Justia Idaho Supreme Court Opinion Summaries

Plaintiff-Appellant Thomas Weisel owned two adjacent parcels within the Beaver Springs Subdivision in Ketchum. He sought to unify and develop the lots. At some point, his plan indicated that he intended that construction would take place in a "setback zone" that abutted the lots' shared border. Plaintiff and the Beaver Springs Owners Association executed an agreement whereby Beaver Springs approved the unification and development plan. Construction on the property was completed in 1985, all structures were located on what used to be "lot 14" and the former setback zone and "lot 13" remained vacant. In 2009, Plaintiff filed suit to rescind or reform the agreement. The district court granted Beaver Springs' motion for summary judgment, and Plaintiff appealed. Upon review, the Supreme Court concluded that "[i]n essence, Plaintiff asked the Court to reform an agreement for which the parties freely bargained." As such, the Court found that the district court properly granted summary judgment in favor of Beaver Springs. View "Weisel v. Beaver Springs Owners Association, Inc." on Justia Law

Claimant Brooke Stark worked for Assisted Living Concepts, Inc. from 2008 to 2010 as a "residence director" of one of Assisted Living's facilities. Claimant was called into the sales director's office one day, and the two talked about a rumor that one of Assisted Living's other facilities was imminently closing. Later that evening, Assisted Living's divisional director of human resources called Claimant to ask where Claimant heard of the closing rumor. Claimant did not disclose her source. Five minutes following that call, Assisted Living's chief executive officer called Claimant (with the director of HR on the call) to ask about the rumor. Claimant said she talked to a number of people, but that she did not want to share the information. The CEO emphasized the importance of knowing who started the rumor so that the company could reassure those involved that the facility in question would not close. Still declining to reveal her source, the CEO suspended Claimant. The human resources director, after a little investigation, found that Claimant violated company policy by refusing a direct order from her supervisor. Claimant was then terminated in the fall of 2010. The issue before the Supreme Court involved whether Claimant's refusal to respond to the CEO's question. The Industrial Commission held that Claimant's refusal to obey the direct order did not constitute misconduct under the Employment Security Law. The Supreme Court held as a matter of law, Claimant's conduct was indeed misconduct under the Employment Security Law, and reversed the Industrial Commission. View "Assisted Living Concepts , Inc. v. Idaho Dept of Labor" on Justia Law

This case arose from a district court's dismissal for failure to exhaust administrative remedies of Petitioner-Appellant Daniel Fuchs's petition for judicial review and complaint for declaratory and injunctive relief. Petitioner challenged the Alcohol Beverage Control's (ABC) removal of his name from liquor license priority waiting lists. He argued that the agency's action constituted an informal rule that was not promulgated in accordance with the Idaho Administrative Procedure Act (Idaho APA). In response, ABC argued that Petitioner failed to exhaust administrative remedies before bringing his action before the district court, and that the removal was done in accordance with Idaho APA. Upon review, the Supreme Court found that the district court erred in finding that Petitioner failed to exhaust administrative remedies, but that Petitioner did not have a property interest in his place on the priority list (since the legislature did not have the authority to create such an interest). Accordingly, the Court affirmed the district court's decision. View "Fuchs v. Idaho" on Justia Law

Jane Doe appealed the termination of her parental rights with regard to her son, John Doe, contending that the magistrate court failed to properly consider her improved participation in mental health and family counseling services. Because there was substantial and competent evidence to support the magistrate court's final Judgment that termination of Jane Doe's parental rights was in John's best interests, the magistrate court did not err in terminating her parental rights. View "Dept. of Health & Welfare v. Jane Doe" on Justia Law

Plaintiffs-Appellants Randolph Farber, Scott Becker, and Critter Clinic (Farber) alleged that the Manager of the Defendant-Respondent State Insurance Fund (SIF or "the Fund") failed to comply with I.C. 72-915, which provides the means by which the SIF Manager may distribute a dividend to policyholders. The district court determined that the gravamen of Farber's claim implicated the statute and held that the three-year statute of limitation provided by I.C. 5-218(1) barred all claims that accrued prior to July 21, 2003. Farber timely appealed. Upon review, the Supreme Court held that the five-year statute of limitation in I.C. 5-216 applied to Farber's claim. Therefore, the Court reversed the trial court's decision and remanded the case for further proceedings. View "Farber v. Idaho State Insurance Fund" on Justia Law

Defendants-Appellants Stanley and Catherine Jensen, as trustees of the Stanley and Catherine Jensen Family Living Trust, appealed the district court's decision that granted Plaintiff-Respondent Rocky Mountain Power's motion for summary judgment. Defendants are record owners of a cattle ranch that lies within a corridor established by the Utility for a 345 kilovolt transmission line. The Utility sought a perpetual easement and a right of way for the Utility and its successors and assigns to locate, construct, reconstruct, operate, and maintain a 150 foot wide high-voltage overhead power line utility corridor through the eastern part of Defendants' property. In 2008, Defendants entered into an Occupancy Agreement with the Utility, waiving all defenses to the Utility's acquisition of the easement, except the claim of just compensation. Upon execution of the Agreement, Defendants were paid $215,630 which would be deducted from any final determination of just compensation for the easement. Under the terms of the Occupancy Agreement, if just compensation was determined to be less than $215,630, Defendants were not required to return the difference. The parties were unable to reach an agreement for just compensation within a specified time, so the Utility filed its Complaint in early 2009, seeking a decree of condemnation, an award of easement, and specific performance of the Occupancy Agreement. The Utility filed a motion for summary judgment, contending that Defendants did not identify any expert witnesses or laid a proper foundation for any probative evidence of just compensation. Upon review, the Supreme Court found that Defendants failed to establish a genuine issue of material fact to establish the fair market value of their property. Accordingly, the Court affirmed the district court's judgment. View "Rocky Mountain Power v. Jensen" on Justia Law

Petitioner-Appellant Michael Maclay appealed the district court's decision affirming the Idaho Real Estate Commission's Final Order, which revoked his real estate license and assessed him a $5,000 fine. Petitioner allegedly used another person's broker's license to carry on Help-U-Sell List 4 Less Realty, prepared incomplete brokerage representation agreements without either a price provision or a conspicuous beginning and end date, advertised listed properties without a listing broker's licensed business name, used a new brokerage name prior to its approval by the Commission, provided misleading advertising to the public, accepted real estate fees not paid through a broker for the performance of acts requiring a real estate license, engaged in a continued or flagrant course of misrepresentation, failed to account for or remit any funds coming in his possession belonging to a brokerage, engaged in dishonorable dealings and recklessness or gross negligence, and acted as a real estate salesperson without a license. Petitioner challenged the sufficiency of the evidence presented against him, and that the Commission's decision exceeded its authority. Because the Commission's decision was supported by substantial evidence and the other issues were waived, the Supreme Court affirmed the Commission's decision. View "Maclay v. Idaho Real Estate Comm'n" on Justia Law

Burns Holdings, LLC, desired to construct a concrete batch plant in Teton County near the City of Driggs. Burns Holdings applied to the county for a zoning change from C-3 (commercial) to M-1 (light industrial), and the county approved the zoning change on the conditions that Burns Holdings and the county execute a development agreement, that the zoning will revert back to C-3 if the project does not come to fruition, and that Burns Holdings pay the impact area application fee. The city planning and zoning department approved the conditional use permit to increase the height limitation on Burns Holdings’s property to 75 feet. The matter was then sent to the county for its approval. The county scheduled a public hearing. At that hearing, there was confusion as to whether the matter being considered was an appeal from the decision of the city planning and zoning department or a decision for the county to make, and whether the county even had jurisdiction to make the decision because of the terms of an "area of city impact" agreement. The county commissioners ultimately decided that the decision of the city department was merely a recommendation and that the county had the responsibility to decide the CUP application. The CUP was ultimately denied, and Burns Holding appealed. The issue on appeal was the district court's decision that upheld the denial of the conditional use permit. Upon review, the Supreme Court agreed with the district court's conclusion that the zoning requirements could be waived only by variance, not by a conditional use permit. View "Burns Holdings, LLC v. Teton County Board of Commissioners" on Justia Law

Appellants in this case contended that the district court erred when it determined that an unnamed road in their subdivision was public by common law dedication. Appellants are property owners in Division III of the Sawtelle Mountain Subdivision of Fremont County, Idaho. The Sawtelle Subdivision plat was created and recorded in 1994. Although the C-shaped road does not intrude on any lots in the subdivision, the disputed road straddles two lots, one of which belongs to Appellants Joni Kepler-Fleenor and Kistin Fleenor, and the other of which belongs to Blue Sky Management, LLC. According to Appellants, heavy construction traffic heading into and out of the Stonegate Subdivision was bothersome and was damaging the disputed road. The owners of the road lots installed a berm and a gate to block traffic on the disputed road in 2005, but the County removed it in 2009, believing the disputed road to be public. Because the subdivision plat unambiguously dedicated the road, the Supreme Court affirmed the district court's ruling. View "Kepler-Fleenor v. Fremont County " on Justia Law

In 2006, Appellant V. J. Magee sustained a work-related injury causing harm to his lumbar spine and impacting the use of his right leg, leaving him in chronic pain. The Idaho Industrial Commission found that Appellant suffered a compensable industrial accident, that he sustained a ten percent permanent partial impairment to the whole body, and sustained a twenty percent permanent partial disability to the whole body. Magee appealed to the Supreme Court, which affirmed the Commission's 2004 decision. While that appeal was still pending, Appellant filed a second complaint with the Commission, arguing that the Commission's 2004 decision should be modified because of a change in his condition. The Commission held a second hearing, additional evidence was presented, and the Commission issued a final decision, concluding that Appellant failed to prove that a change in condition had occurred. The Commission also found that its earlier 2004 decision did not result in manifest injustice and that the benefit claims, which were previously litigated, were barred by res judicata. Upon review, the Supreme Court concluded that Appellant failed to establish a change in condition, that the 2004 decision did not result in manifest injustice, and that the issues regarding his medical benefits were barred under res judicata. View "Magee v. Thompson Creek Mining Co. " on Justia Law