Justia Idaho Supreme Court Opinion Summaries

The Idaho Supreme Court concluded the district court did not err in dismissing the State Defendants under the Constitutionally Based Educational Claims Act (“CBECA”). This appeal arose from Russell Joki’s action challenging the constitutionality of: (1) fees charged to students of Meridian Joint District #21 ; and (2) the statewide system of funding Idaho’s public schools. Joki and sixteen other individuals (collectively referred to as “Joki”) initiated the suit against the State, the Idaho Legislature, the Idaho State Board of Education, and the Superintendent of Public Instruction (collectively referred to as the “State Defendants”), all 114 Idaho public school districts, and one charter school. The district court granted the State Defendants’ motion to dismiss. Joki argued the CBECA did not apply here, but the Supreme Court disagreed, finding: (1) the CBECA was constitutional, “it is not unreasonable for the legislature to also declare that allegations that the required educational services are not being furnished should first be addressed to the local school districts which have been given the responsibility and authority to provide those services;” and (2) Joki’s claims relating to the fees levied by the school districts fell squarely within the definition of a constitutionally based educational claim because the legislature’s duty was to provide free common schools. View "Joki v. Idaho Bd of Education" on Justia Law

Val and LaRee Westover appealed the district court’s judgment and denial of their request for writs of mandate and prohibition against Franklin County Assessor Jase Cundick. The dispute arose when the Westovers granted an easement to Rocky Mountain Power on property owned by the Westovers. Based on his office’s records, Cundick sent a letter to Rocky Mountain Power stating that the Westovers did not own the property in question. The Westovers sought a writ of mandate to require Cundick to retract the letter and a writ of prohibition to prevent him from sending such letters in the future. The district court denied the Westovers’ request for writs of mandate and prohibition after it concluded that there were other remedies available at law. On appeal, the Westovers argued the district court erred by failing to grant injunctive relief prohibiting Cundick from sending out letters concerning real estate transactions and property ownership. Although the Westovers’ complaint did not request that the district court grant injunctive relief, they argued that the district court erred because the Westovers were clearly entitled to injunctive relief under Idaho Rule of Civil Procedure 54(c). Finding no reversible error, the Supreme Court affirmed. View "Westover v. Cundick" on Justia Law

Enrique Lopez appeals an order of the Idaho Industrial Commission (“Industrial Commission”) declining to award him additional workman’s compensation income benefits for binaural hearing loss he sustained as a result of a workplace accident. Lopez was injured by a bull while working on a dairy. Lopez complained to the Industrial Commission that he was entitled to additional income benefits based on his interpretation of the statutory schedule for permanent impairments in Idaho Code section 72-428. The Industrial Commission disagreed, holding that Lopez was only entitled to the 8% impairment benefits previously paid. Lopez timely appealed. Finding no error in the Commission’s calculation of Lopez’ income benefits for his partial binaural hearing loss, the Supreme Court affirmed. View "Lopez v. Vanbeek Herd Partnership" on Justia Law

Jane Doe (Mother) appeals the Bonneville County magistrate court’s termination of her parental rights to her two minor children, K.J.M. and K.M.M. (Children). The Idaho Department of Health and Welfare (IDHW) became involved in this case in November 2012, when it learned Mother and her boyfriend, who was also K.J.M.’s father, were blowing marijuana smoke in K.R.C.’s and K.J.M.’s faces. IDHW visited Mother’s home and noted it was "filthy with pills and drug paraphernalia scattered throughout the home[.]" Further investigation revealed that Mother’s boyfriend was physically abusing Mother. Mother’s boyfriend was arrested for felony strangulation of Mother. Apparently, Mother dropped the charges "due to him being the sole caretaker of the children and needing his help . . . ." In addition, Mother’s boyfriend was physically abusing K.R.C. and K.J.M. Mother reported she had witnessed her boyfriend "shake 4 month old [K.J.M.] . . . and hit[] 1 year old [K.R.C.], leaving bruises on her legs and bottom." Even so, Mother routinely placed them in the care of her boyfriend while she went to work, not "fully comprehend[ing] the danger she [was] placing her children in . . . ." IDHW petitioned to terminate Mother's parental rights to the children in late 2015. After an eight-day trial where over forty witnesses testified and close to 200 exhibits were admitted, the magistrate found termination appropriate on several bases, and entered a judgment of termination. Mother appeals, challenging the sufficiency of the evidence. Finding no reversible error, the Supreme Court affirmed. View "Dept. of Health & Welfare v. Jane Doe (2016-32)" on Justia Law

This appeal arose from an Industrial Commission (the Commission) order denying medical care benefits to Channel Rish. Rish worked as a cashier at Home Depot. While working on October 30, 2005, Rish slipped on a floor mat and injured her right knee. The injury ultimately required Rish to undergo three knee surgeries, which Dr. Casey Huntsman performed in 2005, 2006, and 2007. Roughly three months after Rish’s third surgery, Dr. Huntsman concluded Rish had achieved maximum medical improvement (MMI). Dr. Huntsman, however, further noted that Rish “definitely needs . . . continued pain management” with Dr. Holly Zoe. To that end, Rish visited Dr. Zoe for pain management treatment. Respondents remained skeptical as to Rish’s continued medical care with Dr. Zoe. Rish filed a worker’s compensation complaint to seek past and future disability benefits and medical care. Respondents answered and conceded Rish was entitled to the already-paid disability benefits and medical care, but Respondents disputed whether she was entitled to additional disability benefits and medical care. After a hearing, the Commission held in Respondents’ favor. The Commission noted that Rish did not timely raise the issue of disability benefits, but concluded Rish was nevertheless entitled to no additional disability benefits. Further, the Commission concluded Rish was entitled to no additional medical care benefits because the medical care Rish received after August 9, 2007 (the date when Dr. Huntsman deemed her at MMI) was unreasonable. Rish appealed. After review, the Supreme Court concluded the Commission erred in holding that the medical care Rish received after August 9, 2007 was unreasonable. As such, the Court vacated the Commission’s denial of medical care benefits and remanded for further proceedings. View "Rish v. Home Depot" on Justia Law

Claimant Gary Davis, employer Hammack Management, Inc., surety the Idaho State Insurance Fund, and the Idaho Industrial Special Indemnity Fund (“ISIF”) entered into a compensation agreement (“Stipulation”). The parties agreed that Claimant became totally and permanently disabled based on the combined effects of preexisting impairments and a workplace injury that occurred in 2004. The Stipulation outlined each party’s financial obligations to Claimant, including a credit to Employer for permanent partial impairment benefits previously paid. The Idaho Industrial Commission (“Commission”) approved the Stipulation. Subsequently, the Idaho Supreme Court issued its decision in “Corgatelli v. Steel West, Inc.,” (335 P.3d 1150 (2014)), prohibiting such a credit. Claimant then sought a declaratory ruling that the credit in the Stipulation was void. The Commission issued an order stating that the Stipulation was binding as written and subsequently denied Claimant’s motion for reconsideration. Claimant appealed. The Supreme Court concluded the credit in the Stipulation was invalid and the Commission’s order approving the Stipulation was void. The Court affirmed the Industrial Commission’s holding that it had subject matter jurisdiction over the Claimant’s petition for declaratory ruling but reversed its order upholding the Stipulation and the credit. View "Davis v. Hammack Mgmt." on Justia Law

Joseph Maravilla and J.R. Simplot Company both appealed the Industrial Commission’s (Commission) Order on Petition for Declaratory Ruling. Maravilla was injured in an industrial accident while working for Simplot, and Simplot paid Maravilla’s worker’s compensation benefits for that injury. In a separate action, Maravilla brought suit against Idaho Industrial Contractors, Inc. (IIC), the contractor performing repairs on the area where Maravilla was injured. Maravilla and IIC settled the claim for $75,000 and Simplot claimed subrogation against Maravilla. In its order, the Commission ruled that Maravilla could have argued that Simplot was partly at fault for Maravilla’s industrial accident and that Simplot’s negligence, if proved, was not a bar to Simplot being reimbursed for worker’s compensation payments it had paid Maravilla. Simplot appealed the Commission’s decision that Maravilla’s settlement with IIC does not preclude Maravilla from attempting to prove Simplot’s negligence. Maravilla appealed the Commission’s ruling that Simplot was entitled to reimbursement even if Simplot’s negligence contributed to Maravilla’s injury. The Supreme Court, after its review, affirmed in part and reversed in part, finding that the Commission erred in its interpretation of the controlling case law in this matter: “The adoption of comparative negligence and the abrogation of joint and several liability do not affect the rationale behind the Liberty Mutual rule, let alone require its abandonment.” The Court affirmed in all other respects. View "Maravilla v. J. R. Simplot Co." on Justia Law

Blair Olsen served as sheriff of Jefferson County from January 1989 until May 2015, when he resigned due to his conviction in this case. While he was the sheriff, the county provided Olsen with two cell phones and paid the bills for those phones. It initially did so because of unreliable service in different sides of the county. He also carried a personal cell phone and paid the charges for that service plan from his own funds. Once county-wide coverage was available from one of the providers, he discontinued service with the other provider and had both of his county-provided cell phones with the same provider. One cell phone was to be his primary cell phone and the other was to be his backup cell phone. At the same time, he terminated his personal cell phone service, but had the telephone number of his personal cell phone transferred to the backup cell phone. At some point, he permitted his wife to carry the backup cell phone for her personal use. The issue of Olsen’s wife using the backup cell phone became an election issue. Olsen asked the county commissioners to refer the matter to the Attorney General in an attempt to clear his name. A deputy attorney general obtained an indictment against Olsen charging him with three felony counts of knowingly using public money to make purchases for personal purposes based upon his wife’s use of the backup cell phone. Prior to trial, Olsen moved to dismiss the indictment or merge the three counts into one on the ground that the prosecution for three counts violated his right against double jeopardy. The charges were tried to a jury, and Olsen was found guilty of all three counts. The district court withheld judgment and placed Olsen on three years’ probation, and he appealed. The district court ruled that "I think the statute gives the prosecutor very clearly a substantial amount of discretion that says that the incidents may be aggregated into one count, but it doesn’t say they have to be aggregated into one count." In so holding, Supreme Court found that the district court erred. The Supreme Court affirmed the conviction of one count of misuse of public funds and remanded this case to vacate two other counts and amend the order withholding judgment accordingly. View "Idaho v. Olsen" on Justia Law

Appellants appealed the district court's denial of their motion for summary judgment and the grant of summary judgment in favor of the Board of the Local Improvement District No. 1101 and the Ada County Board of Commissioners (the Boards) in a case regarding assessments levied on properties within the Sage Acres Local Improvement District. Appellants also appealed the district court’s award of attorney fees to the Boards. Ada County Ordinance No. 780 established the Ada County Local Improvement District No. 1101, known as Sage Acres Local Improvement District (LID). The ordinance was adopted in 2011. The purpose of the LID was to construct a water delivery system for residential and irrigation use by properties within the Sage Acres Subdivision (Sage Acres) in Boise. water system was completed in 2014. Appellants challenged the creation of the LID and Ada County Ordinance No. 809, which confirmed the assessments levied on properties affected by the LID. In 2013, Appellants filed a Notice of Appeal from Assessments; the district court set the matter for trial in 2014, and ordered the parties to mediate no later than 90 days prior to trial. Prior to mediation, the Boards moved for summary judgment, arguing that Appellants’ claims were not legally or factually supported. Finding no reversible error in the district court's grant of summary judgment in favor of the Boards, the Supreme Court affirmed. View "Hoffman v. Bd of Local Improvement Dist No. 1101" on Justia Law

In 2008, plaintiff Sharon Hammer began working as the City Administrator for the City of Sun Valley (City) pursuant to a written employment agreement. In 2011, DeWayne Briscoe defeated the incumbent mayor, Wayne Willich, in the mayoral election. The City’s council conducted a special executive session to discuss allegations of improper use of public funds and equipment by plaintiff. The following day, her husband, an attorney, sent a letter to Mayor Willich threatening litigation. The City placed the Plaintiff on paid administrative leave, and three days later her husband filed a lawsuit on her behalf against the City and members of city government. Following an investigation, Plaintiff resumed her duties, and no disciplinary action was taken. In early 2012, Briscoe was sworn in as the mayor. The next day, he placed Plaintiff on paid administrative leave and notified her of another investigation. Plaintiff voluntarily dismissed her pending lawsuit against the City and members of city government. A few days after dismissing her case, Plaintiff was terminated from employment based upon the unanimous vote of the Mayor and city council. Plaintiff brought another lawsuit seeking to recover under the Idaho Protection of Public Employees Act. The district court ruled that the Plaintiff had waived her claim against the City of Sun Valley pursuant to a release she had signed, and that the Act did not provide a cause of action against City officials. Finding no reversible error in that judgment, the Supreme Court affirmed. View "Hammer v. City of Sun Valley" on Justia Law