Justia Idaho Supreme Court Opinion Summaries

The issue this case presented for the Supreme Court's review stemmed from attempts by the Water Users’ Association of the Broadford Slough and Rockwell Bypass Lateral Ditches, Inc. (Association) to collect assessments from Big Wood Ranch, LLC (BWR) for maintenance performed by the Association on the Broadford Slough (Slough) and Rockwell Bypass (Bypass), which were conduits for the delivery of surface water to property owned by BWR and some of its neighbors. The Association claimed it has a statutory right to collect assessments for its maintenance of this water delivery system. BWR disputed that claim. On summary judgment, the district court determined that the Association was validly formed pursuant to Idaho Code section 42-1301, and, after a bench trial, found BWR owed payment for these outstanding assessments. BWR appealed, challenging the validity of the Association’s formation under the statute, as well as the court’s alternative contract and equity-based theories for granting judgment in favor of the Association. Upon review, the Supreme Court found: (1) the Association was not qualified to operate pursuant to Idaho Code section 42-1301; (2)the district court erred by alternatively granting judgment to the Association on unpled contract and equity-based theories; and (3) BWR was entitled to attorney fees and costs on appeal. View "Big Wood Ranch v. Water Users' Assn. of the Broadford Slough & Rockwell Bypass Lateral Ditches, Inc." on Justia Law

The City of Hayden provided sewer service to the residents living in the City and to some persons living outside the City. To do so, the City entered into a joint powers agreement with the Hayden Area Regional Sewer Board, which operated a regional wastewater treatment plant serving the City and two other local entities. The City charged each customer it serves a bi-monthly fee, which covered a proportionate share of the operation and maintenance of the City's sewer collection system and of the operation and maintenance costs associated with the regional wastewater treatment facility. In addition to the bi-monthly fee, the City charged a one-time "sewer capitalization fee" for each new structure, whether residential or commercial, and for any addition to an existing commercial structure that would result in an increase in the volume of sewage generated. The capitalization fee was charged when a building permit is issued. In March 2006, the City contracted with an engineering company to update the City's sewer master plan. The engineering company submitted a capital improvement plan in which it recommended forty projects that would cost about $20 million in order to replace existing infrastructure and to construct new infrastructure so that the sewer system would reach the entire area of city impact and accommodate anticipated future population growth. In order to finance the project, the engineering company recommended that the part of the capitalization fee retained by the City be increased from $735 for one equivalent residence ("ER") to $2,280 for one ER. In 2010, the North Idaho Building Contractors Association filed suit to have the fee declared unlawful because it was an impermissible tax rather than a fee for services. The district court held that it was lawful and entered a judgment dismissing the complaint. The City requested an award of attorney fees, which the court denied. The Contractors Association appealed the dismissal of its complaint, and the City cross-appealed the denial of an award of attorney fees. Because there was nothing in the record showing that as of June 7, 2007, the sum of $2,280 was the actual cost of providing sewer service to a customer connecting to the City sewer system and there was no showing that the amount of the fee was based upon any such calculation, the fee was not authorized by Idaho Code section 63-1311(1). The Supreme Court concluded the district court erred in holding that it was. View "No. Idaho Bldg Contractors Assoc. v. City of Hayden" on Justia Law

The Board of Tax Appeals' (the BTA) denied appellant Jayo Development, Inc.'s application for a business inventory property tax exemption. In 2012, Jayo Development applied for a property tax exemption pursuant to Idaho Code section 63-602W(4), claiming that the property qualified as site improvements held by a land developer. The Ada County Board of Equalization (the BOE) denied the application. Subsequently, the BTA and the district court both affirmed the denial. On appeal, Jayo Development argued: (1) that the plain language of the statute entitled it to the exemption;, (2) that the district court erred in relying on IDAPA 35.01.03.620 in denying Jayo Development the tax exemption; and (3) that the 2013 amendment of Idaho Code section 63-602W(4) clarified the legislature's intent and supports its interpretation of the statute. Finding no reversible error, the Supreme Court affirmed. View "Jayo Development, Inc. v. Ada County Bd. of Equalization" on Justia Law

Thomas and Rebecca Arnold appealed the grant of summary judgment in favor of the City of Stanley. In 2012, the City provided notice to the Arnolds (and other interested parties) of the date and time for three public hearings and a regular city council meeting, all scheduled to take place on August 9, 2012. The first of the three public hearings was noticed to begin at 5:00 p.m. and was for the purpose of receiving public comment on proposed Ordinance 189, the ordinance that the Arnolds alleged affected their property rights. The second and third hearings were noticed to begin at 5:15 p.m. and 5:30 p.m., respectively (and were for the purpose of public comment on matters not at issue here). The regular city council meeting was noticed to begin at 6:00 p.m. The first two meetings were held at their scheduled times. The third meeting began five minutes early, at 5:25 p.m., and concluded at 5:29 p.m. The regular city council meeting, scheduled to begin at 6:00 p.m., commenced at 5:31 p.m. and adjourned at 6:55 p.m. Prior to the start of the 6:00 p.m. meeting, the City did not amend the notices it had provided or otherwise notify the public that the meetings would begin earlier than scheduled. The early start time of the 6:00 p.m. meeting and the City's failure to provide amended notice of the earlier start time were the issues presented in this appeal to the Supreme Court: it was at the 6:00 p.m. meeting that the mayor and city council deliberated toward a decision on Ordinance 189, eventually voting to adopt the ordinance. Although the Arnolds were fully aware of the agenda items to be discussed at the various meetings, at no time from the outset of the first meeting at 5:03 p.m. until the final meeting adjourned at 6:55 p.m. did they attend the meeting; the Arnolds conceded at oral argument that they had no intention of attending the meeting. Following adoption of Ordinance 189, the Arnolds filed an action against the City under Idaho Code section 67-2347(6), seeking to have the ordinance declared null and void because the City held the 6:00 p.m. meeting in violation of Idaho's open meeting law by starting the meeting early and failing to provide notice of the earlier start time. The district court held the Arnolds lacked standing to bring an enforcement action because the plain language of Section 67-2347(6) allows standing for such an action only to one who is actually affected by a violation of the open meeting law, instead of being affected only by a substantive action taken at the meeting. The court granted the City's motion for summary judgment on this basis. The Arnolds appealed. The Supreme Court affirmed the district court: because a plain reading of the statute contradicted the Arnolds' argument, and because they did not even claim to have been actually harmed by the 6:00 p.m. meeting's early start time, the Court found that their appeal was brought without a reasonable basis in fact or law. View "Arnold v. City of Stanley" on Justia Law

917 Lusk, LLC appealed the Boise City Council's decision to grant a conditional use permit to Royal Boulevard Associates, LP to build an apartment complex. Royal's predecessor in interest applied for permission to build a 352,000 square foot, five-story, multi-family apartment complex called River Edge Apartments. The site of the proposed construction was near Boise State University, adjacent to the Boise River, east of Ann Morrison Park, and west of property owned by Lusk. The site was zoned Residential Office with a Design Review Overlay (R-OD). Multi-family housing was an allowed use for this location. However, the Boise City Code (BCC) required a conditional use permit (CUP) in order to construct a building more than 35 feet tall in an R-OD zone. If constructed as planned, River Edge will have been between 59 and 63 feet tall. Lusk appealed the Boise Planning and Zoning Commission's decision to the City Council, contending that the Commission's decision failed to address the requirements for a CUP. The district court affirmed the City Council's decision and Lusk appealed. Lusk argued that because the Commission did not follow the correct procedure for granting a CUP, the City Council erred in affirming the Commission's decision. The Supreme Court agreed, reversed the district court's affirmance of the City Council's approval of the Commission's decision to grant the CUP to Royal. The case was remanded for further proceedings. View "917 LUSK, LLC v. City of Boise" on Justia Law

Claimant-appellant Terri Boyd-Davis filed for unemployment compensation on January 27, 2013, and began receiving benefits. IDOL claims to have mailed an "online review letter" to Boyd-Davis' listed address on March 6, 2013. The Online Review Letter indicated that Boyd-Davis had been selected to provide additional information concerning her unemployment insurance claim for the week of March 2, 2013. The Online Review Letter instructed Boyd-Davis that she would need to complete work search documentation online. The letter also indicated that failure to complete the online eligibility review by 5:00 p.m. on March 15, 2013, would result in the denial of her benefits. Boyd-Davis claimed she did not receive the Online Review Letter. When Boyd-Davis had not provided the requested information by the deadline, IDOL issued an Eligibility Determination on March 19, 2013, indicating that Boyd-Davis had failed to complete the online eligibility review and as a result was ineligible for benefits effective March 10, 2013. Boyd-Davis filed a protest. A telephonic hearing was scheduled for April 18, 2013. On April 1, 2013, Boyd-Davis provided the information IDOL had requested in the Online Review Letter. As soon as the requested information was provided, Boyd-Davis' benefits were reinstated for the week beginning March 31, 2013. However, benefits were not reinstated for the period of March 10 through March 30, 2013. Boyd-Davis proceeded with the April 18, 2013, hearing seeking restoration of her benefits for the period of March 10 through March 30, 2013. Following the hearing, an IDOL Appeals Examiner affirmed the original eligibility determination and concluded that Boyd-Davis' benefits had been properly denied. After review, the Supreme Court reversed and remanded the case for further proceedings, finding that Boyd-Davis presented evidence that "would permit reasonable minds to conclude that the Online Review Letter was not received." The Court concluded that the Commission erred in its application of the presumption of delivery articulated in Idaho Code section 72-1368(5) of the online letter. Furthermore, the Commission abused its discretion in determining that Boyd-Davis was ineligible for unemployment benefits for the period from March 10, 2013, through March 30, 2013. View "Boyd-Davis v. Macomber Law, PLLC" on Justia Law

Joan Thrall appealed an Idaho Industrial Commission decision denying her unemployment benefits. The Commission concluded that Thrall was not entitled to benefits because she voluntarily resigned from St. Luke's Regional Medical Center without good cause. Thrall timely appealed, arguing that she was discharged and that St. Luke's failed to show the discharge was for misconduct. The Supreme Court reversed and remanded this case for further proceedings. Because the Commission's factual findings demonstrate that Thrall satisfied her burden to show that she was discharged, Thrall was entitled to benefits unless the discharge was for misconduct in connection with her employment, with St. Luke's carrying the burden to show the discharge was for misconduct. When the Commission mistakenly concluded that Thrall voluntarily resigned, it improperly placed the burden on Thrall to show that she was not discharged for misconduct. "Though the Commission's order includes a variety of statements regarding misconduct and Thrall's errors in the performance of her job duties, it is unclear to what extent those statements were a consequence of its misallocation of the burden of proof." View "Thrall v. St. Luke's Regional Med Cntr" on Justia Law

Charles Bell was employed by Sears from September 25, 2012, to May 16, 2013. During that period, Bell regularly filed for unemployment benefits with the Idaho Department of Labor (DOL). He received benefits for each week beginning with the week ending on Sept. 29, 2012, through the week ending on March 23, 2013. On March 26, 2013, the DOL discovered discrepancies between the weekly gross wages reported by Bell in his unemployment filings and the gross wages reported to the DOL by Sears. Based on the information provided by Bell, the DOL determined that Bell willfully misstated his gross wages for nineteen weeks in which he received benefits and that he was ineligible for benefits for nine weeks in which he claimed to have worked part-time hours despite working at least forty hours. Bell was disqualified from receiving benefits for fifty-two weeks, ordered to repay benefits he received for the relevant periods, and ordered to pay penalties for willfully misrepresenting his gross wages and the hours he worked in particular weeks. Bell appealed the Idaho Industrial Commission's holding that he willfully made false statements or willfully failed to report material facts for the purpose of obtaining unemployment benefits. Because the Commission’s decision was supported by substantial and competent evidence, the Supreme Court affirmed. View "Charles Bell v. Idaho Dept. of Labor" on Justia Law

Idaho's Bureau of Occupational Licenses (Bureau) investigated and initiated disciplinary proceedings against petitioner-appellant Timothy Williams after it received complaints that he had engaged in various forms of professional misconduct as a licensed real estate appraiser. Ultimately, Idaho's Board of Real Estate Appraisers (Board) revoked Williams' license, imposed $4,000 in fines, and required Williams to pay the Board's attorney fees and costs. The district court, acting in an appellate capacity, affirmed the Board's decision to revoke Williams' license and to impose fines, but reversed the Board's order that Williams pay its attorney fees and costs. Williams appealed and the Board cross-appealed. Finding no reversible error, the Supreme Court affirmed the district court. View "Williams v. Idaho State Board of Real Estate Appraisers" on Justia Law

Cable One, Inc., is a Delaware corporation headquartered in Phoenix, Arizona. In 2005, Cable One received business income from four types of activities in Idaho: cable television services, internet access services, advertising services, and cable modem leasing. In its Idaho income tax return for that year, it included revenues earned from all of those activities except revenues from providing internet access services to Idaho customers. It excluded those revenues on the ground that providing such services to customers in Idaho constituted Arizona sales, although it also excluded such revenues from its 2005 Arizona income tax return on the ground that they came from Idaho sales. In 2008, the Idaho Tax Commission issued a notice of deficiency determination asserting a tax and interest deficiency on Cable One for the 2005 tax year. Cable One petitioned for redetermination, which the Tax Commission denied. Cable One then filed a complaint in the district court, which tried the matter de novo, and ruled in favor of the Tax Commission. Cable One then appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the district court. View "Cable One, Inc. v. Idaho State Tax Commission" on Justia Law