Justia Idaho Supreme Court Opinion Summaries

In 2010, Gerald Durk Simpson shot Ryan Mitchell in the back outside of a coffee shop in Pocatello. Prior to the shooting, Simpson had been receiving mental health services from the Idaho Department of Health and Welfare’s Adult Mental Health program. In fact, Simpson had been receiving services from the Idaho Department of Health and Welfare (IDHW) for most of his adult life. In June of that year, IDHW sent a letter to Simpson informing him that he was being released from its program. The shooting occurred a little over three months after Simpson was released from IDHW’s care and custody. The Bannock County Prosecuting Attorney’s Office filed a charge of Aggravated Battery against Simpson with notice that the State would seek an enhancement penalty for the use of a deadly weapon in the commission of a crime. Approximately ten days after the shooting, psychologist Daniel Traughber, Ph.D., prepared a memorandum on behalf of the IDHW, explaining the processes and procedures that were used to implement the budget cuts so that patient mental health services would be terminated in a way that “reduced the risk of harm to patients and/or the community.” Mitchell appealed a district court order granting summary judgment in favor of the State after he brought suit alleging the State violated his constitutional and statutory victims’ rights and that the State was negligent when it discontinued Simpson’s services. Mitchell sought declaratory and injunctive relief for his victims’ rights claim and sought damages for his negligence claim. Mitchell argued: (1) the Idaho Tort Claims Act (ITCA) did not shield the State from liability for its decision to discontinue mental health services for Simpson; and (2) the victims’ rights laws provided a private cause of action for declaratory and injunctive relief against a state agency. After review, the Idaho Supreme Court concluded the district court erred in granting summary judgment on Mitchell's negligence claim: " It is clear that the complaint alleges that when IDHW made the decision to close Simpson’s file, it negligently followed, or failed to follow, procedures that were put into place to determine whether a client’s file should be closed. The evidence does not indicate who made the decision to close Simpson’s file in particular or how that decision was made." The Court reversed with respect to the negligence claim, affirmed in all other respects, and remanded the case for further proceedings. View "Mitchell v. Idaho" on Justia Law

This case involved a second set of appeals arising from an action challenging the bidding process for the Idaho Education Network (“IEN”). Syringa Networks, LLC, sued Qwest Communications, LLC, ENA Services, LLC, and the Idaho Department of Administration (“DOA”) and certain DOA employees, alleging injury arising from contract awards and amendments that DOA issued to Qwest and ENA related to the IEN. The district court dismissed all of Syringa’s claims. On appeal the Idaho Supreme Court held that Syringa had standing to pursue Count Three, which alleged that DOA violated Idaho Code section 67-5718A. Count Three was remanded to the district court for further proceedings. On remand, the district court entered partial summary judgment for Syringa on Count Three, holding that the amendments and the underlying contracts were void for violating state procurement law. The district court denied Syringa’s motion to order DOA to demand repayment of money advanced under the void contracts. The district court also awarded Syringa attorney fees. Syringa, Qwest, ENA, and DOA each appealed: Syringa appealed the district court’s denial of its request to order DOA to demand repayment from Qwest and ENA; the other parties appealed the district court’s grant of partial summary judgment to Syringa, arguing that the district court’s conclusions were procedurally improper and substantively incorrect for a variety of reasons. DOA also challenges the district court’s award of attorney fees to Syringa. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Syringa Networks v. Dept of Administration" on Justia Law

Appellant Rangen, Inc., filed a petition before the Director of the Idaho Department of Water Resources, alleging that junior ground water pumping in the Eastern Snake Plains Aquifer was materially injuring its water rights. The Director issued an order granting Rangen a curtailment of certain junior priority ground water pumping affecting Rangen’s water rights. The Director also interpreted the source and point of diversion elements of Rangen’s water rights to have a scope smaller than Rangen’s actual historical use. Rangen and intervenor Idaho Ground Water Appropriators, Inc. (“IGWA”) each filed petitions for judicial review. The issues raised by IGWA in its petition for judicial review were not at issue here; rather Rangen raised various issues related to the interpretation of its water rights and the sufficiency of the evidence before the agency. Specifically, Rangen appealed the Director’s determinations that Rangen could divert water only from the mouth of the Martin-Curren Tunnel and only within the ten-acre tract listed on its water right partial decrees. Rangen also appealed the Director’s adoption of an adverse expert’s analysis and the Director’s conclusion that junior priority ground water users are using water efficiently and without waste. The district court affirmed the Director’s orders, and Rangen appealed to the Idaho Supreme Court on substantially the same issues with substantially the same arguments. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Rangen, Inc. v. Idaho Dept of Water Resources" on Justia Law

Claimant Clarence Copper was an employee of Ace Hardware / Sannan, Inc. from 2004 until he was terminated in 2014. Prior to termination, Claimant was reprimanded numerous times for failing to perform his job duties. Claimant appealed an order of the Industrial Commission that the he was not entitled to unemployment benefits because he was discharged for misconduct in connection with his employment for violating his employer’s written policies. Finding no reversible error after review of the record, the Supreme Court affirmed the Commission's order. View "Copper v. Ace Hardware" on Justia Law

Kelli Sevy sustained a work-related injury on October 31, 2006, and contended that she was totally and permanently disabled. The Industrial Commission found that Sevy failed to meet her burden of establishing total and permanent disability. Although the Commission found that Sevy was “profoundly disabled,” the Commission held that Sevy had failed to demonstrate that the accident contributed to her disability beyond a 2% permanent partial impairment (PPI). Sevy argued on appeal that the Commission’s decision that she did not suffer disability in excess of her impairment is not supported by substantial and competent evidence. Finding no reversible error, the Supreme Court affirmed. View "Kelli Sevy v. SVL Analytical, Inc." on Justia Law

In 2013, claimant Scott Chadwick filed a complaint with the Industrial Commission seeking benefits under the Worker’s Compensation Law from his employer, Multi-State Electric, LLC, and its surety, Idaho State Insurance Fund. Claimant alleged that he had suffered back injuries as a result of two separate accidents at work in 2012. The matter was tried to a referee, but the Commission did not adopt the referee’s recommendations. After considering the Claimant’s prehearing deposition, the testimony presented during the evidentiary hearing before the referee, and the exhibits, the Commission issued its findings of fact, conclusions of law, and order. The Commission found that Claimant failed to prove that he suffered an injury from a workplace accident in a May event and that he failed to prove that a July event occurred. The Commission alternatively found that he had failed to provide timely notice to his employer of both claimed accidents, and that he failed to prove that Employer was not prejudiced by the failure to give timely notice. Therefore, he was denied benefits. Claimant then timely appealed. Finding no reversible error, the Supreme Court affirmed the Commission. View "Chadwick v. Multi-State Electric, LLC" on Justia Law

Appellant, the Greater Boise Auditorium District, filed a petition for judicial confirmation (pursuant to Idaho Code section 7-1304) asking the district court for a determination that a lease the District intended to enter into did not violate the Constitution’s Article VIII, section 3 clause prohibiting a municipal body, without voter approval, from incurring indebtedness or liabilities greater than it has funds to pay for in the fiscal year. Respondent, Boise resident and property owner David Frazier, objected to the requested judicial confirmation, and appeared in the case to contest it. The district court denied the Petition for Judicial Confirmation and the District appealed. Frazier sought attorneys’ fees on appeal. After review, the Supreme Court reversed the district court’s denial of the District’s request for judicial confirmation and held that the agreements into which it entered satisfied Article VIII, section 3 of the Constitution. View "Greater Boise Auditorium District v. Frazier" on Justia Law

On September 17, 2011, Martin Hayes was seriously injured after stumbling on uneven ground hidden by grass while attending his grandson’s Pop Warner football game at the Plummer School Park, which was owned by the City of Plummer. Hayes did not pay any fee or admission to enter the Park. Hayes filed a premises liability claim against the City for his injuries. In turn, the City filed a motion for summary judgment on the basis that the City was entitled to a limit on liability under Idaho’s Recreational Use Statute. The district court granted the City’s motion. Hayes appealed. After review, the Supreme Court agreed with the district court's analysis that the Recreational Use Statute provided limited liability protection because the City did not receive "compensation" or "charge" for use of the land upon which Hayes was injured. View "Hayes v. City of Plummer" on Justia Law

On August 13, 2013, the Idaho Department of Labor (IDOL) mailed two Determinations of Overpayment and an Eligibility Determination to Mitchell Kennedy at the address he had provided when filing for unemployment benefits. The Determinations informed Kennedy that he had the right to appeal, or protest, the Determinations and that the last day to do so was August 27, 2013. On August 21, 2013, Kennedy moved to a new residence. He changed his address with the U.S. Postal Service. Kennedy received the Determinations on August 24, 2013, three days before the deadline. He did not read them until either August 26 or 27. The Industrial Commission made no specific finding as to when Kennedy read the letters but did find that “Claimant did not closely review the Determination to realize the applicable appeal dates due to work and other personal priorities.” Kennedy faxed his protest to IDOL on August 29, 2013, two days after the deadline. In the transmission of that protest, Kennedy informed IDOL of his new address. The appeals examiner found that Kennedy’s request for an appeals hearing was not timely and therefore the examiner had no jurisdiction to hear Kennedy’s appeal. Kennedy appealed, and the Commission affirmed the examiner’s decision. Kennedy then requested reconsideration from the Commission. Finding that Kennedy had not presented any further argument on the relevant issues, the Commission denied the motion. Kennedy timely filed this appeal under Idaho Code section 72-1368(9) and Idaho Appellate Rules 11(d) and 14(b). But finding no reversible error in the Commission's decision, the Supreme Court affirmed. View "Kennedy v. Hagadone Hospitality Co." on Justia Law

This appeal from arose from proposed repairs and improvements to the City of Challis’ water distribution system. In 2013, the City initiated a judicial confirmation proceeding seeking approval to incur $3.2 million in debt without a public vote. The Consent of the Governed Caucus challenged the constitutionality of the City’s request based upon Article VIII, section 3 of the Idaho Constitution. The district court granted the City’s request and the Caucus appealed. Finding that the district court erred by failing to apply the legal standard for what constitutes a "necessary" expense under the Idaho Constitution, the Supreme Court reversed the district court's decision and remanded for further proceedings. View "City of Challis v. Consent of the Governed Caucus" on Justia Law