Justia Idaho Supreme Court Opinion Summaries

Mark Radford and the State Board of Land Commissioners and the Idaho Department of Lands (collectively, "the State") were involved in a contract dispute over the State's easement on Radford's property. The State used the easement to access and manage state endowment lands leased for grazing. Historically, the State accessed the easement through the Hallo Property, which Radford purchased in 2020, subsequently revoking the State's access. Radford claimed that an email from the State indicated the easement was no longer needed, leading him to file a lawsuit alleging the State breached the termination clause of the easement agreement by not providing a statement confirming termination.The District Court of the Seventh Judicial District of Idaho granted summary judgment in favor of the State, determining that the termination clause gave the State sole and subjective power to decide whether the easement was necessary. The court found that the State had not made any determination that the easement was no longer needed, thus dismissing Radford's breach of contract claim. Radford appealed the decision.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court's decision. The court held that the State had no contractual duty to assess whether the easement was necessary for its granted purposes. The agreement's termination clause did not impose an obligation on the State to periodically reassess the easement's necessity. The court also rejected Radford's argument that the State's refusal to terminate the easement violated the covenant of good faith and fair dealing, as the State had not determined the easement was no longer needed. The court awarded attorney fees and costs on appeal to the State, concluding that Radford's appeal was unreasonably pursued. View "Radford v. Van Orden" on Justia Law

South Hill Meat Lockers Incorporated (South Hill) alleged that the Idaho Transportation Department (ITD) caused damage to its building during a road construction project on U.S. Highway 95 in Bonners Ferry, Idaho. South Hill claimed ITD was liable under seven different causes of action, including negligence and constitutional violations. ITD moved for summary judgment, asserting "plan or design immunity" under Idaho Code section 6-904(7). The district court initially denied ITD's first motion for summary judgment but later granted ITD's second motion for partial summary judgment, dismissing four of South Hill's claims. After a change in judges, the new judge granted ITD's motion for reconsideration, dismissing South Hill's complaint with prejudice.The district court's rulings were mixed. Judge Buchanan initially denied ITD's first motion for summary judgment, finding genuine disputes of material fact. However, she later granted ITD's second motion for partial summary judgment, dismissing several of South Hill's claims. Upon Judge Buchanan's retirement, Judge Berecz reconsidered and granted ITD's first motion for summary judgment, dismissing all of South Hill's claims.The Idaho Supreme Court reviewed the case and vacated the district court's judgment. The court affirmed in part and reversed in part the district court's summary judgment rulings. The Supreme Court found that there were genuine issues of material fact regarding whether ITD's change orders and the gas line relocation were meaningfully reviewed, which precluded summary judgment on the basis of plan or design immunity. The court also reversed the dismissal of South Hill's nuisance claim, holding that a nuisance claim for damages can persist even after the nuisance has abated. The court affirmed the district court's rulings on other claims, including the determination that Idaho Code section 55-310 does not impose strict liability. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "South Hill Meat Lockers Incorp. v. Idaho Transportation Dept." on Justia Law

Vernon K. Smith, Jr. was declared a vexatious litigant by the Fourth District Administrative District Judge (ADJ) in Idaho. This order prevents Smith from filing new litigation pro se in Idaho courts without obtaining prior permission from a judge. The determination arose from Smith's conduct in litigation concerning the administration of his mother Victoria H. Smith’s estate. Smith, a former attorney, was involved in contentious probate proceedings after his brother successfully challenged their mother's will, which had left the entire estate to Smith. The estate was subsequently administered as intestate, leading to multiple appeals and disciplinary actions against Smith by the Idaho State Bar.The district court found that Smith repeatedly filed frivolous and unmeritorious motions, including petitions to remove the personal representative (PR) and the PR’s counsel, motions to disqualify the district court judge, and objections to court orders. These actions were deemed to lack legal or factual basis and were intended to cause unnecessary delay. The PR of the estate moved to have Smith declared a vexatious litigant under Idaho Court Administrative Rule 59(d)(3), which the district court supported, leading to the referral to the ADJ.The Supreme Court of Idaho reviewed the case and affirmed the ADJ’s decision. The court held that the ADJ did not abuse its discretion in declaring Smith a vexatious litigant. The ADJ acted within the legal standards set forth in Rule 59(d) and reached its decision through an exercise of reason. The court also found that Smith’s due process argument was not preserved for appeal as it was raised for the first time. The court declined to award attorney fees to the ADJ, concluding that Smith’s appeal, although unsuccessful, was not frivolous or unreasonable. View "Smith v. Hippler" on Justia Law

Nicholas Roddy Ramlow and Amanda Marie Mitchell share custody of their minor son. The magistrate court had jurisdiction over their child custody case since 2016. In 2020, a temporary order was issued for the child to attend Kindergarten at Winton Elementary in Coeur d'Alene, Idaho. The parents later entered into a custody agreement that did not specify the child's school. In 2021, Mitchell moved to Pinehurst, Idaho, and enrolled the child in Pinehurst Elementary without informing Ramlow, who was under a no-contact order. Ramlow discovered the change in 2023 and attempted to enroll the child in Bryan Elementary in Coeur d'Alene, but the school secretary, Miriam McBenge, refused without both parents' consent or a court order.Ramlow filed a petition for declaratory judgment and a writ of mandamus in the district court to allow the child's enrollment in Coeur d'Alene. The district court dismissed the petition under Idaho Rule of Civil Procedure 12(b)(8), citing the ongoing child custody case in the magistrate court. Ramlow argued that the district court erred in its dismissal. McBenge and Mitchell requested the district court's decision be affirmed.The Supreme Court of Idaho reviewed the case. The court affirmed the district court's dismissal, agreeing that the magistrate court was better positioned to resolve the issue of the child's school enrollment due to its ongoing jurisdiction over the custody case. The court noted that the district court acted within its discretion and followed the appropriate legal standards. The case was remanded to the district court to amend the judgment to reflect a dismissal without prejudice. Additionally, the court awarded attorney fees on appeal to Mitchell under Idaho Code section 12-121, as Ramlow's appeal was deemed frivolous and without foundation. View "Ramlow v. Mitchell" on Justia Law

Elanore Vaughan purchased a ticket and signed an online liability waiver to go tubing at Eagle Island State Park, operated by Gateway Parks, LLC. The next day, Vaughan was injured when her tube went over an embankment and crashed into a flatbed trailer housing snowmaking equipment. Vaughan sued Gateway, alleging negligence and premises liability, claiming Gateway failed to maintain the tubing hill safely and created a hazard by placing the trailer at the end of the tubing run.The District Court of the Fourth Judicial District of Idaho denied Gateway's motion to dismiss Vaughan's complaint. Gateway argued that Vaughan's claims were barred by the liability waiver she signed and the Responsibilities and Liabilities of Skiers and Ski Area Operators Act. The district court found that while the Act applied, there was a genuine issue of material fact regarding the placement of the snowmaking equipment. The court also concluded that the liability waiver did not preclude Vaughan's claims. Gateway then sought and was granted permission to appeal the denial of its motion for summary judgment.The Supreme Court of the State of Idaho reviewed the case and reversed the district court's decision. The court held that the electronic liability waiver Vaughan signed precluded her claims against Gateway. The waiver explicitly acknowledged the risks of tubing, including collisions with manmade obstacles such as snowmaking equipment. The court determined that the waiver's language was broad enough to encompass Vaughan's accident and injuries. Consequently, the court directed the district court to grant summary judgment in favor of Gateway and dismiss Vaughan's complaint. The court also denied Gateway's request for attorney fees on appeal, as the gravamen of Vaughan's lawsuit was a tort, not a commercial transaction. View "Vaughan v. Gateway Park, LLC" on Justia Law

Petitioners sought to validate a portion of West Fork Pine Creek Road in Shoshone County, Idaho, which runs across private property and into public land managed by the Bureau of Land Management. The road is used by recreationalists to access an area known as "the Roller Coaster." Following disputes between local landowners and recreationalists, a petition was filed with the Shoshone County Board of Commissioners to validate the road. The Board denied the petition, citing concerns about environmental impacts, safety, and costs to taxpayers.The petitioners then sought judicial review in the District Court of the First Judicial District of Idaho, arguing that the Board erred in its decision. The district court affirmed the Board's decision, concluding that the Board's findings were supported by substantial and competent evidence. The petitioners appealed to the Supreme Court of Idaho, arguing that the district court erred in affirming the Board's conclusions.The Supreme Court of Idaho reviewed the case and determined that the Board erred in concluding that the 1909 meeting minutes did not establish the road as a public highway. However, the Court found no error in the Board's determination that validating the road was not in the public interest. The Court noted that the Board had considered various factors, including the availability of alternative access routes, the costs of surveying and maintaining the road, and the concerns of private property owners.Ultimately, the Supreme Court of Idaho affirmed the district court's decision, holding that while the road was established as a public highway in 1909, the Board did not abuse its discretion in determining that validation was not in the public interest. Neither party was awarded attorney fees on appeal. View "Jutila v. County of Shoshone" on Justia Law

Laura Milus, on behalf of herself and her minor son, D.L.J., filed a wrongful death action against Sun Valley Company after her husband died from colliding with snowmaking equipment while skiing at Sun Valley Ski Resort. Milus claimed that Sun Valley breached its duties under Idaho Code section 6-1103(2) and (6) by not properly marking the equipment and failing to post a notice about snowmaking operations.The District Court of the Fifth Judicial District of Idaho granted summary judgment in favor of Sun Valley, concluding that the company met its duty under section 6-1103(2) by placing yellow padding on the equipment and had no duty under section 6-1103(6) because the equipment was not actively discharging snow. The court did not address Sun Valley's argument that Milus' claims were barred by section 6-1106, which states that skiers assume the risk of injury from plainly visible or marked snowmaking equipment.The Supreme Court of Idaho reviewed the case and held that ski area operators are held to an ordinarily prudent person standard of care when performing duties under the Ski Area Liability Act. The court found that Milus failed to create a genuine issue of material fact regarding whether Sun Valley met this standard with the yellow padding. However, the court also held that there was a genuine issue of material fact about whether Sun Valley posted the required notice under section 6-1103(6).Despite this, the court affirmed the district court's decision, concluding that Milus' claims were barred by section 6-1106 because Mr. Milus assumed the risk of injury from the plainly marked snowmaking equipment. The court denied Sun Valley's request for attorney fees on appeal, as both parties prevailed on some arguments. View "Milus v. Sun Valley Company" on Justia Law

A group called Idahoans United for Women and Families filed an original action in the Idaho Supreme Court seeking writs of certiorari and mandamus. They challenged the fiscal impact statement (FIS) and ballot titles prepared for a citizen initiative titled the “Reproductive Freedom and Privacy Act.” The group argued that the FIS and ballot titles did not comply with Idaho law and requested the court to either certify their versions or order the Idaho Division of Financial Management (DFM) and the Attorney General to prepare new ones.The Idaho Supreme Court dismissed the petition against the Secretary of State, as Idahoans United failed to specify the writ or what they sought to compel. The court partially granted the writ of mandamus against DFM, finding that the FIS did not substantially comply with Idaho Code section 34-1812 due to a lack of a reasonable basis for its estimated fiscal impact, unclear language, and unnecessary legal terms. The court also partially granted the writ of mandamus against the Attorney General, concluding that the short ballot title did not substantially comply with Idaho Code section 34-1809 because it failed to capture all distinctive features of the initiative. However, the court found that the long ballot title substantially complied with the statutory requirements.The Idaho Supreme Court retained jurisdiction and ordered DFM to provide a new FIS and the Attorney General to provide a new short ballot title by a specified deadline. The court declined to certify the versions provided by Idahoans United and did not award attorney fees to any party. Upon submission, the court reviewed the new FIS and short ballot title, concluding that both substantially complied with the statutory requirements and certified the new short ballot title to the Idaho Secretary of State. View "Idahoans United for Women and Families v. Labrador" on Justia Law

Lisa Sánchez, a member of the Boise City Council, moved her residence outside of the district she represented. She was informed by the mayor and city council that she had automatically vacated her seat due to this move. The mayor subsequently appointed a new council member to fill her seat. Sánchez sued the City of Boise, claiming improper removal and seeking reinstatement, along with damages for lost salary and benefits. The City moved for judgment on the pleadings, which the district court granted, dismissing her case with prejudice. Sánchez appealed, questioning whether a city council member automatically vacates their seat under Idaho Code section 59-901(1)(e) when they unintentionally move out of their district.The district court concluded that Idaho Code section 59-901(1)(e) applies to city council members and that Sánchez's intent to remain a resident of her district was irrelevant. The court held that the statute's plain language indicated an automatic vacancy upon moving out of the district, regardless of intent. The court also found that Sánchez received all due process required under the statute.The Supreme Court of Idaho affirmed the district court's decision. The court held that Idaho Code section 59-901(1)(e) applies to city council members and that the statute's plain language does not require an inquiry into the official's intent. The court also concluded that no additional due process was required because any potential property interest in Sánchez’s elected position was forfeited when she moved out of her district. Thus, the district court's judgment on the pleadings in favor of the City was affirmed. View "Sanchez v. City of Boise" on Justia Law

A group called Idahoans United for Women and Families filed a petition seeking writs of certiorari and mandamus against the Idaho Division of Financial Management (DFM), the Idaho Attorney General, and the Idaho Secretary of State. The petition concerns the fiscal impact statement (FIS) and ballot titles for a citizen initiative titled the “Reproductive Freedom and Privacy Act.” Idahoans United argued that the FIS and ballot titles did not comply with Idaho law and requested the court to either certify their proposed versions or order the respondents to prepare new compliant versions.The Idaho Supreme Court reviewed the case. The court dismissed the petition against the Secretary of State, finding that Idahoans United failed to properly invoke the court's original jurisdiction against him. However, the court partially granted the writ of mandamus against DFM, concluding that the FIS did not substantially comply with Idaho Code section 34-1812 due to a lack of a reasonable basis for its estimated fiscal impacts, unclear and conflicting statements, and unnecessary legal terms. The court also partially granted the writ of mandamus against the Attorney General, finding that the short ballot title did not substantially comply with Idaho Code section 34-1809 because it failed to capture all distinctive features of the initiative. However, the court found that the long ballot title substantially complied with the statutory requirements.The Idaho Supreme Court retained jurisdiction and ordered DFM to provide a new FIS and the Attorney General to provide a new short ballot title by June 23, 2025. The court denied the request for attorney fees, noting that both parties prevailed in part. View "Idahoans United for Women and Families v. Labrador" on Justia Law