reconsideration. View "Cole v. IPUC" on Justia Law

The Idaho State Board of Education approved a proposal for the University of Idaho to purchase the University of Phoenix for $550 million, funded by a $685 million bond. This decision followed three closed-door executive sessions. Idaho Attorney General Raúl R. Labrador filed a suit to void the sale, alleging violations of the Idaho Open Meetings Law, which mandates that public policy formation be conducted openly. The district court dismissed the suit, finding no violations.The district court ruled that the Board's actions during the executive sessions were lawful under the exception in Idaho Code section 74-206(1)(e), which allows closed meetings for preliminary negotiations involving trade or commerce when in competition with other states. The court interpreted "preliminary negotiations" to include all negotiations before contracting and applied a "reasonable belief" standard to determine if the Board believed it was in competition with another governing body.The Idaho Supreme Court reviewed the case and found that the district court erred in its broad interpretation of "preliminary negotiations" and the application of the "reasonable belief" standard. The Supreme Court held that "preliminary negotiations" should be narrowly construed to mean a phase of negotiations before final negotiations, and the statute requires actual competition, not just a reasonable belief of competition. The court vacated the district court's summary judgment, its judgment following the bench trial, and the award of attorney fees and costs to the Board. The case was remanded for further proceedings consistent with the Supreme Court's interpretation of Idaho Code section 74-206(1)(e). View "Labrador v. Board of Education" on Justia Law

Adrian Renee Soliz was found unconscious behind the wheel of his vehicle, which was impeding traffic. Concerned, a passerby called 9-1-1, and emergency responders arrived at the scene. They discovered drug paraphernalia on Soliz's lap while providing medical assistance for what was later confirmed to be a drug overdose. Soliz was subsequently charged with possession of a controlled substance, possession of drug paraphernalia, and other related offenses.Soliz filed a motion to dismiss the charges, arguing that under Idaho’s overdose immunity statute (Idaho Code section 37-2739C(2)), he should be immune from prosecution because the evidence was obtained as a result of his medical emergency. The State opposed the motion, contending that the evidence was discovered during a traffic investigation, not solely due to the medical emergency. The district court denied Soliz’s motion, concluding that the evidence was not obtained solely as a result of the medical emergency.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision. The Court held that the phrase “as a result of” in the overdose immunity statute means that the drug-related medical emergency must be the sole cause of the discovery of evidence. Since the evidence was discovered during both a traffic investigation and a medical emergency response, the statute did not apply. Therefore, Soliz was not entitled to immunity, and the district court’s denial of his motion to dismiss was upheld. View "State v. Soliz" on Justia Law