Justia Idaho Supreme Court Opinion Summaries

Petitioner Peter Kaseburg was a littoral owner on Lake Pend Oreille who held an encroachment permit for a series of decaying wooden pilings that were driven into the lakebed in the 1930s. With the exception of a single piling that a neighboring marina uses to anchor one of its docks, the pilings never had any known navigational purpose. Petitioner applied to the Idaho Department of Lands (IDL) for a permit to replace ten of the wooden pilings with steel pilings, but failed to specify any navigational purpose for this proposal. The IDL considered the application a request for a nonnavigational encroachment permit and denied it after receiving several objections. While a final decision was still pending on the first permit application, Petitioner filed a second application for a permit to install a mobile dock system and mooring buoy. The IDL considered the second application a request for a permit for a navigational encroachment extending beyond the line of navigability. Again, the IDL received many objections and denied the application. Petitioner then sought judicial review, which reversed the IDL. The court held that all pilings were navigational encroachments as a matter of law, regardless of whether they have ever been used to aid navigation. The district court set aside both denials. The IDL appealed to the Supreme Court. Upon review, the Supreme Court reversed the district court with respect to the first application, but affirmed the district court with respect to the second. View "Idaho Bd of Land Comm v. Kaseburg" on Justia Law

Appellant Matthew Mazzone appealed an Idaho Industrial Commission's order that denied him workers' compensation for psychological injuries allegedly arising as a result of an industrial accident wherein appellant tripped and fell into a deep fat fryer while employed at Texas Roadhouse. Appellant contended the Commission’s order was not based on substantial and competent evidence. During his time at a Burn Center, appellant was twice noted in medical records to be exhibiting exaggerated pain behaviors. At one point during his treatment, appellant stayed at a hotel in Salt Lake City so as to receive follow-up care. In a follow-up at the Burn Center, appellant had quit "cold turkey" his opioid medication, at which point he began to experience nightmares and flashbacks. Appellant was referred to an Idaho psychiatrist. The Idaho psychiatrist clarified that appellant's nightmares and anxiety were related to returning to work; appellant was assessed a GAF score of 55/85, the same assessment he had before the industrial accident. Three months after accident, appellant returned to work, but he was allegedly so overwhelmed that he asked to transfer to another Texas Roadhouse location in Massachusetts because he was nervous, sick, worried, and nauseous working at the site of the accident. Subsequent years following the accident, appellant sought additional counseling and medical treatment. He was eventually diagnosed with post-traumatic stress disorder (PTSD) and general anxiety and memory loss. Appellant then filed a complaint against Texas Roadhouse and its insurer. Upon review, the Supreme Court concluded that appellant did not suffer a compensable psychological injury, and that the evidence presented was substantial enough to support the Industrial Commission's order. View "Mazzone v. Texas Roadhouse" on Justia Law

This appeal stemmed from a protracted contract dispute arising out of the construction of Meridian’s new City Hall. The City brought suit against the project’s construction manager, Petra, Inc., alleging that Petra breached the parties’ agreement in a number of ways. The City further claimed that Petra was not entitled to any additional fees for its work. Petra counterclaimed, seeking an equitable adjustment of its construction manager fee. After trial, the district court entered its findings of fact and conclusions of law, ruling against the City on all but one of its claims and awarding Petra an additional fee for its services. The court awarded Petra $595,896.17 in costs and $1,275,416.50 in attorney fees, but stayed enforcement of the judgment pending appeal. The City appealed. Finding no error in the district court's judgment in favor of Petra, the Supreme Court affirmed. View "City of Meridian v. PETRA Inc." on Justia Law

Plaintiff-Appellant Brian Woodworth brought suit against the State and the City of Nampa to recover damages for injuries he sustained while pushing a shopping cart across a state highway. Both defendants moved for summary judgment. Following a motion hearing, the court granted both motions. The district court granted summary judgment in favor of the State on two separate grounds: (1) the State was entitled to immunity from suit; and (2) regardless of immunity, the court found that Woodworth failed to raise a genuine issue of material fact that the State acted negligently. Following the summary judgment ruling, Woodworth reached a settlement with Nampa whereby the City was dismissed from the case. Woodworth filed an appeal with regard to the court’s dismissal of his claim against the State. Upon review of the district court record, the Supreme Court concluded that the district court correctly applied the immunity test as outlined in applicable precedent. Because Woodworth failed to present a viable negligence claim against the State, the Court affirmed the district court's judgment. View "Woodworth v. Idaho Transportation Bd" on Justia Law

This was an appeal of an order setting aside a sheriff's sale of real property. The respondents, Earline Chance and Leon Phillips who were deed of trust beneficiaries and judgment creditors, failed to attend or bid at the sheriff's sale but claimed the successful bidder, appellant Roy Jacobson, obtained the property for a grossly inadequate price. The district court agreed and set the sale aside. Upon review, the Supreme Court found that the district court indeed erred in setting aside the sheriff's sale, and reversed. View "Phillips v. Jacobson" on Justia Law

In 2008, the legislature enacted legislation to establish the Idaho Education Network (IEN), which was to be a high-bandwidth telecommunications distribution system for distance learning in every public school in the state. Syringa Networks, LLC (Syringa), an Idaho telecommunications company, entered into a “teaming agreement” with ENA Services, LLC (ENA). Pursuant to their agreement, ENA submitted a proposal in response to a request-for-proposals (RFP) with the Department of Administration, although the cover letter stated that both ENA and Syringa were responding jointly to the proposal. Qwest Communications Company, LLC, and Verizon Business Network Services, Inc., also submitted responsive proposals. The proposals were then scored based upon specific criteria; the ENA and Qwest proposals received the highest scores. The Department issued a letter of intent to award contracts to Qwest and ENA. One month later, it issued amendments to the two purchase orders to alter the scope of work that each would perform. Qwest became "the general contractor for all IEN technical network services" (providing the “backbone”) and ENA became "the Service Provider." The effect of these amendments was to make Qwest the exclusive provider of the backbone, which was what Syringa intended to provide as a subcontractor of ENA. Syringa filed this lawsuit against the Department, its director, the chief technology officer, ENA and Qwest. The district court ultimately dismissed Syringa’s lawsuit against all of the Defendants on their respective motions for summary judgment. Syringa then appealed the grants of summary judgment, and the State Defendants cross-appealed the refusal to award them attorney fees. Upon review, the Supreme Court affirmed the judgment dismissing all counts of the complaint except count three seeking to set aside the State's contract with Qwest on the ground that it was awarded in violation of the applicable statutes. Furthermore, the Court reversed Qwest’s award of attorney fees against Syringa. We remand to the trial court the determination of whether any of the State Defendants were entitled to an award of attorney fees against Syringa for proceedings in the district court. The Court awarded costs and attorney fees on appeal to ENA. Because the State Defendants and Syringa both prevailed only in part on appeal, the Court did not award them either costs or attorney fees on appeal. View "Syringa Networks v. Idaho Dept of Admin" on Justia Law

Appellant Altrua HealthShare appealed the district court's decision affirming the Idaho Department of Insurance's (Department) determination that Altrua transacted insurance without a certificate of authority. Altrua argued that both the Department and the Ada County district court erred in finding that Altrua was an insurer because Altrua never assumed the risk of paying its members' medical bills. The Department found, and the district court affirmed, that when members make their predetermined monthly payments into the escrow account Altrua operates, the risk of payment shifts from the individual members to the escrow account, and in turn to Altrua. Altrua also contended that the Department's determination that it is an insurer despite the disclaimers in its membership contract to the contrary is an unconstitutional interference with Altrua's right to contract. Upon review, the Supreme Court found that the Department's conclusion that Altrua's membership contract was an insurance contract was clearly erroneous, and reversed the findings. The case was remanded for further proceedings. View "Altrua Healthshare v. Deal" on Justia Law

Pro se plaintiff Martin Bettwieser brought a breach of contract action against the New York Irrigation District and its directors (collectively, the District). Bettwieser alleged that the District breached an oral contract by not timely providing him with a legal opinion regarding whether he could be excluded from the irrigation district without paying statutory exclusion and filing fees. Following a bench trial, the district court issued findings of fact and conclusions of law, ruling that Bettwieser had failed to demonstrate that he was entitled to relief. Bettwieser appealed, alleging the district court made errors of fact and law during the trial and in its decisions regarding Bettwieser's pre- and post-trial motions. As a preliminary matter, the Supreme Court noted that Bettwieser's briefing was, "at best, difficult to follow. In some cases, it is unclear what issue Bettwieser is attempting to raise. And, even where an issue is identifiable, argument, authority, and legal reasoning are often absent." The Court concluded that the district court's findings of fact and conclusions of law were supported by substantial competent evidence. Bettwieser failed to satisfy the requirements for certification of a class action. The district court was not obligated to consider claims not raised by the pleadings. The district court did not abuse its discretion in denying Bettwieser's motion to disqualify counsel. Bettwieser was not entitled to declaratory judgment because he failed to demonstrate the existence of an actual or justiciable controversy. View "Bettwieser v. New York Irrigation Dist." on Justia Law

In 2011, the Idaho Department of Health and Welfare (the Department) initiated this action to terminate the parental rights of John Doe. The matter proceeded to trial where the magistrate court found that Doe had neglected and abandoned his minor child, D.C., and that it was in the best interest of the child that Doe's parental rights be terminated. Doe appealed and the Supreme Court affirmed: Doe failed to show that the magistrate erred in finding that he had abandoned D.C. "Even if the Department failed to implement the case plan in an appropriate fashion, the magistrate's finding of neglect was supported on a prong of neglect essentially independent of case plan performance. Doe has made no effort to show that it is not in the best interest of D.C. to terminate Doe's parental rights. There are no grounds to reverse the termination order." View "Health & Welfare v. Doe" on Justia Law

This case was an appeal to challenge the administrative rule adopted by the Industrial Commission in 1994 that regulates the amount of attorney fees allowable for attorneys representing claimants in worker's compensation proceedings. Upon review of the facts of this case, the Supreme Court upheld the validity of the rule. View "Seiniger Law v. Industrial Commission" on Justia Law