Justia Idaho Supreme Court Opinion Summaries

In 2011, plaintiff-respondent Jamee Wade was shot twice by a Fruitland police officer after an altercation. Intending to file a claim under the Idaho Tort Claims Act, Wade sought copies of investigatory records related to the incident pursuant to the Idaho Public Records Act (IPRA). This appeal arose from a Petition for Access to Public Records filed by plaintiff seeking the disclosure of investigatory records in the possession of the Canyon County Prosecuting Attorney’s Office (CCPA). The district court ordered CCPA to produce the records pursuant to the request, but limited disclosure to Wade and his counsel. CCPA timely appealed. Upon review, the Supreme Court vacated the district court's judgment: the district court applied an erroneous legal standard in its analysis under I.C. 9-335. The records Wade requested were active investigatory records. View "Wade v. Taylor" on Justia Law

There are five children involved in this case: C.C., M.R., G.C., M.C.C., and A.C.C. The children have four different fathers. This appeal is the culmination of several child protection actions involving their mother Jane Doe. The State petitioned to terminate Jane Doe's parental rights as to all children, and Jane Doe appealed the ultimate termination order. Finding no reversible error, the Supreme Court affirmed. View "Re: Thermination of Parental Rights (mother)" on Justia Law

In 2006, claimant William Waters was working as a drywall hanger and taper. He was injured on a jobsite and sought medical care from a chiropractor. When chiropractic did not resolve his pain, he was recommended for surgery. The surgeon released Claimant to return to light work with a 45-pound lifting restriction. In 2007, the surgeon concluded that Claimant had reached medical stability, and he released Claimant to full activities, restricting him only from impact loading with axial activities, such as diving and gymnastics. Claimant returned to drywall work, but was laid off due to his difficulty keeping up. He applied for jobs at a convenience store and at rental car agencies, but was not hired. Later that year, Claimant sustained a whiplash injury to his neck in a rear-end motor vehicle accident, for which he sought and received emergency medical care. During the first part of 2008, he tripped and fell while running, sustaining an injury to his right shoulder for which he also sought and received emergency medical care. Claimant returned for treatment of right shoulder pain. After examining Claimant and conducting further testing, the doctor determined that Claimant had shoulder weakness from a nerve injury likely due to the industrial accident. Whether and to what extent Claimant was entitled to permanent partial disability benefits was tried to a referee. Claimant relied upon the testimony of two experts: his examining doctor and a vocational rehabilitation consultant. The central issue was whether the medical conditions identified by the doctor after the car accident were caused by the industrial accident. The referee concluded that Claimant had failed to prove that they were. The referee recommended that Claimant had failed to prove any permanent partial disability in excess of a 12% permanent partial impairment, which the State Insurance Fund (Surety) had already paid. The Commission adopted the referee’s proposed findings of fact and conclusions of law as its own. Claimant then timely appealed. Finding no reversible error, the Supreme Court affirmed the Industrial Commission. View "Waters v. All Phase Const." on Justia Law

Defendant-respondent New Sweden Irrigation District mowed canal banks on plaintiff-appellant Bradley Morgan's property. Plaintiff claimed New Sweden negligently damaged his property. New Sweden counterclaimed for a declaratory judgment as to its easement's existence and scope, and then moved for summary judgment. The district court granted partial summary judgment, holding that New Sweden's easement was sixteen feet wide and New Sweden was not liable for damaged items within its easement. The district court denied summary judgment as to plaintiff's claim for damaged items outside the easement. Plaintiff appealed. Upon review, the Supreme Court remanded this case back to the district court for that court to enter a judgment that described the precise location where the easement's sixteen-foot width measurement began. The Supreme Court affirmed the district court in all other respects. View "Morgan v. New Sweden Irrigation" on Justia Law

Dale Piercy appealed the district court’s dismissal of his amended action for declaratory relief, which challenged the validity of a herd district ordinance enacted in 1982 by the Canyon County Commissioners. The district court dismissed Piercy’s claim on the basis that it was barred by a seven-year statute of limitations or, in the alternative, a four-year statute of limitations. Piercy challenged the application of both statutes, and argued that Respondents Jennifer Sutton, Luis Guzman, and Canyon County waived any statute of limitations defense. Upon review, the Supreme Court found no reversible error, and affirmed the district court. View "Guzman v. Piercy" on Justia Law

In 1994, an en banc panel of the district judges of the Fourth Judicial District ordered Garden City and Meridian to provide suitable and adequate quarters for the magistrate’s division of the Fourth Judicial District. In addition to providing quarters, the Cities were ordered to provide for the equipment, staff, supplies, and other expenses necessary for the quarters to function properly. The Cities have never complied with the order. In 2010, Ada County brought a declaratory action asking the district judges to find that the 1994 Order was still valid and to require the Cities to comply with it. The Cities responded by filing a motion to vacate the 1994 Order, claiming that the order was invalid because it was entered on an ex parte basis. The en banc panel dismissed Ada County’s complaint, holding that a declaratory judgment action was not the appropriate means to determine the validity of the 1994 Order. The panel also denied the Cities’ motion to vacate on the grounds that before the 1994 Order was entered, the Cities had received all the process to which they were entitled. The Cities appealed. Finding that the appeal did not present a justiciable controversy, the Supreme Court dismissed the appeal. View "Ada County v. Garden City" on Justia Law

Attorney L. Clyel Berry argued that he was entitled to a 40% attorney fee award, based on a contingent fee agreement he entered into with Claimant VerDene Page. The Industrial Commission awarded Berry a 30% attorney fee award pursuant to Idaho Code 72-804, which requires an employer to pay reasonable attorney fees when it unreasonably withholds compensation from an injured employee. Upon review of the matter, the Supreme Court held: (1) the Commission's approval of a 30% attorney fee award under I.C. 72-804 was supported by substantial and competent evidence; (2) the Commission properly exercised its discretion in fixing the 30% fee; and (3) counsel's fee agreement with Claimant did not guarantee a certain attorney fee award. View "Verdene Page v. McCain Foods, Inc." on Justia Law

This appeal involves the transfer of the experience rating account for unemployment tax purposes from one employer to another pursuant to Idaho Code section 72-1351A(1)(a). After an investigation, the Department of Labor determined that the experience rating account of Diamond Z Trailer, Inc. (Diamond Z), which ceased operating in the spring of 2010, was transferred to Rule Steel Tanks, Inc. (Rule Steel), which hired the majority of the employees who were laid off by Diamond Z and which commenced marketing and manufacturing the same product that was manufactured by Diamond Z. Rule Steel appealed that determination. Finding no reversible error, the Supreme Court affirmed. View "Rule Steel Tanks, Inc. v. Dept of Labor" on Justia Law

The Idaho Power Company appealed an order of the Idaho Public Utilities Commission that denied approval of contracts between the utility and two wind farms on the ground that the contract rate for purchasing the power was contrary to public policy because it exceeded the utility's avoided costs. Finding no reversible error, the Supreme Court affirmed. View "Idaho Power v. Grouse Creek" on Justia Law

Bremer, LLC and KGG Partnership (collectively "Bremer") appealed a district court’s grant of summary judgment to East Greenacres Irrigation District ("EGID") and the district court’s denial of several additional motions. This case arose after EGID looped its pressurized water system to a main water line extension that Bremer constructed to serve Bremer’s land. Bremer claimed the extension was an illegal tax. The district court granted EGID summary judgment on the grounds that Bremer and EGID had an agreement under I.C. 43-330A where Bremer was responsible for constructing water line improvements to serve their land. Bremer argued on appeal that the district court erred because there were genuine issues of material fact regarding: (1) whether the parties reached an agreement under I.C. 43-330A; and (2) whether EGID had authority to require Bremer to pay for the extension. Finding no error, the Supreme Court affirmed the district court in all regards. View "Bremer v. E. Greenacres Irrig Dist" on Justia Law