Justia Idaho Supreme Court Opinion Summaries

Articles Posted in Government & Administrative Law
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This case arose from an Idaho Industrial Commission determination denying an application for unemployment benefits. William Wittkopf appealed pro se the Commission’s determination that he was ineligible for unemployment benefits because he voluntarily quit his job without good cause and he willfully made a false statement or willfully failed to report a material fact in his unemployment application. On appeal, Wittkopf challenged the factual findings made by the Commission and argued it violated his right to due process by taking into consideration the fact that he voluntarily terminated his employment approximately two and a half years prior to applying for unemployment benefits. After review, the Idaho Supreme Court concluded: (1) Wittkopf failed to provide a cogent argument on appeal regarding whether his right to due process was violated; (2) the Commission’s determination that Wittkopf voluntarily terminated his employment at Stewart’s Firefighter without good cause and without exhausting all reasonable alternatives was supported by substantial and competent evidence; and (3) the Commission’s determination that Wittkopf willfully made a false statement or willfully failed to report a material fact in order to obtain benefits was supported by substantial and competent evidence. Accordingly, the Commission’s decision and order denying Wittkopf’s application for unemployment benefits was affirmed. View "Wittkopf v. Stewart's Firefighter Food Catering, Inc." on Justia Law

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At issue in this appeal was whether claimant Curtis Stanley filed a timely complaint against the Industrial Special Indemnity Fund ("ISIF") when Stanley filed his complaint more than five years after his industrial accident and more than one year after receiving his last payment of income benefits. The Idaho Industrial Commission (“Commission”) held it did not have continuing jurisdiction to entertain Stanley’s complaint against ISIF for non-medical benefits. The Commission found Idaho Code section 72-706 barred Stanley’s complaint and dismissed it. Stanley appealed, arguing continuing jurisdiction over medical benefits alone was sufficient to confer jurisdiction over complaints against ISIF and that the Commission erred in determining section 72-706 barred his complaint. Finding the Commission erred in determining section 72-706 barred Stanley's complaint, the Idaho Supreme Court reversed the Commission’s decision. View "Stanley v. Idaho Industrial Special Indemnity Fund" on Justia Law

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This appeal stemmed from a dispute between the presiding officers of the Idaho Legislature and the Idaho State Treasurer. The Speaker of the Idaho House of Representatives and the President Pro Tempore of the Idaho State Sentate sought to evict Treasurer Julie Ellsworth from her current office on the first floor of the Idaho State Capitol building pursuant to Idaho Code section 67-1602(3). The office of the State Treasurer was historically located in the southeast quadrant of the Capitol Building. However, plaintiffs cited the need for more legislative space to evict the Treasurer from that historic office. The Treasurer refused to vacate, relying on a purported agreement base between the Governor and the 2007 leadership of the Idaho Legislature. Finding that the political question doctrine did not preclude it from reaching the merits of this dispute, the Idaho Supreme Court concluded Idaho Code section 67-1602(3) unambiguously authorized the presiding officers to determine the use and allocate the space within the first floor of the Capitol. The district court's denial of the Treasurer's motion to dismiss was affirmed; summary judgment in favor of the House and Senate were also affirmed. View "Bedke v. Ellsworth" on Justia Law

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At the heart of this case was a highway right-of-way proposed and approved in 1908 by the Kootenai County Board of Commissioners (the Board), then purportedly abandoned in 1910. This appeal arose from a decision of the East Side Highway District, the Board’s successor-in-interest, in which it declined to validate this highway right-of-way. In 2017, Gloria Palmer, Trustee of the Palmer Family Trust (the Trust) requested that the District validate the right-of-way. This was opposed by Rande and Debra Warner, and Steffen and Allison Teichmann, over whose land the purported right-of-way traversed. The Warners sought to have the right-of-way abandoned. The Highway District initiated road validation proceedings, after which it declined to validate "Leonard Road No. 2." After this decision, the Highway District granted a motion for reconsideration and reopened the public hearing. After hearing additional evidence and public comments, the Highway District again declined to validate the purported right-of-way. The Trust petitioned the district court for judicial review. The district court affirmed the Highway District’s decision. The Trust again appealed. Finding no reversible error or abuse of discretion, the Idaho Supreme Court affirmed the district court. View "Palmer v. ESHD" on Justia Law

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At issue before the Idaho Supreme Court in this case was whether the Public Records Act authorized the Idaho Department of Correction (“Department”) to withhold certain records in response to a public records request. In 2017, Aliza Cover requested records relating to the use of the death penalty in Idaho. The Department provided some records in response, but withheld or redacted others, claiming these records were exempt from disclosure in whole or in part under Board of Correction Rule 135.06 (“Rule 135”). The Department argued Rule 135 was promulgated pursuant to a provision of the Public Records Act that allowed the Board of Correction (“Board”) to identify records as exempt from disclosure through rulemaking. Because there was no evidence that the Board promulgated Rule 135 as a public records exemption, the Supreme Court reversed the district court's judgment permitting the Department to withhold records from Cover on this basis, and remanded for further proceedings. View "Cover v. ID Board of Correction" on Justia Law

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This appeal arose from a dispute over the construction of a ready-mix concrete manufacturing facility in Teton County, Idaho. In 2007, Burns Holdings entered into a development agreement with Teton County regarding property owned by Burns Concrete. The development agreement required the construction of a permanent concrete manufacturing facility on the property within 18 months of the execution of the agreement, but allowed operation of a temporary facility in the meantime. Burns Concrete, the concrete company that would operate the facility, and Burns Holdings, a holding company that was to eventually take title to the property, wanted to build a permanent facility that was 75-feet tall, but the applicable zoning ordinance limited building heights to 45-feet. The County denied Burns Holdings’ application for a conditional use permit and its subsequent application for a variance to exceed the height limit. The Burns Companies operated the temporary facility for several years but never constructed the permanent facility. In 2012, the County sent written notice revoking the authority to operate the temporary facility and demanding that the temporary facility be removed. The Burns Companies subsequently filed this action, stating claims for breach of contract, declaratory judgment, and unjust enrichment. The County counterclaimed, alleging breach of contract and seeking declaratory judgment for the removal of the temporary facility. This began a multi-year period of litigation that included two appeals to the Idaho Supreme Court, each followed by a remand to the district court. This case has returned to the Supreme Court again, this time as a result of the parties’ cross-appeals of the district court’s grant of partial summary judgment in favor of the Burns Companies on their breach of contract claim, its award of $1,049.250.90 in damages, and its award of attorney fees. The Supreme Court affirmed the district court’s grant of partial summary judgment on the issue of breach of contract, but vacated the district court’s judgment for a recalculation of damages. In its recalculation of damages, the district court was instructed to reverse its reduction of damages by the difference between the Temporary Facility’s sales and cost of sales. The Supreme Court vacated the district court’s award of attorney fees and remanded the matter for an explanation of the district court’s reduction of requested attorney fees. View "Burns Concrete v. Teton County" on Justia Law

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Connie Schoeffel worked for Thorne Research, Inc. (“Thorne”) as a kitchen manager. In 2016, Thorne announced that it would be moving its operations from Idaho to South Carolina. For those employees who would not be relocating to South Carolina, Thorne offered an employee retention program to encourage them to continue working at the Idaho facility until the South Carolina facility was ready. As part of this program, Thorne prepared a “Release of Claims Agreement” (“the Agreement”) providing that Thorne would pay participating employees “bargained-for compensation” in exchange for giving up certain rights, including the right to quit before their positions were eliminated. Schoeffel signed this Agreement approximately six weeks before her last day of work. After her separation, Schoeffel filed for unemployment benefits without reporting the retention payments as income. Around the time Schoeffel received her fourth benefit payment, the Department learned of the payments that Thorne owed Schoeffel under the Agreement. The Department determined that those payments constituted reportable “severance pay” under Idaho Code section 72-1367(4). Consequently, the Department determined that Schoeffel was receiving severance pay and was required to repay the unemployment benefits she had received. Schoeffel appealed to the Department’s Appeals Bureau, which initially ruled in her favor but affirmed the Department’s decision on reconsideration. Schoeffel then appealed to the Industrial Commission which affirmed the Appeals Bureau’s decision. The Idaho Supreme Court determined the payments were reportable severance pay, applying Parker v. Underwriters Labs, Inc., 96 P.3d 618 (2004). "[B]ecause the primary purpose of the Agreement was to secure the relinquishment of Schoeffel’s right to quit, rather than to compensate her for her past service to Thorne, they were not made 'as a result of' severance under Idaho Code section 72-1367(4). Therefore, the retention payments do not constitute reportable severance pay." The Commission's decision was reversed. View "Schoeffel v. Idaho Dept. of Labor" on Justia Law

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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

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The Idaho Department of Finance ("Department") filed a civil enforcement action against appellant appellant, Sean Zarinegar, Performance Realty Management LLC ("PRM") and other nominal defendants, alleging Zarinegar and PRM committed securities fraud. The Department moved for summary judgment; Zarinegar and PRM responded with their own motion for partial summary judgment and a motion to strike several documents submitted by the Department in support of its motion for summary judgment. A few days before the district court was set to hear arguments on the motions, counsel for Zarinegar and PRM moved the district court for leave to withdraw as counsel of record. At the hearing, the district court preliminary denied the motion to withdraw, entertained the parties’ arguments, and took all matters under advisement. The district court later issued a memorandum decision and order denying, in part, Zarinegar’s, and PRM’s motions to strike. The district court also denied Zarinegar’s and PRM’s motion for partial summary judgment. The district court granted summary judgment for the Department after finding Zarinegar and PRM had misrepresented and omitted material facts in violation of Idaho Code section 30-14-501(2) and fraudulently diverted investor funds for personal use in violation of section 30-14-501(4). The district court then granted the motion to withdraw. The district court entered its final judgment against Zarinegar and PRM September 30, 2019. Zarinegar, representing himself pro se, appealed the judgment, arguing: (1) the district court lacked jurisdiction to enter judgment against him; (2) the district court violated his constitutional right to a jury trial and right to proceed pro se; (3) the district court’s denial of Zarinegar’s motions to strike as to certain documents was an abuse of discretion; and (4) the district court erroneously granted summary judgment for the Department. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgment. View "Idaho v. Zarinegar" on Justia Law

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Kirby Vickers filed a grievance letter with Idaho Board of Veterinary Medicine (the Board”) against a veterinarian requesting that they take various disciplinary actions. After an investigation, the Board declined to take any action against the veterinarian. Vickers then filed suit in district court, seeking to compel the Board to hold a hearing. The district court dismissed his suit for lack of subject-matter jurisdiction. On appeal, Vickers argued his letter to the Board initiated a contested action for which he was entitled to judicial review. To this, the Idaho Supreme Court disagreed, finding that a private citizen could not initiate a "contested case" with a grievance letter. Vickers points to the language in caselaw: “[t]he filing of a complaint initiates a contested case,”to argue that any public citizen could file a complaint pursuant to Idaho Rule of Administrative Procedure of the Attorney General (“IDAPA”) 04.11.01.240.02 and begin a contested case. However, the Supreme Court found both the Administrative Procedures Act (APA) and the corresponding IDAPA rules, addressed only agency actions. "Vickers cannot apply these rules to his grievance letter, even if it was referred to as a “complaint” in correspondence from the Board, because it is not an agency action under the APA or IDAPA." The Court affirmed the district court's order dismissed this case for lack of subject-matter jurisdiction. View "Vickers v. Idaho Bd of Veterinary Medicine" on Justia Law