Justia Idaho Supreme Court Opinion Summaries

Bennett Day, Trustee of Trust B of the Donald M. and Marjorie D. Day Family Trust, John Day, Dan E. Day, Holcomb Road Holdings, LLC, Donna Day Jacobs, and David R. Day (collectively, the Day family) appealed a district court's decision dismissing their claims against the State of Idaho and the Idaho Transportation Department (the Department). This case related to certain property the Day family owned near Isaacs Canyon in Ada County, Idaho. In the 1990s, the State began working on the Isaacs Canyon Interchange near the Day property. The frontage road (Eisenman Road) was extended to the interchange. Eisenman Road did not reach the Day property. In late 1997, which the parties each stipulated was the date for valuation of any taking, the Department substantially completed construction of the Isaacs Canyon Interchange project. After the interchange was completed, the State transferred jurisdiction and maintenance of Eisenman Road southwest of the Interchange to the Ada County Highway District (ACHD). In 2014, the Department applied to ACHD to obtain access from Eisenman Road to the Day property. In 2015, the Department offered the Day family $560,000 to build an access road themselves, but the Days rejected the offer. In May 2016, ACHD advised the Department that it would “not accept a public street” needed to create the access desired by the Day family. Following ACHD’s denial of the Department’s application, the Day family filed this action, asserting claims against the Department for inverse condemnation, breach of contract, and breach of the implied covenant of good faith and fair dealing. Both parties moved for partial summary judgment and the Department moved to dismiss the Day family’s complaint. The Day family appealed when the district ocurt dismissed its claims. Their appeal presented for the Idaho Supreme Court's review: (1) a question of whether the district court erred by considering the Department’s motion to dismiss without notifying the Day family that it would consider matters outside of the pleadings; (2) a question of whether the district court correctly dismissed the Day family’s claims for lack of standing and for untimeliness; and (3) whether either party was entitled to an award of attorney fees on appeal. The Supreme Court determined the district court: erred in granting summary judgment for the Department on all of the Day family’s inverse condemnation claims; erred by granting summary judgment on the contract claim; and incorrectly held that the statute of limitations barred the inverse condemnation claims of Donna Day Jacobs and David R. Day. Furthermore, the Court determined the district court erred by dismissing the Day family’s contract-based claims. View "Day v. Idaho Transportation Dept" on Justia Law

Natalie Shubert filed a negligence claim against her former public defender, Michael Lojek, former Ada County chief public defender Alan Trimming, and Ada County (collectively, “Ada County Defendants”). In 2008, Shubert was charged with two felonies and pleaded guilty to both charges. Her sentences were suspended in each case, and she was placed on probation. After a probation violation in 2011, the Ada County district court entered an order extending Shubert’s probation beyond the time period allowed by law, and the mistake was not caught. After Shubert’s probation should have ended in both cases, she was charged and incarcerated for a subsequent probation violation in 2014. Thereafter, in 2016, Shubert was charged with a new probation violation. Shubert was assigned a new public defender, who discovered the error that unlawfully kept Shubert on probation. Shubert’s new public defender filed a motion to correct the illegal sentence, raising the error that had improperly extended her probation. The district court granted Shubert’s motion to correct the illegal sentence and released Shubert from custody. Shubert then sued her original public defender, the Ada County Public Defender’s Officer, and other unknown Ada County employees alleging false imprisonment, intentional infliction of emotional distress, negligence per se, negligence, and state and federal constitutional violations. The district court dismissed all of Shubert’s claims except for negligence. In denying the Ada County Defendants’ motion for summary judgment on Shubert’s negligence claim, the district court held that public defenders were not entitled to common law quasi-judicial immunity from civil malpractice liability, and two provisions of the Idaho Tort Claims Act (ITCA) did not exempt public defenders from civil malpractice liability. The Ada County Defendants petitioned the Idaho Supreme Court, but the Supreme Court affirmed, finding the district court did not err in its finding that the public defenders and the County were not entitled to immunity. The case was remanded for further proceedings. View "Shubert v. Ada County" on Justia Law

In an expedited appeal to the Idaho Supreme Court, a magistrate court terminated Jane Doe’s (“Mother”) parental rights after finding clear and convincing evidence that Mother neglected her children, K.M. and R.M., and that termination was in the best interests of the children. Mother did not appeal the magistrate’s finding that she neglected her children. She only appealed the magistrate court’s finding that termination was in the best interests of the children. The magistrate court found Mother’s testimony lacked credibility and relied on other witnesses to find that Mother had neglected her children under Idaho Code section 16-2005(1)(b) because Mother had failed to reunify with her children and had failed to comply with her case plan. According to Mother, termination was not in the best interests of her children because Mother had a close bond with her children, K.M. was not responding well to foster care, there was no evidence of violence between Mother and her children, and Mother tried to the best of her ability to comply with her case plan. The Supreme Court found substantial evidence supported the magistrate court's finding that termination was in the children's best interests, and affirmed. View "Idaho Dept. of Health & Welfare v. Jane Doe (2019-27)" on Justia Law

Mother Jane Doe appealed a magistrate court’s s decree terminating her parental rights. Both Mother and her child (Child) tested positive for methamphetamine when he was born. Law enforcement declared that Child was in imminent danger, and the Idaho Department of Health and Welfare (IDHW or Department) assumed temporary custody. A case plan for reunification was adopted, focusing on Mother’s substance abuse and mental health issues, and on obtaining safe and stable housing. Mother made no progress on her case plan, and was subsequently incarcerated. IDHW petitioned to terminate Mother’s paternal rights. After a termination hearing in September 2019, where Mother argued that her recent sobriety and improved lifestyle justified the denial of the Department’s petition, the magistrate court entered a decree terminating Mother’s parental rights based on Mother’s neglect and the best interests of the child. After review, the Idaho Supreme Court found no abuse of discretion, and affirmed the magistrate court’s decree. View "Idaho Dept. of Health & Welfare v. Jane Doe (2019-32)" on Justia Law

Mother Jane Doe appealed a magistrate court’s termination of her parental rights to her minor son, A.V. The magistrate court concluded that the Department proved by clear and convincing evidence that Mother and John Doe (“Father”) neglected A.V. and that termination was in A.V.’s best interests (Father’s termination was the subject of a separate appeal (Dkt. No. 47200)). A.V. went into foster care in November 2017, when he was approximately two-and-a-half years old. The child was malnourished; health care providers testified the child was four to six months developmentally delayed. November 2017 was his second trip to foster care; social workers found A.V. weighed less than he had in his first trip a year before, "the size and weight of a twelve-month-old." In response to a question about why she thought A.V. was losing weight in the time period before he was placed into care in November of 2017, Mother testified that she was dealing with a very big loss—the death of her mother by suicide—and unfortunately she let it get in the way of her life and the lives of her children. She did not ask for help because she did not want people feeling sorry for her. However, after A.V. was placed in foster care, she realized that all of this could have been avoided if she had just reached out for help. A Department social worker developed a case plan for Mother and Father. Both parents were present at the case plan meeting in which the case plans were designed. The magistrate court determined, however, by clear and convincing evidence the Department had established statutory grounds for termination under Idaho Code section 16-2002(3)(b), neglect through failure to complete a case plan, and under section 16-1602(31), neglect through conduct or omission of the parents. The magistrate court also determined that termination was in A.V.’s best interests. A final judgment and a decree were entered, terminating both Mother’s and Father’s parental relationship with A.V. Mother’s main argument on appeal was that the magistrate court erred in terminating her parental rights because her disabilities prevented her from completing her case plan. Finding no reversible error, the Idaho Supreme Court affirmed the magistrate court’s decree terminating Mother’s parental rights. View "DHW v. Jane Doe" on Justia Law

Father John Doe appealed a magistrate court's judgment granting the Idaho Department of Health and Welfare’s (“the Department”) petition to terminate his parental rights to his son, A.V. The magistrate court concluded the Department proved by clear and convincing evidence that Father and Jane Doe (“Mother”) neglected A.V. and that termination was in A.V.’s best interests (Mother’s termination was the subject of a separate appeal (Dkt. No. 47190)). Father’s main argument on appeal was that the magistrate court erred in terminating his parental rights because it was not in A.V.’s best interests to be separated from his siblings. A.V., the child at issue in this case, went into foster care in November 2017, when he was approximately two-and-a-half years old. The child was malnourished; health care providers testified the child was four to six months developmentally delayed. November 2017 was his second trip to foster care; social workers found A.V. weighed less than he had in his first trip a year before, "the size and weight of a twelve-month-old." Father testified that he was aware that A.V. was malnourished and not developing as he should have been while he was in Father’s care, and that he did not obtain services to help A.V. with walking and talking. However, Father did not realize that A.V. had lost weight when he came back into their care. One Department social worker testified that Father feels that it is his responsibility to work and provide financially for the family, and it is Mother’s responsibility to ensure the children are getting their medical and emotional needs met and to feed and care for them during the day. She further testified that she had talked with Father about his observing A.V. being underweight or not gaining weight, and Father said that he told Mother she needed to take care of it. The Idaho Supreme Court determined the magistrate court did not err in concluding termination was in A.V.'s best interests, even though termination would result in A.V. being separated from his siblings. The Court determined it was not error for the magistrate court finding Father was also responsible for A.V.'s neglect. Accordingly, the magistrate court was affirmed. View "DHW v. John Doe" on Justia Law

Father John Doe appealed a magistrate court's termination of his parental rights to his minor children “B.L.S.” and “A.C.S.” On Christmas Eve, 2017, the Department received a referral when A.C.S. was born prematurely. Mother’s amniotic fluid had ruptured prematurely due to drug use. Tests confirmed that A.C.S. was prenatally exposed to methamphetamine. Shortly after her birth, A.C.S. was life-flighted to Sacred Heart Medical Center in Spokane, Washington for treatment. Mother explained that she and Father had been in an on-and-off relationship for the past 20 years. At the time of the meeting, Mother and Father lived together in a camper on his family’s farm near Kendrick, Idaho. Mother disclosed that she actively used methamphetamine and had used methamphetamine while pregnant with A.C.S. She also explained that she and Father used methamphetamine together in their camper, sometimes with their children present. Mother described frequent incidents of domestic violence that occurred in the home: when the couple fought, it could become violent, where they would yell and throw appliances and other objects at each other. After an adjudicatory hearing where Father and Mother again stipulated to jurisdiction and custody, the Department worked with the parents to develop a case plan. At a review hearing in October 2018, the Department requested an early permanency hearing on the grounds that both parents had made little progress on their case plans. Agreeing that the parents had made very little progress up to that point, the magistrate court moved the permanency hearing up from December 2018, to November 26, 2018. At the permanency hearing, the magistrate court approved a permanency plan that sought termination of parental rights and relative adoption with the foster parents as the primary goal for each child. The Idaho Supreme Court determined Father failed to preserve his argument that Idaho Code section 16-1622(2)(g)(i) caused the magistrate court to violate his right to due process by moving the date of the permanency hearing from December to November. Further, the Supreme Court determined the magistrate court's decision to termination Father's parental rights was supported by substantial, competent evidence. Accordingly, the Supreme Court affirmed the magistrate court’s order terminating Father’s parental rights to B.L.S. and A.C.S. View "DHW v. John Doe" on Justia Law

Mother Jane Doe appealed a magistrate court’s termination of her parental rights to her minor children “B.L.S.”, “X.V.S.”, and “A.C.S.” Mother’s amniotic fluid had ruptured prematurely due to drug use. Tests confirmed that A.C.S. was prenatally exposed to methamphetamine. Shortly after her birth, A.C.S. was life-flighted to Sacred Heart Medical Center in Spokane, Washington for treatment. Mother explained that she and Father had been in an on-and-off relationship for the past 20 years. At the time of the meeting, Mother and Father lived together in a camper on his family’s farm near Kendrick, Idaho. Mother disclosed that she actively used methamphetamine and had used methamphetamine while pregnant with A.C.S. She also explained that she and Father used methamphetamine together in their camper, sometimes with their children present. Mother described frequent incidents of domestic violence that occurred in the home: when the couple fought, it could become violent, where they would yell and throw appliances and other objects at each other. After an adjudicatory hearing where Father and Mother again stipulated to jurisdiction and custody, the Department worked with the parents to develop a case plan. At a review hearing in October 2018, the Department requested an early permanency hearing on the grounds that both parents had made little progress on their case plans. Agreeing that the parents had made very little progress up to that point, the magistrate court moved the permanency hearing up from December 2018, to November 26, 2018. At the permanency hearing, the magistrate court approved a permanency plan that sought termination of parental rights and relative adoption with the foster parents as the primary goal for each child. Mother argued on appeal that the magistrate court abused its discretion by holding the permanency hearing 11 months after the children were placed in the Department's custody, and that the decision to terminate was not supported by substantial, competent evidence. Finding no abuse of discretion or other reversible error, the Idaho Supreme Court affirmed termination of parental rights. View "DHW v. Jane Doe" on Justia Law

The East Side Highway District (the District) and Gregory and Ellen Delavan (the Delavans) disputed the location of their common boundary relating to a portion of a road, Boothe Park Road, which included a boat ramp located on the shore of Lake Coeur d’Alene. The District asserted a claim to the disputed property under two theories: (1) a boundary by agreement that was established by the location of a fence that was erected by the Delavans’ predecessor in interest; and (2) Boothe Park Road and the boat ramp at its termination was a public highway pursuant to Idaho Code section 40-202(3). In response, the Delavans claimed the boat ramp was on their property, and its use by the public has always been, and remained, permissive. Further, the Delavans claimed the fence which was erected by their predecessor in interest was intended to act as a barrier, not a boundary. After two bench trials, the trial court ruled in favor of the Delavans, finding that the public’s use of the boat ramp had been permissive. As a result, the trial court ruled that the District did not have a right to a public easement based on Idaho Code section 40-202(3). Further, the trial court found that the fence had been erected as a barrier, not a boundary. Instead, the trial court found that the intention of the parties at the time the disputed property was conveyed to the Delavans demonstrated that the Delavans owned the property in dispute. The District appealed. After review, the Idaho Supreme Court held there was substantial and competent evidence to support the trial court’s findings that there was no boundary by agreement and that the Delavans owned the property in dispute. However, the Supreme Court vacated the trial court’s order granting summary judgment in favor of the Delavans because there was no hostility requirement in Idaho Code section 40-202(3). Accordingly, the case was remanded to determine whether the District had a public easement under Idaho Code section 40-202(3). View "Eastside Hwy Dist v. Delavan" on Justia Law

This case arose out of the termination of Ryan and Lanie Berrett (“the Berretts”) from their jobs with Clark County School District No. 161 (the “School District”), and raised issues regarding the “law of the case” doctrine, the Idaho Protection of Public Employees Act (“Whistleblower Act”), and wrongful termination in violation of public policy. The Berretts sued the School District, alleging that both of their terminations were in retaliation for Ryan Berrett reporting a building code violation to the School District’s board of trustees (the “board”). The district court granted the School District’s motion for summary judgment, finding that Ryan Berrett did not engage in a protected activity under the Whistleblower Act, and that Idaho’s public policy did not extend to protect Lanie Berrett in a termination in violation of public policy claim. The district court also denied the Berretts’ motion for reconsideration. The Berretts timely appealed. The Idaho Supreme Court concluded after review the law of the case doctrine did not preclude the district court from considering the School District’s motion for summary judgment, however, the Court erred in granting summary judgment on Ryan Berrett’s Whistleblower Act claim; the Court found genuine issues of material fact regarding whether Ryan Berrett engaged in a protected activity and causation. The trial court did not err in granting summary judgment on Lanie Berrett’s termination in violation of public policy claim. The matter was remanded for further proceedings. View "Berrett v. Clark County School District" on Justia Law