Justia Idaho Supreme Court Opinion Summaries

Plaintiff Randy Hoffer challenged the district court's dismissal of three of his five tort claims against the City of Boise (City). Of two in particular, the district court dismissed Plaintiff's claims of tortious interference with a contract and defamation against the City because it held as a matter of law that under the Idaho Tort Claims Act (ITCA), a governmental entity could not be held liable for the torts of its employees when a complainant alleges malice and/or criminal intent. Upon review of the applicable legal authority and the trial record, the Supreme Court found that the ITCA indeed exempted governmental entities from liability for the intentional torts at issue in this case. Accordingly, the Court affirmed the lower court's dismissal of Plaintiff's claims. View "Hoffer v. City of Boise" on Justia Law

In 2001, Plaintiff Allied Bail Bonds, Inc. and Defendants the Kootenai County Sheriff and Board of Commissioners entered into a settlement agreement setting forth procedures for how inmates at the county jail would be informed of and obtain bail bonds. Allied brought suit alleging several claims including breach of the settlement agreement. The district court dismissed Allied's claims. Principal among them was Allied's contention that the Sheriff wrongfully diverted Allied's potential customers away from Allied, toward credit card companies, with the intent to harm Allied's business. Upon review, the Supreme Court found that Allied ran afoul of the technical pleading requirements of the legal authorities it used to support its claims. As such, the Court held that the district court properly dismissed Allied's claims against Defendants. View "Allied Bail Bonds, Inc. v. County of Kootenai" on Justia Law

Appellant Lynnette Patterson argued that she was constructively discharged from her position with the Fraud Unit of the state Department of Health and Welfare (IDHW) due to her complaints about an intra-office romance between her supervisor and a lateral employee. IDHW had a strict policy regarding romantic relationships between supervisors and employees. Ms. Patterson made multiple complaints regarding the relationship which she alleged resulted in her first negative performance review with the IDHW, culminating in a "constructive discharge." In 2007, she filed a complaint with the Human Rights Commission (IHRC) then with the district court. The court granted summary judgment to the IDHW, finding that Ms. Patterson did not file her claim within a proscribed 180 day period following her initial complaint, and that she failed to demonstrate that her complaint was a "protected activity" in order to sustain her claim. On appeal to the Supreme Court, Ms. Patterson argued that the district court erred in its determination. Upon consideration of the trial record, the Supreme Court affirmed the district court's decision, concluding that the evidence presented at trial was sufficient to support the dismissal of Ms. Patterson's case. View "Patterson v. Dept. of Health & Welfare" on Justia Law

Petitioner-Appellant Stan Hawkins appealed a decision by the Bonneville County Board of Commissioners that granted his neighbors Dale and Mary Meyers variances to replace aging homes on two parcels of their land. The parcels in question were originally zoned as agriculture, and each contained homes built before the 1940s. People living on the Meyers' land regularly used a road over Mr. Hawkins' land for access. Bonneville County enacted its zoning ordinance in 1959, after the homes on the Meyers' land were built and occupied. The ordinance required dwellings to have frontage along a county-approved road. No easement was ever granted across Mr. Hawkins' land, nor was a public road officially designated to the Meyers' property. The Meyers filed for variances in 2007 believing that they needed to comply with the frontage requirement. At a hearing, the Commissioners found that the Meyers' did not need variances because their property had been "grandfathered in" so that the frontage requirement did not apply. However, the Commissioners granted the variance anyway. A trial court dismissed Mr. Hawkins' petition for review, holding that he did not have standing to file a petition for judicial review, and he did not show that the County had prejudiced any of his substantial rights. Upon review of the trial court record, the Supreme Court found that Mr. Hawkins had standing to pursue his petition for judicial review. However, the Court dismissed his petition because he did not show any prejudice to his substantial rights. Accordingly, the Court affirmed the trial court's order dismissing Mr. Hawkins' petition. View "Hawkins v. Bonneville Cty. Bd. of Commissioners " on Justia Law

Appellants David and Marsha Steed are the former employers of Claimant Marsha Fearn. Ms. Fearn resigned from her job in April 2009, and sent an email with her personal contact information to approximately 7500 of the Steeds’ sales contacts. Upon finding out about this email, the Steeds terminated Ms. Fearn's employment. A state Department of Labor (DOL) appeals examiner and the Industrial Commission (Commission) both determined that the Steeds failed to show that Ms. Fearn was discharged for misconduct. The Steeds appealed the decisions of both the DOL and the Commission. Upon consideration of the record and the applicable legal authority, the Supreme Court found that the DOL's and Commission's decisions were supported by substantial and competent evidence. The Court affirmed the decisions. View "Fearn v. Steed" on Justia Law

Petitioner-Appellant Roger Steele and several residents appealed a district court order that dismissed their claim that the City of Shelley (City) illegally annexed land in Bingham County known as "Kelley Acres." The district court found that there was no statutory authorization for the district court's review of the annexation. On appeal to the Supreme Court, Appellants argued that the annexation was "arbitrary and capricious" and procedurally defective. Upon careful consideration of the arguments and the applicable legal authority, the Supreme Court found that there was indeed, no statutory authority for judicial review of the annexation. Furthermore, the Court found substantial evidence that supported the City's annexation of Kelley Acres. The Court affirmed the lower court's decision. View "Steele v. City of Shelley " on Justia Law

Plaintiff Eileen McDevitt tripped and fell on a recessed irrigation box outside Sportsman's Warehouse. The store was part of a larger shopping center. Plaintiff sued the store and others to recover for her injuries. The district court granted summary judgment in favor of the store, finding that as a tenant in the shopping center, the store owed no duty to shoppers (or invitees) to warn them of potential hazards. Plaintiff appealed to the Supreme Court. Upon careful consideration of the arguments and the applicable legal authority, the Supreme Court affirmed the lower court's decision. View "McDevitt v. Sportsmans Warehouse, Inc." on Justia Law

The Idaho Department of Water Resources (Department) appealed an order of the district court that required it to strike a term from a hydropower water right license issued to the Idaho Power Company. In 1984, an agreement was entered into between Idaho Power, the State, the governor, and the attorney general, in an effort to resolve a controversy associated with the company's water rights at the Swan Falls Dam. As part of the Swan Falls agreement, the parties agreed to support legislation for the commencement of an adjudication of water rights in the Snake River Basin. One key piece of the legislation that was passed pursuant to the Swan Falls Agreement gave the Department specific authority to subordinate hydropower rights in a permit or license to the rights of subsequent upstream depletionary users. The Department was also authorized to limit a permit or license involving hydropower to a term of years. The Department issued a final order that articulated the legal basis for including the "term of years" condition in the license to Idaho Power. The Company sought judicial review of the Department's final order, arguing that the Department did not have statutory authority to include a term condition in its license. The court indeed concluded that the Department did not have the authority to limit the license. The Department appealed to the Supreme Court. Upon review, the Supreme Court found that the Department had the statutory authority to include a term condition in Idaho Power's license. The Court reversed the district court's decision. View "Idaho Power Company v. Idaho Dept of Water Resources" on Justia Law

Coeur d'Alene Paving, Inc. (CDA Paving) leased several parcels of real property in Kootenai County from Beacon West, LLC. Approximately thirty acres of this leased property was zoned for mining activity. CDA had an interest in two undeveloped parcels that were initially zoned for agricultural use. The two agricultural parcels bordered the mining-parcel, but were not adjacent to it. In January 2008, CDA Paving submitted an application to the Kootenai County Building and Planning Department to have its two agricultural lots rezoned for mining. The Kootenai County Board of County Commissioners (BOCC) held public hearings on the application, and eventually approved the application. Several property owners located in the vicinity of the zone changes, including Appellant Linda Ciszek, petitioned the district court for a declaratory judgment, alleging the zone change was invalid. The district court granted summary judgment in favor of CDA Paving, holding that the BOCC had the authority to amend its zoning map. Appellants raised multiple issues with the district court's decision. Principal among their arguments to the Supreme Court was that the BOCC lacked statutory authority to approve a zoning application as it had for CDA Paving. The Supreme Court found all of Appellants' arguments persuasive, and affirmed the district court's decision. View "Ciszik v. Kootenai County Bd of Commissioners" on Justia Law

In October 2008, the Idaho Power Company filed an application with the Idaho Public Utilities Commission (IPUC) to modify its tariff. Some of the proposed amendments applied to the relocation of utilities facilities within public rights-of-way. The City of Nampa and the Association of Canyon County Highway Districts intervened in the proceedings, and each objected to the Company’s proposed amendments to the tariff. The IPUC approved the amendments, and Ada County Highway District (ACHD) filed a petition or reconsideration and clarification. Specifically, ACHD argued that the IPUC exceeded its authority in approving the amendments and that portions of the amended tariff were “an unlawful attempt to amend or abrogate the common law rule requiring a utility to relocate its facilities placed in a public right-of-way at its expense.” Upon review, the Supreme Court found that the IPUC exceeded its authority in determining utilities relocation within public rights-of-way. The Court set aside the amended tariff. View "Ada County Highway Dist. v. Idaho Public Utilities Comm’n " on Justia Law