Justia Idaho Supreme Court Opinion Summaries

Appellant is the mother of two minor children who were placed into the custody of the Idaho Department of Health and Welfare on suspicion that they were abused or neglected. On March 27, 2009, the Canyon County Prosecuting Attorney filed a petition under the Child Protective Act alleging that Appellant’s infant daughter was abused. On April 8, 2009, the prosecutor filed an amended petition adding Appellant’s son and alleging that he was neglected. A year later, the prosecutor filed a petition seeking to terminate Appellant’s parental rights in her two children. The matter was tried to the magistrate court, which on December 7, 2011, issued its decision. The court found that Appellant had failed to complete the tasks required of her under the case plan. Finding no abuse of discretion, the Supreme Court affirmed the district court's judgment terminating Appellants parental rights. View "RE: Termination of Parental Rights of Jane (2011-24) Doe" on Justia Law

The appellant in this case, Kenneth Adler, had been appointed as guardian ad litem for the children of Plaintiff-Respondent Joseph Abolafia and Defendant-Respondent Rebecca Reeves who were involved in a proceeding to modify the custody provisions of their divorce decree. After the parties reached an agreement to resolve their dispute and the magistrate court terminated Appellant as guardian ad litem. Appellant sought to appeal, challenging his termination. The district court held Appellant did not have standing to appeal, and dismissed the appeal and awarded attorney fees to the parents. Upon review, the Supreme Court affirmed the district court: "Although he may have been miffed by his termination as guardian ad litem, injury to his pride is not justiciable. After he was terminated as guardian ad litem . . ., his actions in appealing to the district court have simply been those of an officious intermeddler. He had no standing to appeal." View "Abolafia v. Reeves " on Justia Law

Petitioner-Appellant Philip Hart appealed two State Tax Commission Notice of Deficiency determinations to the Board of Tax Appeals (BTA). The BTA found Petitioner's appeal untimely and dismissed it. Petitioner then appealed to the district court who likewise found the appeal untimely and dismissed the case for lack of jurisdiction. Upon review, the Supreme Court agreed with both the district court and the BTA, and dismissed Petitioner's appeal. View "Hart v. Idaho Tax Commission" on Justia Law

Plaintiffs-Appellants JoAn and Fred Ball were patrons of the City of Blackfoot's municipal pool. JoAn slipped on ice accumulated on the sidewalk between the pool and the parking lot. The Balls brought suit against the City. A district court granted summary judgment in favor of the City, dismissing the Balls' claims on grounds that property owners are not liable for injuries resulting from natural accumulations of snow or ice. The Balls appealed. Upon further review, the Supreme Court concluded the district court appealed the wrong legal standard to the Balls' case, and therefore its grant of summary judgment was in error. The Court reversed the district court and remanded the case for further proceedings. View "Ball v. City of Blackfoot" on Justia Law

When "Child" was three years and seven months old, his Mother was arrested while Child was in her care. Since Father was already incarcerated, the state declared Child to be in imminent danger. Child was placed in the the Department of Health and Welfare's custody, and a child protection case was initiated. The matter proceeded to trial, after which the trial court granted the Department's petition to terminate Father-Petitioner John Doe's parental rights. Father appealed. Finding clear and convincing evidence that termination of Father's parental rights were in Child's best interests, the Supreme Court affirmed the trial court's decision to terminate. View "Department of Health & Welfare v. Doe" on Justia Law

Plaintiff-Appellant Robert Arambarri was Regional Director of Region VI with the Idaho Department of Health and Welfare. In this capacity, he was a non-classified, at-will employee serving at the pleasure of the Director of the Department. Due to budget reductions, four of the seven regional director positions, including Plaintiff's position, were eliminated by the Director. Responsibility for the seven administrative regions was consolidated in the remaining three regional directors. Plaintiff contended that the Director did not have the statutory authority to abolish those positions. He further contended that the Idaho Board of Health and Welfare did not properly concur with a formal vote in the elimination of the four regional director positions. Upon review, the Supreme Court concluded that the district court did not err when it granted the Director's Motion for Summary Judgment and the denial of Plaintiff's Motion to Strike did not affect his substantial rights. The Court affirmed the judgment in favor of the Department. View "Arambarri v. Armstrong" on Justia Law

Claimant Gary Brown filed a complaint with the Industrial Commission seeking disability benefits after he injured his back while working for The Home Depot. Arguing that the injuries caused by the accident in combination with his preexisting conditions, left him permanently and totally disabled, Claimant sought workers' compensation benefits from both Home Depot and the Idaho Industrial Special Indemnity Fund (ISIF). The Commission determined that Claimant was not permanently and totally disabled. Claimant contended on appeal that the Commission erred by evaluating his ability to find work based upon his access to the local labor market at the time his medical condition stabilized in 2005. He argued that his labor market access should have been evaluated as of the date of the Commission hearing in 2009. He also argued that the Commission based its finding that he was 95 percent disabled on an incorrect understanding of the expert testimony presented at the hearing. Upon review, the Supreme Court held that Claimant's labor market at the time of the disability hearing was the proper labor market to be used in evaluating his disability. But because the Commission applied an incorrect legal standard, the Court vacated the Commission's decision and remanded the case for further proceedings. View "Brown v. Home Depot" on Justia Law

Appellant Lincoln McNulty worked as a ski patroller for Sinclair Services Company as a member of the Sun Valley Resort from 2005 to 2010. Once the ski season ended in 2009, Appellant filed for unemployment benefits effective April 2009, through November 2009. During those off-season months, he began working part-time at the Sawtooth Club for extra income. However, Appellant failed to report such employment or any earnings from the Sawtooth Club to the Idaho Department of Labor when he filed for unemployment benefits each week. The Idaho Department of Labor discovered the discrepancy and a claims investigator spoke with Appellant and ultimately issued an Eligibility Determination that Appellant was ineligible for benefits because he willfully made false statements or failed to report material facts in order to obtain benefits. Appellant appealed to the Supreme Court, arguing that his failure to report was not willful, the facts were not material, and that he should be eligible for a waiver of the requirement to repay the unemployment benefits. Upon review, the Court affirmed the Industrial Commission's conclusion that Appellant willfully failed to disclose material facts in order to obtain unemployment benefits and that he must repay the overpayment of both state and federal benefits as well as any applicable interest and penalties. View "McNulty v. Sinclair Oil" on Justia Law

On June 28, 2010, Appellant Maria Gomez filed a Worker’s Compensation Complaint with the Industrial Commission (Commission) claiming benefits for an accident that occurred in 2009, when she injured her lower back lifting sixty-pound boxes. The injury occurred at Blackfoot Brass (Dura Mark). Appellant had previously suffered two work-related accidents while working with Dura Mark, one in 2002, the other in 2006, but had returned to work without restrictions after participating in physical therapy for both injuries. The issue before the Supreme Court centered on a Commission order denying reconsideration of Appellant's motion to reopen the record to allow for additional evidence on the issue of causation. The Industrial Commission previously ordered that Appellant had failed to prove the medical treatment she received for a back injury was related to an industrial accident and injury. At the emergency hearing pursuant to the Judicial Rules of Practice and Procedure adopted by the Commission, Appellant introduced evidence regarding her entitlement to reasonable and necessary medical care pursuant to I.C. 72-432, but the referee denied Appellant's claim on the grounds of causation. Upon review, the Supreme Court affirmed the Commission's judgment. In doing so, the Court wanted to provide a "clear message that without a specific stipulation that causation will be a contested issue at the hearing pursuant to I.C. 72-713, and especially if there is a difference of opinion as to causation by opposing parties and their experts, claimant’s attorneys should no longer be lulled by anything other than a stipulation to all legal prerequisites and elements for recovery and be prepared to present evidence of a causal connection between the industrial injury or sickness and the required treatment." View "Gomez v. Dura Mark, Inc." on Justia Law

Fall River Rural Electric Cooperative hired Plaintiff-Appellant Suzette Bollinger as a cashier and receptionist at its Ashton headquarters in 1988. She was terminated in 2009 despite having satisfactory performance without cause. Plaintiff alleged in her complaint that she signed an employment contract at the time of her hiring, but she failed to produce the contract at trial. In 2009, Fall River adopted an "at-will" employment policy which expressly superseded any prior conflicting policy. Plaintiff ultimately sued Fall River for: (1) breach of express and implied contract, including breach of the covenant of good faith and fair dealing; (2) retaliatory discharge and wrongful termination in violation of public policy; and (3) negligent and intentional infliction of emotional distress. The district court granted summary judgment to Fall River on all of Plaintiff's claims. The district court also denied her motion for reconsideration, and she timely appealed to the Supreme Court. Finding that Plaintiff's claims were properly dismissed, the Supreme Court affirmed the district court's ruling. View "Bollinger v. Fall River Rural Electric Cooperative, Inc." on Justia Law