Justia Idaho Supreme Court Opinion Summaries

In March 2009, the City of Nampa issued a request for proposals regarding obtaining services to prosecute city misdemeanors and infractions. Former Canyon County prosecuting attorney John Bujak desired to contract with Nampa to perform those services. The Canyon County commissioners unanimously adopted a proposal pursuant to permit him to do so. Plaintiff-Appellant Bob Henry filed three public records requests with the county clerk asking for information regarding the contract with Nampa, including "invoices, etc sent to Nampa by county for prosecuting svc." and "an accounting of where those funds are being deposited + how they are being dispursed [sic] to Canyon County." Upon review, the Supreme Court held that the requested records were public records, but that the City could not be required to produce them because it was not the public official who refused to disclose the records. View "Henry v. Taylor" on Justia Law

The Supreme Court considered this appeal of a district court's decision pertaining to the "Snake River Basin Adjudication" which held: (a) that Pocatello could not use its wells as alternate points of diversion for its surface water rights; (b) that it could use its interconnected wells as alternate points of diversion for all of the associated water rights on the condition that doing so would not change the priority date and quantity of water that could be pumped from each well; (c) that one groundwater right was properly classified as for an irrigation purpose; and (d) that Pocatello failed to establish earlier priority dates for two of its groundwater rights. The City of Pocatello submitted an application to the State for a groundwater right, stating the proposed use was to irrigate crops located outside the city. The State challenged the City's claims of pre-existing rights and water access points upon which it would permit the City to make changes to then-current water rights. Upon careful review of the parties briefs and the applicable legal authority, the Supreme Court found sufficient evidence to support the district court's holding, and affirmed its judgment. View "City of Pocatello v. Idaho " on Justia Law

Claimant-Appellant Dennis Current appealed the Idaho Industrial Commission's denial of his unemployment benefits. Claimant argued that the Commission erred in finding he willfully made a false statement, and in failing to call one of his witnesses. The Department of Labor argued the Commission's findings were supported by substantial and competent evidence. The Supreme Court found that there was indeed substantial and competent evidence to support the Commission's findings that Claimant willfully made a false statement. The Court also found that the hearing officer did not abuse her discretion in finding that one of Claimant's witnesses would not provide relevant testimony. Accordingly, the Court affirmed the Commission's decision. View "Current v. Haddons Fencing, Inc. " on Justia Law

Former engineering professor Plaintiff Habib Sadid appealed the grant of summary judgment in favor of his former employer Defendant Idaho State University which dismissed his retaliation claim. Plaintiff alleged the University retaliated against him because of his comments criticizing the administration that had been published in a local newspaper over several years and that the University had breached his employment contract. Upon review careful review of the issues Plaintiff raised in his appellate brief, the Supreme Court affirmed the judgment of the district court dismissing the amended complaint. The Court vacated the denial of attorney fees to the University and remanded this case for consideration of its request for attorney fees in defending against the breach of employment contract claim. View "Sadid v. Idaho State University" on Justia Law

John Doe (Father) and Jane Doe (Mother) appeal from an order terminating their parental rights. The two appellants have three children together, and Mother has an additional child with another man. The magistrate terminated the parental rights of both parents as to all children, holding that both Father and Mother neglected the children and that termination was in the children’s best interest. In 2009, Mother was arrested for possession of methamphetamine. The arresting officer declared all four children in imminent danger and took them into protective custody. The children have been in State custody ever since. In June 2010, the State petitioned for termination of Mother's and Father's parental rights. The State's petition contended that both Mother and Father neglected the children: Mother, because she failed to complete a scheduled child protective case plan; Father, because he was incarcerated and unable to provide for the children. Mother stipulated "that she had put forth very little, if any, effort to comply with the … case plan prior to the time the State filed its petition to terminate her parental rights in this matter." In its memorandum decision, the court weighed the trial evidence and ultimately determined that Father and Mother neglected their children and that termination of their parental rights was in the children’s best interest. Both parents timely appealed. Upon review, the issue before the Supreme Court was whether there was substantial, competent evidence to support the magistrate judge's decision to terminate Mother’s and Father’s parental rights, and whether, as Mother argued, the State was estopped from seeking to terminate her rights. Because there was substantial and competent evidence to support the magistrate's findings that the children were neglected and that termination of his rights was in their best interest, the Supreme Court "[would] not disturb those findings." View "In re Termination of Parental Rights of John & Jane Doe" on Justia Law

This was an insurance coverage dispute between the County of Boise and its Insurer, Idaho Counties Risk Mangement Program (ICRMP). ICRMP refused to defend the County in Fair Housing Act (FHA) litigation in federal court, which the County claimed breached its insurance agreement. The district court determined the FHA claims against the County were excluded from the policy and granted summary judgment to ICRMP. Upon review, the Supreme Court concluded the district court properly granted summary judgment to ICRMP based on the land use exclusion in the Policy, and it therefore affirmed the district court's judgment. View "County of Boise v. Idaho Counties Risk Mgmt. Pgm. " on Justia Law

Plaintiff-Appellant Kepler-Fleenor and several other property owners in Division III of the Sawtelle Mountain Subdivision challenged a district court's decision that an unnamed road in their subdivision was public by common law dedication. Although the road did not intrude on any lots in the subdivision, it straddled two lots, one of which belongs to Plaintiffs Joni Kepler-Fleenor and Kistin Fleenor, and the other of which belongs to Blue Sky Management, LLC. According to Plaintiffs, heavy construction traffic heading into and out of an adjoining subdivision was bothersome and was damaging the unnamed road. Plaintiffs installed a berm and a gate to block traffic on the road, but the County removed it believing the disputed road to be public. After the County removed the road obstructions, Plaintiffs filed this lawsuit seeking a judgment to declare the road as private. The district court granted the County’s Motion for Summary Judgment, holding that the plat unambiguously showed the disputed road to be dedicated to public use. 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

Petitioner-Appellant Brian Sopatyk sought judicial review of the Lemhi County Board of Commissioners' decision to validate Anderson Creek Road, which ran the length of his property. He contended the road never became public and, if so, was abandoned. He also maintained that the validation was an unconstitutional taking, that it was error for the road easement to be validated at fifty-feet wide, that one of the commissioners was biased against him, that the road illegally invades federal public lands, and that the Board of Commissioners failed to explain why the validation is in the public interest. Upon review, the Supreme Court affirmed the validation decision, finding the road became public by legislative declaration in the late 1800s and was never abandoned. View "Sopatyk v. Lemhi County " on Justia Law

The City of Lewiston (City) enacted "Ordinance No. 4512" that created a stormwater utility and fee for the operation and maintenance of the its stormwater system. Five government entities (Entities) subject to the stormwater fee brought suit seeking a declaratory judgment that the fee was an unconstitutional tax requiring authorization by the Legislature. The Entities thereafter filed a motion for summary judgment. The City filed its cross-motion for summary judgment asserting that the stormwater fee was authorized pursuant to the City’s police powers, the Revenue Bond Act, the Local Improvement District Code, and various other provisions of the Idaho Code. Relying primarily on "Brewster v. City of Pocatello," (768 P.2d 765 (1988)), and finding no legislative authorization for the stormwater fee, the district court granted summary judgment in favor of the Entities, holding that the stormwater fee was an unconstitutional tax. The City filed an appeal of the district court's decision. Because the Supreme Court concluded that stormwater fee was an unauthorized tax, it held that the district court did not err in granting summary judgment in favor of the Entities. View "Lewiston Indep. Sch. Dist. #1 v. City of Lewiston " on Justia Law

The issue before the Supreme Court in this appeal was the City of Lewiston's rejection of a bid for a public works project on the grounds that the lowest bidder lacked sufficient experience for the project. In 2009, the City of Lewiston (City) advertised for bids to replace the irrigation system at the City golf course. Hillside Landscape Construction, Inc. (Hillside) desired to bid on the project, but prior to doing so it sent a letter to City stating that if City insisted upon having qualifications other than a current Idaho public works license to bid on the project, the City must follow the Category B procedures set forth in the Idaho Code and pre-qualify the bidders. Hillside asked that the qualification of prior experience be removed. City’s attorney denied the request, stating that City’s specifications and bidding process complied with state law. Hillside and four others submitted bids for the project. City notified the bidders that Hillside Landscape Construction submitted the lowest bid but that the company lacked the required experience specified within the bid documents. City awarded the contract to Landscapes Unlimited, the next lowest bidder. Hillside filed a complaint seeking injunctive relief, declaratory relief, and damages. The district court held that City complied with the bidding statutes, vacated a temporary restraining order, denied the motion for an injunction then dismissed Hillside’s complaint. In its review, the Supreme Court found that because the City chose to follow the "Category A" procedures set forth in the Idaho Code rather than the Category B procedures, the district court erred in holding that City could reject the bid on that ground. The Court therefore vacated the judgment of the district court and remanded the case for further proceedings. View "Hillside Landscape Construction, Inc. v. City of Lewiston " on Justia Law