Justia Idaho Supreme Court Opinion Summaries

The issue before the Supreme Court in this case centered on an appeal from several district court rulings in an ongoing dispute between Kyle Athay (Athay) and Rich County, Utah (Rich County). Athay was injured in a motor vehicle collision with Daryl Ervin (Ervin), who was fleeing police pursuit. Subsequently, Athay filed a civil suit against the pursuing law enforcement officers from Bear Lake County, Idaho and Rich County. After "Athay II," a jury trial commenced with Rich County as the sole remaining defendant. The jury returned a special verdict for Athay and awarded him $2,720,126.00 in economic damages and $1,000,000 in non-economic damages. The jury found that Ervin was 70% responsible for Athay’s injuries, and that Rich County was responsible for the remaining 30%. On appeal, Rich County argued that the district court made multiple errors: that the district court abused its discretion when it declined to disqualify the presiding judge for the limited purpose of deciding Rich County’s First Motion for a New Trial; that the district court erred by denying Rich County’s first and second motions for new trial; and that the district court erred when it denied Rich County’s Motion for Judgment Notwithstanding the Verdict. Finding no error, the Supreme Court affirmed the decisions of the district court. View "Athay v. Rich County, Utah" on Justia Law

The Idaho Department of Fish and Game (IDFG) appealed the district court's post-judgment orders (1) refusing to lift a portion of an injunction and (2) declaring the Idaho Outdoor Sport Shooting Range Act unconstitutional. In 2004, IDFG made a public proposal to renovate the Farragut Shooting Range, (owned and operated by IDFG since World War II), based on the "Vargas Master Plan." Citizens Against Range Expansion (CARE), an unincorporated non-profit association comprised of individuals who reside near the range, contended that the plan would greatly increase range usage, and harm the community. CARE sued IDFG in 2005 for nuisance and other related causes of action regarding the range's operation. CARE's claims were grounded in both safety and noise concerns regarding the increased use of the range, and its proposed expansion. Among other relief, CARE sought to enjoin IDFG's operation of the range. The case proceeded to a court trial in December of 2006 and in February of 2007 the court issued its memorandum decision wherein it determined that CARE was entitled to relief enjoining further operation of the Farragut Range until IDFG completed certain safety improvements. Upon completion of its range improvements, IDFG filed a Motion for Partial Lifting of Injunction. CARE then moved for summary judgment, claiming that the Act was a special law in violation of art. III, sec. 19 of the Idaho Constitution, and a deprivation of judicial power in violation of art. V, sec. 13. The district court issued summary judgment in favor of CARE on the constitutional issues in March of 2011. In its order, the court found that the Act was unconstitutional as a special law and a deprivation of judicial power. For this reason alone, it denied IDFG's Relief Motion with regard to the 501-shooter component. The court found that there remained disputed issues of fact regarding range safety. On August 25, 2011, following the evidentiary hearing on safety issues, the district court denied IDFG's Relief Motion with regard to the one component of the injunction. IDFG timely appealed to the Supreme Court. Upon review, the Supreme Court: 1) reversed the district court's order holding that IDFG did not comply with the "500-shooter" component of the injunction; 2) concluded as a matter of law that IDFG complied with the 500-shooter component, and lifted that component of the injunction; 3) reversed the district court's order holding the Act to be unconstitutional; 4) remanded this case to the district court to determine whether IDFG has complied with the "501-shooter" component of the injunction. View "Citizens Against Range Expansion v. Idaho Fish & Game" on Justia Law

The issue before the Supreme Court in this case was whether an agricultural exemption for real property taxes was not available to Petitioner-Appellant Thompson Development, LLC because agricultural use of the property in question would violate a local zoning ordinance. Because the Supreme Court found that the zoning ordinance was irrelevant to qualifying for the exemption, the Court vacated the district court's judgment and remanded the case for further proceedings. View "Thompson Development v. Latah Co Bd of Equalization" on Justia Law

This appeal arose from the district court's reversal of the Idaho Transportation Department's (Department) suspension of Johnathan Paul Van Camp's driver's license subsequent to a urine analysis that revealed the presence of cyclobenzaprine in his system. The district court held that the Department had not properly shown that cyclobenzaprine was intoxicating. The Department timely appealed, arguing that the arresting officer's observations of impairment, in combination with an evidentiary test revealing a drug in Van Camp's system, were sufficient to permit an administrative license suspension. The Department asked the Supreme Court to reverse the district court's decision vacating the suspension. Finding that Van Camp failed to establish a proper ground to support an order vacating the suspension, the Supreme Court reversed the district court and remanded the case for further proceedings. View "Idaho Dept. of Trans. v. Van Camp" on Justia Law

The Idaho Wool Growers Association (IWGA) and several of its members brought suit against the State of Idaho, claiming that the State failed to protect domestic sheep operators from curtailment of their grazing allotments by the United States Forest Service. The curtailment of the allotments was designed to accommodate the reintroduction of bighorn sheep in the Hells Canyon area. In their complaint, the Wool Growers alleged that the State was obligated to redress damage caused to domestic sheep operations by virtue of the reintroduction. The district court dismissed the complaint for failure to state a claim upon which relief can be granted. The Wool Growers appealed that dismissal, but upon review, the Supreme Court affirmed. View "Idaho Wool Growers v. State of Idaho Fish & Game" on Justia Law

This was an appeal of a district court’s grant of summary judgment in favor of the State of Idaho, former Governor James E. Risch, and former Fish and Game Department Director Steven Huffaker (collectively "Defendants"). Appellants, Rex and Lynda Rammell, owners of a domestic elk ranch, brought suit against Defendants to recover for the loss and destruction of elk that escaped from their ranch in 2006. Upon review of the matter, the Supreme Court affirmed the judgment of the district court. View "Rammell v. Idaho" on Justia Law

The appellant had filed a petition for reconsideration of an administrative order issued by the Idaho Department of Water Resources, and, when the Department failed to decide the merits of the petition within twenty-one days, the appellant filed a petition for judicial review of the Department’s order, contending that the petition for reconsideration was deemed denied pursuant to Idaho Code section 67-5246(4). The Department later decided the petition for reconsideration and issued an amended order. The district court held that section 67-5246(4) did not require the Department decide the merits of the petition for reconsideration within twenty-one days; it only had to agree to consider the petition within that time frame. The court therefore dismissed appellant’s petition for judicial review on the ground that the order it sought to have reviewed had been superseded by the amended order. The Supreme Court vacated the dismissal because the petition for reconsideration was deemed denied by section 67-5246(4) when the Department failed to decide it within twenty-one days, and the amended order was therefore a nullity because the Department did not have jurisdiction to issue it. View "A&B Irrigation District v. Idaho Dept of Water Resources" on Justia Law

This appeal arose from a claim filed by the Idaho Department of Health and Welfare in the probate proceeding of George D. Perry, the deceased spouse of Medicaid recipient Martha J. Perry. The Department sought to recover funds under I.C. 56-218 from the sale of the couple’s home (their only significant asset) to recoup Medicaid benefits paid to Martha during her lifetime. The magistrate court disallowed the Department’s claim for recovery, finding that Martha had no interest in the real property because George, acting for Martha under a power of attorney, conveyed the property to himself before his death. That decision was upheld on appeal to the district court. The Department appealed to the Supreme Court. Upon review, the Court found that the district court erred in finding that federal law preempted the Department's ability to recover from George's estate what was once Martha's community property during the marriage. The Court reversed the district court and remanded the case for further proceedings. View "Id. Dept. of Health & Welfare v. McCormick" on Justia Law

This case concerned the Director (Director) of the Idaho Department of Water Resources' application of the Rules for Conjunctive Management of Surface and Ground Water Resources (CM Rules) in response to a ground water to ground water delivery call filed by the A&B Irrigation District (A&B). The Director’s Final Order found that A&B was not materially injured and was affirmed by the district court on nearly all points. A&B appealed to the Supreme Court, contending that the Director and the district court erred in their analyses. The City of Pocatello and the Idaho Ground Water Appropriators, Inc. cross-appealed alleging that the district court erred by requiring that the Director's finding of no material injury must be supported by clear and convincing evidence, rather than a preponderance of the evidence. Upon review of the matter, the Supreme Court affirmed the decision of the district court. View "A & B Irrigation v. Idaho Dept of Water Resources" on Justia Law

This case concerned the ownership status of Coolwater Ridge Road in Idaho County. The predecessors in interest of appellant Paddison Scenic Properties, Family Trust, L.C. granted rights of way to the United States for a road which became Coolwater Ridge Road. In the district court, Paddison sought a declaratory judgment that the rights of way did not constitute a public road or highway under Idaho law. That court held that the rights of way were public because the criteria for common law dedication were met. Upon review, the Idaho Supreme Court vacated the district court's judgment because it concluded this case was not ripe for adjudication. View "Paddison Scenic Properties Family Trust v. Idaho County" on Justia Law