Justia Idaho Supreme Court Opinion Summaries

Articles Posted in Government & Administrative Law
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Appellant Habib Sadid, a former tenured professor of civil engineering at Idaho State University, appealed an Industrial Commission Order that reversed the Department of Labor Appeals Examiner's grant of unemployment benefits to Appellant after he was terminated by Idaho State University. Upon review, the Supreme Court concluded that the Commission's finding of misconduct was supported by substantial and competent evidence. As such, the Court affirmed the Industrial Commission's order. View "Sadid v. Idaho State University" on Justia Law

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CDA Dairy Queen, Inc. and Discovery Care Centre, LLC of Salmon (collectively, Dairy Queen) filed a class action against the Idaho State Insurance Fund (SIF) seeking a declaratory judgment that SIF violated Idaho Code section 72-915 by failing to distribute premium rate readjustments on a pro rata basis. The district court granted SIF's motion for summary judgment, finding that the Idaho Legislature's retroactive repeal of section 72-915 was constitutional and that Dairy Queen's action was thereby barred. Dairy Queen appealed and argued that the retroactive repeal violated article I, section 16 of the Idaho Constitution. Dairy Queen the Supreme Court to reverse the decision of the district court and remand for further proceedings consistent with the determination that the retroactive repeal was unconstitutional. Upon review, the Supreme Court agreed with Dairy Queen and reversed. View "CDA Dairy Queen, Inc. v. State Insurance Fund" on Justia Law

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A bail bond company challenged the district court's decision affirming an order of the Director of the Idaho Department of Insurance. That order, which was based on I.C. 41-1042, prohibited a bail bond company from contemporaneously writing a bail bond and contracting with a client to indemnify the company for the cost of apprehending a bail jumper. It also prohibited a bail bond company from later requiring a client to agree to such indemnification as a condition of the bond's continuing validity. While the proceedings before the district court were pending, the Director promulgated I.D.A.P.A. 18.01.04.016.02, which by rule expressed the Final Order. Upon review of the applicable statutory authority and the trial court record below, the Supreme Court concluded that: (1) the plain text of I.C. 41-1042 permits a bail bond company to contemporaneously write a bail bond and contract with a client to indemnify the company for the cost of apprehending a defendant who jumps bail; and (2) the Director's interpretation of I.C. 41-1042 prejudiced PetitionerTwo Jinn's substantial rights. The Court reversed the district court's memorandum decision and remanded the case for further review. View "Two Jinn, Inc. v. Idaho Dept of Insurance" on Justia Law

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Appellant Camas County appealed an injunction granted by the district court against the enforcement of Camas County Ordinances 150 and 153, and Resolutions 96 and 103 (2007 zoning amendments). Plaintiff-Respondent George Martin opposed the zoning amendments at a public hearing of the Camas County Board of Commissioners. In late 2008 while this case was still being adjudicated, Martin filed a complaint for declaratory judgment against 2008 zoning amendments. Camas County removed the case to the federal district court, which ultimately granted Martin's requested relief to the 2007 amendments. The federal district court then remanded the case to the state district court. Martin was granted attorney fees and costs as a result of the federal district court's order; the court held that Camas County acted without a reasonable basis in fact or law. Camas County appealed, maintaining that the district court abused its discretion in ordering the injunction and should have awarded the County attorney fees. Upon review, the Supreme Court found that the 2007 and 2008 zoning amendments were practically identical. Both cases involved the same property owned by Martin in Camas County. Thus, the facts between this case and the underlying case "Martin I" (concerning the 2007 amendments) were nearly identical. . . . as such, Martin properly conceded that the district court's injunction against the 2007 zoning amendments should have been reversed. Martin also properly conceded that his award of attorney fees by the district court also should have been reversed. The County was not entitled to a fee award. View "Martin v. Smith" on Justia Law

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The Idaho State Tax Commission appealed a district court judgment which held that PacifiCorp, an Oregon corporation, proved by a preponderance of the evidence that the Commission's valuation of its taxable operating property in Idaho was erroneous pursuant to I.C. 63-409(2). The Commission contended on appeal that the district court's decision was not supported by substantial and competent evidence because the appraisal methodologies utilized by PacifiCorp's appraiser are so unreliable as to amount to incompetent evidence. Because the district court's judgment was not clearly erroneous and was supported by substantial and competent evidence, the Supreme Court affirmed the district court's judgment. View "PacificCorp V. Idaho State Tax Commission" on Justia Law

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At issue in this case was the definition of the width of an easement for an irrigation pipeline. Dalton Gardens Irrigation District (the District) owned pipeline and intended to replace an existing four-inch pipe with a ten-inch pipe. A portion of the pipeline crosses Diane Ruddy-Lamarca's property. The parties agreed that an easement of some kind existed in favor of the District. However, they disagreed regarding the nature and width of that easement. The district court held that the District had an express easement and an easement by prescription that were identical in location and sixteen feet wide. The District appealed, claiming that the district court erred by restricting the easement to sixteen feet in width and requiring it to make every effort to preserve trees and a drain field on Ruddy-Lamarca's property. Upon review of the district court order, and finding no error in its decision, the Supreme Court affirmed. View "Ruddy-Lamarca v. Dalton Gardens" on Justia Law

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Kootenai County (the County) and Panhandle Health District No. 1 (the District) filed an action against Peggy Harriman-Sayler and Terry Sayler, seeking injunctive relief to prevent the Saylers from operating a recreational vehicle (RV) park without a conditional use permit, from occupying or using a building without a certificate of occupancy, and from operating a subsurface sewage system without a permit. The district court granted summary judgment in favor of the County and the District. The Saylers appealed, asking the Supreme Court to vacate the district court's judgment. Their argument on appeal was that the RV park did not require a permit because it was allowed as a nonconforming use and that the sewage system and other building were properly permitted. Finding no error in the district court's decision, the Supreme Court affirmed. View "Kootenai County v. Harriman-Sayler" on Justia Law

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Appellants Hobson Fabricating Corp. (Hobson) and SE/Z Construction, LLC (SE/Z) appealed a district court decision in their case against the State of Idaho, Department of Administration, Division of Public Works (DPW) regarding costs and attorney fees. Prior to the district court's decision, the parties had settled all of their claims but for costs and attorney fees. The district court declared that all parties had prevailed in part and were to bear their own costs and fees. Hobson and SE/Z appealed the decision, arguing that the district court abused its discretion and should have found that they were the overall prevailing party. Upon review, the Supreme Court affirmed the district court's order that the Contractors and DPW bear their own costs and fees and its order that Hobson pay the individual defendants' costs. View "Hobson Fabricating Corp v. SE/Z Construction" on Justia Law

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A mother appealed a magistrate court's order terminating her parental rights with respect to her youngest child. John Doe was born in September, 2011, and was declared to be in imminent danger two days after birth. John's mother, Jane Doe (Mother) had eight other children, all with her ex-husband (Father). One died shortly after birth, and the others are aged three to fifteen years old. Mother was not caring for any of these children when the Department of Health and Welfare (DHW) removed John from her care. In its Memorandum Decision and Order issued the same day, the court found by clear and convincing evidence that Mother "cannot parent this child now and that inability will continue indefinitely" and termination of her parental rights would be in the child's best interest. Mother's argument on appeal focused on whether the magistrate court properly weighed the evidence in making its best interest of the child determination. Upon review, the Supreme Court was satisfied that substantial evidence supported the magistrate court's findings, and accordingly held that the magistrate court did not err in determining that termination of Mother's parental rights was in John's best interest. View "Idaho Dept of Health & Welfare v. Jane (2012-05) Doe" on Justia Law

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This case appealed a district court's denial of Petitioner Jim Brannon's election contest of the Coeur d'Alene city council election in 2009. In the official vote total, Brannon lost the election for seat 2 of the city council to Mike Kennedy by five votes. Brannon then filed an election contest that alleged numerous irregularities and sought to set aside, void, or annul the election. After a bench trial, the district court issued a memorandum decision that affirmed the election result, finding insufficient illegal votes or irregularities to change the outcome of the election. On appeal, Brannon argued that the City delegated its election duties to Kootenai County in contravention of Idaho law, that the district court made numerous factual and legal errors at trial, and that the district court erred in denying Brannon's motion to disqualify and motion for new trial. Upon review and finding no error, the Supreme Court affirmed the decision of the district court. View "Brannon v. City of Coeur D'Alene" on Justia Law