Justia Idaho Supreme Court Opinion Summaries

Sean C. Flynn was laid off from his full-time job at Sun Valley Brewing Company during the COVID-19 pandemic and applied for unemployment benefits from the Idaho Department of Labor (IDOL) on March 25, 2020. Flynn received unemployment benefits from March 29, 2020, through June 27, 2020, while he was still employed part-time as a French teacher for the Community School, Inc. Flynn did not report his earnings from the Community School on the weekly certification forms required by IDOL. Additionally, when Flynn returned to full-time work at Sun Valley Brewing, he inaccurately reported his income for the week ending June 27, 2020.Flynn's claim for unemployment benefits was audited two years later, revealing discrepancies in his reported income. IDOL issued an eligibility determination letter retroactively denying Flynn's unemployment benefits and imposing civil penalties for willfully making false statements or failing to report material facts. Flynn appealed to the Idaho Department of Labor Appeals Bureau, arguing that his omissions were honest mistakes. The Appeals Examiner modified IDOL’s determination, finding Flynn misunderstood the reporting requirements for his part-time job but willfully misreported his income from Sun Valley Brewing for one week.IDOL appealed to the Idaho Industrial Commission, which conducted a de novo review and reversed the Appeals Examiner’s decision. The Commission reinstated IDOL’s original eligibility and overpayment determinations, concluding that Flynn’s omissions were willful based on the explicit instructions provided by IDOL and Flynn’s repeated failure to accurately report his income.The Supreme Court of Idaho affirmed the Commission’s decision, holding that Flynn’s omissions constituted a willful misstatement or concealment of material facts under Idaho Code section 72-1366(12). The Court determined that Flynn knew or should have known the necessity of reporting all income, and his failure to do so was intentional. Neither party was awarded attorney fees on appeal. View "Flynn v. Sun Valley Brewing Company" on Justia Law

Sentry Dynamics, Inc. (Sentry) requested a list of all property owners' names and addresses in Ada County from the Ada County Assessor’s Office. Ada County denied the request, suspecting Sentry intended to sell the data for use as a mailing or telephone list, which is prohibited under Idaho Code section 74-120(1). Sentry filed a complaint in district court seeking access to the records. The district court ordered Ada County to release the records in an electronic format of its choosing. Ada County appealed, and Sentry cross-appealed, requesting the records in the shapefile format used by the County.The district court of the Fourth Judicial District of Idaho ruled that the information Sentry sought was a public record and constituted a "list of persons" under Idaho Code section 74-120(1). The court held that Sentry was entitled to the records because it agreed not to use them as a mailing list. However, the court allowed Ada County to choose the electronic format for providing the records. Ada County appealed, arguing that Sentry did not assure the data would not be used for mailing list purposes by third parties. Sentry cross-appealed, seeking the records in their original shapefile format.The Supreme Court of Idaho reviewed the case and held that the records requested by Sentry constituted a "list of persons" and that Ada County could require Sentry to assure that the data would not be used for mailing purposes by its clients and customers. The court affirmed the district court's ruling that paragraphs 3, 4, and 6 of Ada County’s "Acknowledgment and Agreement" form went beyond the permissible inquiry under Idaho Code section 74-102(5)(b). However, the court reversed the district court's order requiring Ada County to provide the records in an electronic format, stating that the PRA does not mandate delivery in any specific format. The court concluded that Ada County was not required to produce the records because Sentry refused to certify that neither it nor its clients would use the records as a mailing list. View "Sentry Dynamics, Inc. v. Ada County" on Justia Law

A mother and father, who divorced in 2017, were involved in a contentious child custody dispute. Initially, the mother was granted primary physical custody of their two sons, with the father having visitation rights. The court ordered both parents to attend counseling and appointed a parenting coordinator to help manage their disputes. In 2021, the father sought to modify the custody arrangement, alleging that the mother had been dishonest and failed to comply with the court's orders, including attending counseling for her factitious disorder.The magistrate court held an eight-day trial and found that the mother had indeed been dishonest and had not complied with the court's orders, which negatively impacted the children. The court granted the father sole legal and physical custody of the children, with the mother having limited visitation rights. The mother was also ordered to attend counseling with a new therapist experienced in treating dishonesty.The mother appealed directly to the Idaho Supreme Court, arguing that the magistrate court's findings were not supported by substantial evidence and that the court had abused its discretion in various ways, including denying her motion to interview the children and admitting her personnel file from a previous employer.The Idaho Supreme Court affirmed the magistrate court's decision, finding that there was substantial and competent evidence to support the findings of the mother's dishonesty and its negative impact on the children. The court also held that the magistrate court did not abuse its discretion in denying the motion to interview the children, admitting the personnel file, or retaining the parenting coordinator. The Supreme Court awarded attorney fees and costs to the father, concluding that the mother's appeal was frivolous and without foundation. View "Stephens v. Buell" on Justia Law

Samuel and Peggy Edwards, residents of Rexburg, Idaho, refused to allow PacifiCorp, doing business as Rocky Mountain Power Company, to install a smart electrical meter on their property due to health concerns. Rocky Mountain considered this refusal a violation of its terms of service, which required access to electrical meter bases. After negotiations failed, Rocky Mountain informed the Edwards that their electrical service would be terminated unless they allowed the installation. The Edwards filed a formal complaint with the Idaho Public Utilities Commission (PUC), arguing they had not denied access and should be allowed to opt-out of the smart meter installation.The PUC consolidated the Edwards' complaint with similar complaints from other customers and granted Rocky Mountain's motion to dismiss, concluding that the Edwards had not provided evidence that smart meters presented a legitimate safety concern and that Rocky Mountain had the authority to access and replace meters. The Edwards' motion for reconsideration was also dismissed by the PUC, leading them to appeal to the Idaho Supreme Court.The Idaho Supreme Court reviewed whether the PUC properly determined that Rocky Mountain had the authority to access the Edwards' property to replace the existing meter with a smart meter. The Court affirmed the PUC's decision, concluding that the tariff provisions allowed Rocky Mountain to access and replace meters. The Court also found that the Edwards' constitutional arguments were waived due to insufficient support and authority. The PUC's orders dismissing the Edwards' complaint and denying reconsideration were affirmed. View "Edwards v. IPUC" on Justia Law

James and David Hart were involved in a real estate transaction with Millennial Development Partners, LLC, from 2016 to 2022. The Harts filed a complaint in September 2021 seeking a declaratory judgment that future purchases would be unenforceable. The district court set a trial date for July 12, 2022, with a backup date of October 11, 2022, and required discovery to be completed sixty days before trial. Millennial answered the complaint on June 7, 2022, asserting eleven affirmative defenses and counterclaimed for declaratory relief. The Harts' counsel requested a trial continuance due to an undisclosed conflict of interest with previous counsel. The district court continued the trial to October and ordered the Harts to file a motion and brief establishing good cause to amend the scheduling order. The Harts failed to comply with this order.The district court of the Sixth Judicial District of Idaho struck the Harts' pleadings and dismissed the case without prejudice as a sanction for failing to follow the court’s scheduling order. Millennial moved for attorney fees, which the district court awarded on two grounds: as a sanction for disobeying the scheduling order and under Idaho Code section 12-121, finding the Harts pursued the case unreasonably. The district court calculated the award considering Idaho Rule of Civil Procedure 54(e)(3) factors and awarded Millennial $9,592.46 in attorney fees and costs. The Harts moved to reconsider, arguing the district court incorrectly applied Idaho Rule of Civil Procedure 37(d)(3) and prematurely applied Idaho Code section 12-121. The district court clarified its sanction under Rule 16(e) and upheld the award.The Supreme Court of Idaho affirmed the district court’s decision, holding that the district court did not abuse its discretion in sanctioning the Harts under Idaho Rule of Civil Procedure 16(e) and awarding attorney fees under Idaho Code section 12-121. The court also affirmed the calculation of attorney fees and awarded Millennial attorney fees on appeal under Idaho Code section 12-120(3). View "Petersen v. Millennial Development Partners, LLC" on Justia Law

Sunnyside Park Utilities, Inc. (SPU) provides water and sewer services to commercial properties in Bonneville County, Idaho. Donald Sorrells, the owner of a lot in the Sunnyside Industrial & Professional Park, received a "Will Serve" letter from SPU in 2018, agreeing to provide water and sewer services based on his representation that he would install only two restrooms. However, Sorrells installed additional unauthorized water and sewer connections, leading to repeated excessive discharges into SPU's septic system. Despite multiple notices and requests for remediation from SPU, Sorrells failed to address the issues adequately, resulting in SPU seeking a declaratory judgment against him.The District Court of the Seventh Judicial District of Idaho found that Sorrells was a persistent violator of SPU's Sewer Rules and Regulations but determined that the Idaho Public Utilities Commission (IPUC) retained original jurisdiction over SPU's water system. The court denied SPU's requests for costs and attorney fees, leading to appeals from both parties.The Supreme Court of Idaho reviewed the case and affirmed the district court's judgment. The court held that the district court did not err in granting a declaratory judgment to SPU regarding Sorrells' violations of the sewer rules. However, it also upheld the district court's determination that the IPUC initially had jurisdiction over SPU's water system, as SPU had not established its nonprofit status at the time of filing. The court further affirmed the denial of attorney fees and costs to SPU, concluding that the Rules and Regulations did not expressly provide for such fees.On appeal, the Supreme Court declined to consider the merits of Sorrells' arguments due to his failure to comply with the Idaho Appellate Rules. The court also denied SPU's request for attorney fees and costs on appeal, as SPU did not prevail on its cross-appeal. View "Sunnyside Park Utilities, LLC v. Sorrells" on Justia Law

An attorney discipline case arose from allegations that Justin Oleson violated several Idaho Rules of Professional Conduct while representing Jeff Katseanes in post-divorce proceedings. Jeff's ex-wife, Judy, filed a civil complaint against him for unpaid spousal support, leading to a judgment and a motion for a Qualified Domestic Relations Order (QDRO) to access Jeff's retirement funds. Despite the district court granting the QDRO, Oleson advised Jeff to withdraw the funds, leading to further legal complications, including Jeff's contempt of court for failing to file an accounting of the funds.The Professional Conduct Board Hearing Committee found that Oleson violated Rules 1.7(a)(2), 3.4(c), and 8.4(d), recommending a public reprimand. However, they did not find clear and convincing evidence for violations of Rules 1.2(a), 1.3, 1.4, 4.1, and 8.4(c). Both the Idaho State Bar (ISB) and Oleson appealed the Committee's decision.The Idaho Supreme Court reviewed the case, affirming the Committee's findings of violations of Rules 1.7(a)(2), 3.4(c), and 8.4(d), but reversing the findings regarding Rules 1.2(a), 1.4, 4.1, and 8.4(c), determining that Oleson did violate these rules. The Court found that Oleson failed to consult with Jeff about the consequences of not filing the accounting, made misleading statements to a third party, and had a conflict of interest. The Court also concluded that Oleson’s actions were prejudicial to the administration of justice.Given the severity of the violations, Oleson's history of misconduct, and the absence of mitigating factors, the Idaho Supreme Court vacated the public reprimand and disbarred Oleson from practicing law in Idaho, effective immediately. Oleson is barred from applying for readmission for five years. His request for attorney fees was denied. View "ISB v. Oleson" on Justia Law

The plaintiffs, Kandi Terry-Smith and Roy A. Smith, Jr., filed a complaint against Mountain View Hospital (MVH) and Idaho Falls Community Hospital (IFCH) alleging medical malpractice after Kandi suffered an injury while a patient at MVH. The complaint was filed on March 11, 2022, and a second, identical complaint was filed on September 8, 2022. The first case was dismissed for inactivity, but the district court granted an extension for service of process. The process server, Tony Mares, filed an affidavit claiming he served MVH, but deficiencies were later found.In the district court, MVH moved to dismiss the second case as time-barred and the first case for insufficient service of process. The district court denied the Smiths' motion to consolidate the cases and dismissed the second case. The district court granted MVH’s motion to dismiss the first case for insufficient service of process, finding that the Smiths failed to properly serve MVH. The Smiths' subsequent motions for reconsideration, to amend the complaint, and for additional extensions were denied. The district court also denied the Smiths' I.R.C.P. 60(b) motion for relief from the order denying reconsideration and judgment.The Idaho Court of Appeals reviewed the case and affirmed the district court’s judgment. The court held that the Smiths failed to show good cause for the failure to timely serve MVH and did not exercise due diligence. The court also found no excusable neglect and determined that the Smiths' attorney's reliance on the process server’s affidavit was unreasonable. The court denied MVH’s request for attorney fees in the district court due to the lack of a cross-appeal but granted attorney fees and costs on appeal, finding the Smiths' appeal frivolous and without foundation. View "Smith v. Mountain View Hospital, LLC" on Justia Law

Crystal Lorene Limary and Shaun Patrick McLean were married in 2015 and had one child together. They moved into a house purchased by Shaun's parents in 2016, making monthly payments to them until 2019 when Shaun took out a mortgage to buy the house, using a $70,000 gift of equity from his parents as a down payment. Crystal filed for divorce, and the couple disagreed on the classification of the house, the $70,000 gift, a camper trailer, and the parenting schedule for their daughter.The magistrate court held a four-day trial, during which it extensively questioned the parties and witnesses. The court determined that the house and camper trailer were community property and that the $70,000 was a gift to both Crystal and Shaun. Shaun appealed, arguing that the magistrate court's conduct at trial was inappropriate and biased. The district court agreed, finding that the magistrate court's active participation obscured the reliability of its decision. The district court vacated the judgment and remanded the case with instructions to reassign it to a different judge.The Supreme Court of Idaho reviewed the district court's decision and affirmed it. The court held that the magistrate court abused its discretion by extensively questioning the parties and witnesses, which affected Shaun's right to a fair trial. The court concluded that the district court did not err in vacating the judgment and remanding the case for a new trial with a different magistrate judge. Neither party was awarded attorney fees on appeal, but costs were awarded to Shaun as the prevailing party. View "Limary v. McLean" on Justia Law

This case involves the termination of parental rights and an adoption proceeding. Jane Doe 1 ("Mother") and John Doe ("Father") had a child out of wedlock. Approximately eight months after the child's birth, Mother and her fiancé filed a petition to terminate Father's parental rights and allow the fiancé to adopt the child. Mother did not serve the petition on Father, and he did not participate in the proceedings. The magistrate court terminated Father's parental rights and granted the adoption. Father later filed two motions to set aside the judgment, arguing that his due process rights were violated due to lack of notice. This appeal concerns Father's second motion.The magistrate court denied Father's second motion, finding it barred by res judicata. The district court disagreed, reversed the magistrate court's order, and remanded the matter for the magistrate court to consider the motion on its merits. Mother appealed, arguing that Father's motion was barred by procedural doctrines, including res judicata and waiver.The Supreme Court of Idaho held that Father's Rule 60(b)(4) motion alleged a fundamental error that deprived him of his right to procedural due process, which in turn violated his fundamental constitutional right to raise his child. The Court concluded that the fundamental error doctrine applies to create an exception to the doctrines of res judicata and waiver. The Court affirmed the district court's decision and remanded the matter to the magistrate court to hold an evidentiary hearing to determine whether Father's Rule 60(b)(4) motion was timely and, if so, whether the termination and adoption judgment is void. The Court also awarded partial attorney fees to Father for defending against certain arguments raised by Mother on appeal. View "Doe v. Doe" on Justia Law