Justia Idaho Supreme Court Opinion Summaries

Lamont Bair Enterprises, Inc. (“LBE”) was an Idaho corporation based in Idaho Falls that owned residential rental units. One of LBE’s rental units was a four-plex rental property at 547 South Skyline Drive (“the Property”), served by municipal water lines owned and maintained by the City of Idaho Falls (“the City”). On December 28, 2015, a municipal water main broke, causing water to flow beneath the Property’s driveway, crack the concrete basement floor, and flood the basements of all four rental units. The City received an emergency call for assistance in shutting off the water. Believing the incident to be a service line leak (as opposed to a water main break), the City’s response crew first closed the water service line and waited for confirmation that the water flow had stopped. After the crew received notice that water continued to flow into the basement, they isolated the leak to the water main and began repairing the main line. The water was turned back on the following day, and the road and curb were filled back in. None of LBE’s rental units ever experienced flooding from the city’s water lines prior to this flooding incident at the Property. LBE contended the water main “ruptured” due to negligent care (that “the City neglected its water system to the point that literally miles of pipe became past their design life and in need of replacement”) thus failing to exercise reasonable care in maintaining the water supply system. The district court ruled the City was immune from liability under the Idaho Tort Claims Act’s discretionary function exception. The Idaho Supreme Court determined the district court did not err in holding that the City is immune from suit pursuant to the discretionary function exception set forth in Idaho Code section 6-904(1). The Court did not reach the merits of the other issues LBE raised on appeal. View "Lamont Bair Enterprises v. City of Idaho Falls" on Justia Law

Peter Nemeth and his wife Mary Nemeth (deceased), and Peter Nemeth acting as trustee of the Peter and Mary Nemeth Family Trust (collectively, “the Nemeths”), petitioned Shoshone County, Idaho, to validate a public right-of-way across federal land pursuant to Idaho Code section 40-204A and United States Revised Statute 2477 (“R.S. 2477”). The right-of-way followed a road which crossed federal land that Nemeths claimed historically provided access to their property and patented mining claims. When the County failed to act on the petition, the Nemeths filed a declaratory judgment action seeking validation of the right-of-way pursuant to Idaho Code section 40- 208(7). On a motion from the County, the district court dismissed the complaint pursuant to I.R.C.P. 12(b)(6) on grounds that because the Road traversed federal land, only a federal court had jurisdiction to hear the claim, which had to be brought under the federal Quiet Title Act (QTA), 28 U.S.C. section 2409a. The Nemeths appealed, arguing that state courts had jurisdiction to validate rights-of- way on federal land pursuant to R.S. 2477 and that the QTA did not preempt Idaho law that provided for such validation. After review, the Idaho Supreme Court reversed, because the district court erred in dismissing the Nemeths’ action on the basis it lacked subject matter jurisdiction. View "Nemeth v. Shoshone County" on Justia Law

Three cases were consolidated by the Idaho Supreme Court for the purposes of appeal. The cases involved three separate actions: one brought by First Security Corporation and two others brought by Richard Fosbury to quiet title to their purported ownership of irrigation water rights to land owned by Belle Ranch, LLC. All parties agreed that partial decrees for the water rights were issued in the Snake River Basin Adjudication (SRBA) in the name of South County Estates, LLC. As South County’s successors in interest, First Security and Fosbury argued their interests in the water rights are senior and therefore superior to the interest of Belle Ranch, LLC. Notwithstanding these claims, the district court quieted title to the water rights in question to Belle Ranch, LLC. First Security and Fosbury appeal. The Idaho Supreme Court determined First Security and Fosbury’s claims were precluded by res judicata: the claims were the same claims that were adjudicated in the SRBA. The Supreme Court found it was appropriate for the district court to quiet title in favor of Belle Ranch, LLC, because Belle Ranch, LLC, filed a notice of a change in ownership during the pendency of the SRBA. Accordingly, the Court affirmed the district court’s judgment. View "First Security v. Belle Ranch" on Justia Law

Dale Johnson maintained roller coasters for Silverwood, Inc. Among rising contentions and a dispute with Silverwood’s new director of construction and maintenance, Johnson resigned his position on June 8, 2015. He subsequently applied for unemployment benefits, but his claim was denied. Johnson challenged the denial with the Appeals Bureau of the Idaho Department of Labor, and a hearing was held on August 5, 2015. When denied again, Johnson appealed to the Industrial Commission. While the appeal was pending, Johnson learned that his hearing’s recording was lost. The Industrial Commission remanded the case to the Appeals Bureau for a new hearing. Ultimately, after two additional hearings and a second appeal to the Industrial Commission, Johnson won his claim for benefits with the Commission finding that Johnson was eligible for benefits. Johnson subsequently filed suit against the Department of Labor for unnecessary delays and other alleged improprieties in the handling of his claim. The district court dismissed the case for failure to file a notice of tort claim pursuant to the Idaho Tort Claims Act and then denied Johnson’s post-judgment motions. Finding no reversible error in the district court’s judgment, the Idaho Supreme Court affirmed the district court. View "Johnson v. Idaho Dept of Labor" 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

At issue before the Idaho Supreme Court in this matter centered on whether a person bringing a tort claim against a governmental entity for alleged child abuse had to comply with the notice requirement of the Idaho Tort Claims Act. Seven individuals (collectively, the Juveniles) filed suit alleging they had been abused while they were minors in the custody of the Idaho Department of Juvenile Corrections. In its ruling on summary judgment, the district court found the Juveniles’ claims based on Idaho Code section 6-1701 were not barred by the notice requirements of the Idaho Tort Claims Act. The Idaho Department of Juvenile Corrections and its employees moved for permission to appeal, which was granted, and they argued the district court erred by allowing the Juveniles’ claims to proceed. The Idaho Supreme Court held that because of the plain language of the ITCA, the notice requirement applied to claims based on tort actions in child abuse cases. Accordingly, the Court reversed the district court’s decision and remanded the case for further proceedings. View "D.A.F. v. Lieteau and Juvenile Corrections Nampa" on Justia Law

The Idaho Board of Licensure of Professional Engineers and Professional Land Surveyors (the Board), through its executive director, Keith Simila, brought disciplinary proceedings against Chad Erickson for allegedly violating certain statutes and rules governing the surveying profession. Following an administrative hearing, the Board found that Erickson violated a number of the statutes and rules alleged and revoked his license as a professional land surveyor. Erickson sought judicial review by the district court. On review, the district court upheld the Board’s finding that Erickson had committed certain violations; however, the district court reversed the portion of the Board’s Order revoking Erickson’s license and remanded the matter for further consideration of the appropriate sanction. Erickson appeals from the district court’s decision, arguing that the evidence does not support the Board’s finding of any violations. In addition, Erickson asserts that numerous procedural errors made by the Board necessitate reversal. After its review, the Idaho Supreme Court reversed the district court's order, finding the Board's order against Erickson was time-barred. View "Erickson v. Idaho Board of Licensure of Professional Engineers & Professional Land Surveyors" on Justia Law

Due to a failed breath alcohol test and multiple convictions for driving under the influence, the Idaho Transportation Department permanently suspended Bruce Edwards’ driving privileges to operate a commercial motor vehicle. The district court affirmed the Department’s order and Edwards appealed. After review of the Department’s order and the circumstances leading to the suspension, the Idaho Supreme Court affirm the district court’s judgment and the Department’s lifetime disqualification of Edwards’ commercial motor vehicle driving privileges. View "Edwards v. Transportation Dept" on Justia Law

Four appeals arose from a consolidated subcase that was a part of the broader Coeur d’Alene-Spokane River Basin Adjudication (CSRBA). The United States Department of the Interior (the United States), as trustee for the Coeur d’Alene Tribe (the Tribe), filed 353 claims in Idaho state court seeking judicial recognition of federal reserved water rights to fulfill the purposes of the Coeur d’Alene Tribe’s Reservation (the Reservation). The Tribe joined the litigation. The State of Idaho (the State) and others objected to claims asserted by the United States and the Tribe. The district court bifurcated the proceedings to decide only the entitlement to water at this stage, with the quantification stage to follow. After cross-motions for summary judgment, the district court allowed certain claims to proceed and disallowed others. The district court specifically allowed reserved water rights for agriculture, fishing and hunting, and domestic purposes. The district court allowed reserved water rights for instream flows within the Reservation, but disallowed those for instream flows outside the Reservation. The district court determined priority dates for the various claims it found should proceed to quantification, holding generally the Tribe was entitled to a date-of-reservation priority date for the claims for consumptive uses, and a time immemorial priority date for nonconsumptive uses. However, in regard to lands homesteaded on the Reservation by non-Indians that had since been reacquired by the Tribe, the district court ruled the Tribe was entitled to a priority date of a perfected state water right, or if none had been perfected or it had been lost due to nonuse, the Tribe’s priority date would be the date-of-reacquisition. The Idaho Supreme Court affirmed in part and reversed in part. The Supreme Court determined the district court improperly applied the controlling case law's rule of "primary-secondary" distinction and instead should have allowed aboriginal purposes of plant gathering and cultural uses under the homeland purpose theory. Furthermore, the Court determined the priority date associated with nonconsumptive water rights was time immemorial. The Court affirmed the remainder of the district court’s decisions and remanded for further proceedings. View "United States v. Idaho" on Justia Law

SSI Food Services Inc. (SSI) appealed the district court’s decision rejecting the Board of Tax Appeal’s (BTA) 2016 assessed value of SSI’s food processing facility in favor of the Canyon County Assessor’s (Canyon County) significantly higher valuation. On appeal, SSI argued the district court erred when it modified the BTA’s valuation because: (1) Canyon County did not meet its burden of proving that the BTA’s valuation was erroneous; (2) the modified valuation was not supported by substantial and competent evidence; and (3) the conclusions of law contained in the district court’s findings of fact and conclusions of law are inadequate. SSI also appealed the district court’s decision to allow Canyon County’s expert to testify on rebuttal. Canyon County cross-appealed the district court’s decision that SSI was not obligated to pay penalties and interest on the unpaid amount of property taxes. Finding no reversible error or abuse of discretion, the Idaho Supreme Court affirmed the district court. View "Stender v. SSI Food Services, Inc." on Justia Law