Justia Idaho Supreme Court Opinion Summaries

Ponderay Police Department Officer Michael Watkins injured his knee while chasing a suspect. Because Watkins was injured during the performance of his duties as a police officer, he was eligible to receive his full base salary during the period of his disability under the Peace Officer and Detention Officer Temporary Disability Act. Rather than receive payments under the Act, Watkins accepted worker’s compensation benefits from the Idaho State Insurance Fund. Nearly a year later, Watkins filed a complaint against the City of Ponderay seeking payment of his full base salary. The Commission fashioned a remedy which required the City to pay Watkins his full base salary, but reduced that amount by the worker’s compensation payments Watkins had already received. Watkins appealed, arguing the Commission failed to follow the Act and exceeded its authority by ordering that the City receive a credit for benefits Watkins received. Finding the Commission erred in ordering the City receive a credit for the worker's compensation benefits, the Idaho Supreme Court reversed. View "Watkins v. City of Ponderay" on Justia Law

The Day family and Trust B of the Donald M. Day and Marjorie D. Day Family Trust appealed a district court’s decision to grant the Idaho Transportation Department’s (“ITD”) motion for involuntary dismissal. ITD cross-appealed, arguing that the district court erred in denying its request for attorney fees under Idaho Code section 12-120(3). In 1961, the Days learned that access to their property via public highways would be affected when the state highway converted to a controlled-access federal interstate highway, then known as Interstate 80. The Days entered into a preliminary agreement with the Idaho Department of Highways (“IDH,” predecessor to ITD) that allowed IDH to take possession of approximately nine acres of the Day Property for construction of the interstate. In 1967, the Days entered into a right-of-way contract with IDH in furtherance of the 1961 Agreement. The 1967 Contract included an agreement for IDH to provide access to a future frontage road from I-80 to the Day Property. In the 1990s, the State began construction on the Isaacs Canyon Interchange near the Day Property. The Interchange Project eliminated a portion of the original 50-foot right of way that provided access to the Day Property under the 1967 Contract. Because of this, ITD provided replacement access easements to the Day Property. These replacement access easements were located southwest of the Interstate. The Days informed ITD the family was dissatisfied with the replacement easements and did not think they afforded the Days equivalent access to what they had prior to the construction of the Interchange. The Days sold the property to Edmonds Groves Land Holdings Inc. (“Groves”) in 2005, with the purchase price secured by a mortgage held by the Day Family. Groves later defaulted in its mortgage agreement with the Days during the recession in December of 2008. As a result, ownership of the Day Property reverted to the Day Family by way of deed in lieu of foreclosure. After the Days reacquired the property, they had difficulty obtaining title insurance because of concerns that “the access easement was owned by ITD and [the Days] did not have any statement that the easement was for the benefit of the Days.” They sued alleging inverse condemnation, and breach of contract. Finding no reversible error in the district court's dismissal, the Idaho Supreme Court affirmed. View "Day v. Idaho Transportation Department" on Justia Law

Petitioners Idahoans for Open Primaries and Reclaim Idaho filed an original action to the Idaho Supreme Court, claiming that the Idaho Attorney General’s short and general ballot titles for “The Idaho Open Primaries Act” failed to comply with Idaho Code section 34-1809(2)(d) and (e). Petitioners asked the Supreme Court to declare the ballot titles deficient, certify Petitioners’ proposed short and general ballot titles to the Idaho Secretary of State, or in the alternative, retain jurisdiction of this matter and order the Attorney General to immediately prepare ballot titles consistent with Petitioners’ proposed titles and submit them to this Court for review. Petitioners also requested a writ of mandamus compelling the Secretary of State to extend the deadline for Petitioners to obtain signatures to qualify the initiative for placement on the 2024 general election ballot. After review, the Supreme Court granted certiorari review, holding that the short and general titles failed to substantially comply with Idaho Code section 34-1809. The Attorney General was ordered to provide revised, substantially compliant short and general ballot titles. The request for mandamus relief was denied. View "Idahoans for Open Primaries v. Labrador" on Justia Law

Tiffani Finco appealed a district court’s decision, acting in its appellate capacity, remanding a petition to modify child custody to the magistrate court for further proceedings. The Idaho Supreme Court dismissed the appeal because it was moot. View "Edmonson v. Finco" on Justia Law

Gregory Lowell appealed the Idaho Industrial Commission’s decision affirming the Idaho Department of Labor’s determination that Lowell was ineligible for unemployment benefits because he had been discharged for employee-related misconduct. After review, the Idaho Supreme Court affirmed the Industrial Commission’s decision because Lowell failed to provide a sufficient record or sufficient argument and authority to support his claims. View "Lowell v. Human Dynamics & Diagnostics, PLLC" on Justia Law

Petitioner-appellant John Bradbury was resident of the City of Lewiston, Idaho and was an elected member of its city council. While serving in that capacity, he filed a petition alleging nine causes of action concerning various City funds and services, including those related to water, sanitation, wastewater, city streets, the library, and the municipally-owned Bryden Canyon Golf Course. Bradbury contended the City had been collecting excessive utility fees and improperly spending municipal funds. Bradbury sought declaratory and equitable relief. He appealed when the district court dismissed most of his claims at summary judgment, and raised additional errors for appellate review. The Idaho Supreme Court determined only that the district court erred in determining that the Idaho Tort Claims Act (“ITCA”) precluded recovery on a constitutional claim seeking equitable relief. The Court determined a remand was unnecessary where Bradbury conceded he was seeking no such remedy for himself. The Court affirmed the district court in all other respects. View "Bradbury v. City of Lewiston" on Justia Law

This appeal concerned the 2008 sale of real property located in Twin Falls, Idaho owned by the partnership White, White & Lawley I (“WWLI”), which sold the Property to White X Three, LLC, for $650,000. In 2009, after White X Three acquired and then substantially renovated the Property, it began to lease the Property. At the time of the sale, Xantha White, then a minor child, and Todd White, her uncle, each held a one-half interest in the White Family Trust. The White Family Trust was a one-third partner in WWLI when it sold the Property. Todd was also a member of White X Three, placing him on both sides of the sale and purchase of the Property. Although he had a conflict of interest in the sale, Todd did not obtain court approval for the sale pursuant to Idaho Code section 68-108(b), nor did he inform Xantha or her mother, who was also Xantha’s conservator, of the sale. Xantha (now known as Xantha Darrow) and the Trustee of the Xantha J. White Trust, Larry Braga, brought suit against Todd and White X Three, asserting that, because Todd did not obtain court approval for the sale of the Property, the sale was void and the Property should be placed in a constructive trust. Both parties moved for summary judgment. The district court granted partial summary judgment in favor of Todd and White X Three, concluding that the sale of the Property was not void because Idaho Code section 68-108(b) did not apply. The district court also declined to place the Property in a constructive trust but allowed Xantha's claim of breach of a fiduciary duty to continue. Xantha thereafter moved for an Idaho Rule of Civil Procedure 54(b) certification to allow her to appeal the partial judgment rendered against her. The district court granted her request, and this appeal followed. The Idaho Supreme Court found the district court erred in determining there was no issue of material fact that Todd complied with the terms of the Trust Indenture in consenting to the sale of the Property, both in general and in terms of the sale price. Further, the Supreme Court concluded the district court erred in declining to place the Property in a constructive trust. The case was remanded for further proceedings. View "Darrow v. White" on Justia Law

Robert Houston created a trust which, after amendments, created three separate subtrusts designed to become effective following Robert’s death: a “Marital Trust,” a “Grandchildren’s Trust,” and a “Residuary Trust.” Within the Residuary Trust, Robert created two "for the benefit of" ("FBO") trusts, one for each of Robert’s children, Patricia and Richard. A clause in the FBO Richard Trust granted Richard a testamentary power of appointment to direct how Richard’s share of the Residuary Trust would be distributed if Richard predeceased Robert’s then-wife Lyn. The Marital Trust separately provided that if Richard was not alive when the Marital Trust assets were distributed, Richard’s portion of the Marital Trust would be placed in a “Grandchildren’s Trust” to benefit Richard’s two children from his first marriage (Robert and Lyn’s grandchildren) Ryan Houston and Crystal Siegler. This matter was litigated in Richard’s probate case after his death. Before the magistrate, Richard’s second wife and the personal representative of his estate, Susan Marie Houston, claimed that Richard assigned his interest in Robert’s trusts to her in Richard’s will. Ryan and Crystal argued that because their father, Richard, had not yet inherited from their grandfather’s trusts before he died, Richard could not assign those interests to Susan. The magistrate court agreed with Susan and held that Richard validly assigned his interests to her. Ryan and Crystal, as potential beneficiaries of the Grandchildren’s Trust, appealed that decision to the district court, which reversed the magistrate’s decision. Susan appealed, arguing that the district court erred by converting the intermediate appeal to a trial de novo and by concluding the magistrate court’s interpretation of Robert’s Trust was unreasonable. After its review, the Idaho Supreme Court found no reversible error in the district court's decision and affirmed. View "Houston v. Houston" on Justia Law

The Idaho Industrial Commission issued an order denying Veronica Arreola’s petition for a declaratory ruling and motion for reinstatement of compensation. Arreola brought her petition and motion against the Granite State Insurance Co. (“the Surety”), when the Surety, without an order from the Commission invoked I.C. section 72-434 to suspend Arreola’s compensation payments. In the Surety’s unilateral and private determination, suspending Arreola’s compensation payments was appropriate because the Surety had purportedly scheduled Arreola’s Independent Medical Exam (“IME”) with its physician at a “reasonable” time, and Arreola “unreasonably” failed to submit to or had obstructed the scheduled IME by not appearing. Arreola’s petition and motion disputed these private conclusions by the Surety. Arreola also maintained that only the Commission has the authority to adjudicate the underlying medical exam dispute and determine whether there is a factual basis to execute the enforcement mechanisms in Idaho Code section 72-434. The Commission denied the petition and motion, instructing Arreola to instead proceed through a complaint for relief. The Idaho Supreme Court concluded its decision in Brewer v. La Crosse Health & Rehab, 71 P.3d 458 (2003) interpreting Idaho Code section 72-434 was manifestly wrong. "Only the Commission has the authority to adjudicate medical exam disputes, and to enforce that adjudication through the enforcement mechanisms in section 72-434." In light of this, Arreola’s concern that the Surety’s unilateral execution of the enforcement mechanisms in section 72-434 also suspended her right to file a “complaint” to seek relief was now abated. Nevertheless, the Supreme Court did not affirm: given the shift in the legal landscape with Brewer overruled, the Commission’s order denying the petition and motion was vacated, and the case remanded with instructions that the Commission: (1) order payment of prospective compensation payments that might be owed until such time as the Commission determines that payments are not required under section 72-434; (2) reconsider the appropriate procedural mechanism for adjudicating the underlying factual dispute; and (3) instruct the Surety what procedural mechanism it must use to obtain an order authorizing it to lawfully suspend compensation payments. View "Arreola v. Scentsy, Inc." on Justia Law

This case stemmed from a 2019 lease by Respondents the City of Sandpoint (“the City”) to The Festival at Sandpoint (“The Festival”), a nonprofit corporation, to operate a multi-day music concert series in War Memorial Field Park. The Festival had a long-standing policy of prohibiting festival patrons from bringing weapons, including firearms, into the event. On August 9, 2019, Scott Herndon and Jeff Avery purchased tickets to the festival and attempted to enter. Avery openly carried a firearm and Herndon possessed a firearm either on his person or in a bag (the record was unclear on this point). Security personnel for the event denied entry to both. After discussions with a City police officer and the City’s attorney, who was coincidentally attending the same event in his private capacity, Herndon and Avery eventually left the music festival and received a refund for their tickets. Appellants Herndon, Avery, the Idaho Second Amendment Alliance, Inc., and the Second Amendment Foundation, Inc. subsequently sued the City and The Festival, asserting several claims, including seeking injunctive relief prohibiting the Respondents from violating the Idaho and United States Constitutions, particularly the Second Amendment and the Idaho Constitution’s provision securing the right to keep and bear arms in public for all lawful purposes. The district court ultimately granted the Respondents’ motions for summary judgment, awarded both the City and The Festival attorney fees and costs, and dismissed all the Appellants’ claims with prejudice. The issue raised on appeal was whether a private party who leased public property from a municipality may govern those who come and go from the property during the lease. The Idaho Supreme Court responded in the affirmative, and affirmed the district court's judgment. View "Herndon v. City of Sandpoint" on Justia Law