Justia Idaho Supreme Court Opinion Summaries

Two online fundraising companies, Snap! Mobile, Inc. ("Snap") and Vertical Raise, LLC ("Vertical Raise"), were involved in a dispute. Snap accused Vertical Raise and its CEO, Paul Landers, of poaching its sales representatives and customers, which violated non-compete and confidentiality provisions in the former sales representatives’ employment agreements with Snap. The trial court granted Snap a preliminary injunction to prevent further violations and partially ruled in Snap's favor on some claims. A jury trial on damages resulted in an award of $1,000,000 to Snap. However, the trial court increased the award to $2,310,021. Both parties appealed. The Supreme Court of Idaho affirmed the trial court's award of discretionary costs for expert witness fees but reversed the trial court’s order granting an additur or new trial. The Supreme Court ordered the trial court to enter a judgment consistent with the original jury award. The Supreme Court also reversed the trial court’s decision granting Snap a permanent injunction. In a separate contempt proceeding, the Supreme Court affirmed the contempt court's decision to dismiss contempt charges against Vertical Raise and Paul Croghan, a former Snap employee. The contempt court had determined the preliminary injunction was vague, overbroad, and unenforceable. View "Snap! Mobile v. Vertical Raise" on Justia Law

This case arises from a water rights dispute in Idaho. The McConnells sought to transfer their water rights to a new point of diversion on Lee Creek. Their upstream neighbor, Whittaker, protested the application, arguing that the new diversion would infringe upon his water rights. The Idaho Department of Water Resources (IDWR) approved the transfer, finding that it would not injure Whittaker's water rights. The IDWR used the historic confluence of two creeks to make this determination, asserting that if the confluence was above the McConnells’ diversion point, then Whittaker’s upstream water right was already subject to the McConnells’ senior water rights and the transfer wouldn't injure Whittaker's rights.On review, the district court disagreed with IDWR’s use of the historic confluence, instead favoring the modern confluence which was downstream of the McConnells' diversion point. This meant that the transfer would injure Whittaker's water rights.The Supreme Court of the State of Idaho reversed the district court's decision. The Supreme Court held that the West Springs Ditch, which altered the natural flow of the creek and created the modern confluence, was an unauthorized diversion of water. Therefore, the historic confluence should be used in the injury analysis, and the approval of the McConnells’ transfer application would not injure Whittaker’s water rights. The case was remanded for further proceedings in accordance with the Supreme Court's decision. View "Whittaker v. Idaho Department of Water Resources" on Justia Law

The Supreme Court of the State of Idaho affirmed the judgment of the District Court of the Third Judicial District of the State of Idaho, Washington County, in a medical malpractice action brought by Vivian Nipper against Dr. Lore Wootton, M.D., Dr. Robert Mairs, D.O., and the Weiser Memorial Hospital District. Nipper alleged that she was injured during the delivery of her child via a cesarean section when Dr. Wootton negligently cut her bladder, causing significant damage. Dr. Mairs was called to assist in repairing the injury, but Nipper alleged his efforts also fell below the standard of care.After a significant period of discovery, both Dr. Wootton and Dr. Mairs moved for summary judgment on the claims asserted against them. In response to each motion, Nipper moved for Rule 56(d) relief, requesting additional time to respond. The district court denied both requests for Rule 56(d) relief and granted summary judgment in favor of Dr. Wootton and Dr. Mairs.The Supreme Court affirmed the district court’s denials of Rule 56(d) relief and subsequent grants of summary judgment. The Court found that Nipper failed to provide specific reasons why she could not present essential facts to oppose the summary judgment motion within the allotted timeframes. Further, the Court concluded that Nipper failed to set forth a satisfactory explanation for why, after two years, such essential evidence was not sought earlier. View "Nipper V. Wootton" on Justia Law

In this case, the Idaho State Athletic Commission and the Idaho Division of Occupational and Professional Licenses sought a declaratory ruling that provisions of the Idaho Administrative Procedure Act (APA) requiring legislative approval of pending administrative fee rules violated the Idaho Constitution. They also sought a Writ of Mandamus directing the Office of the Administrative Rules Coordinator to publish the Athletic Commission’s 2022 administrative rules in the Idaho Administrative Code. The Idaho Supreme Court held that it had jurisdiction to consider the case, but dismissed the petition for a declaration of unconstitutionality and denied the petition for a Writ of Mandamus. The court concluded that the APA requirement for legislative approval of pending administrative rules did not violate the Idaho Constitution's separation of powers, enactment, presentment, or administrative rules provisions. In reaching this conclusion, the court emphasized that administrative rulemaking authority was a legislative delegation, not a constitutional power, and that the legislature was free to modify the process by which administrative rules were enacted. View "Idaho State Athletic Commission v. Office of the Administrative Rules Coordinator" on Justia Law

The Supreme Court of the State of Idaho held that the Director of the Idaho Department of Water Resources (IDWR) had the authority under Idaho Code section 42-237a.g. to initiate administrative proceedings to curtail the withdrawal of water from any well during any period where water to fill a water right in said well was not available. The proceedings stemmed from a district court decision involving the adjudication of water rights in the Wood River Valley during an unprecedented drought in 2021. The Director of the IDWR initiated an administrative proceeding to determine whether water was available to fill junior groundwater rights in the aquifer beneath the Bellevue Triangle. After a six-day hearing, the Director issued a Final Order that found water was unavailable to fill the junior rights because pumping from the aquifer was affecting the use of senior surface water rights. The South Valley Ground Water District and Galena Ground Water District challenged the Director's authority to initiate proceedings under Idaho Code section 42-237a.g., arguing that the Director did not comply with the prior appropriation doctrine because the Director had not formally designated an area of common groundwater supply, or determined "material injury" had been sustained by senior surface water rights holders. The Court affirmed in part and reversed in part, ruling that the Director had the authority to initiate administrative proceedings under Idaho Code section 42-237a.g. and that the Director did not violate the prior appropriation doctrine. It held that the Director had the discretion to limit or prohibit the withdrawal of groundwater from any well during any period when water was not available to fill a water right in said well, and was not required to establish an area of common groundwater supply before he is allowed to curtail groundwater pumping. The Court also held that the Director's decision to reject the proposed mitigation plan without a hearing was not properly before the Court on appeal. View "South Valley Ground Water v. Idaho Dept of Water Resources" on Justia Law

In an appeal from a property dispute in Ketchum, Idaho, the Supreme Court of the State of Idaho affirmed the lower court's judgment, in part, and vacated and remanded the case, in part, for further proceedings. The dispute arose when Trustees Glen Miller and Cynthia Anderson attempted to build a home on a lot they purchased in the Rocking Ranch No. 3 subdivision. The Rocking Ranch No. 3 Property Owners’ Association denied their application to construct the home and asserted several counterclaims to recover unpaid homeowners association (HOA) assessments. The district court granted summary judgment to the Association on Miller and Anderson’s claims and dismissed the Association’s counterclaims. On appeal, the Supreme Court of the State of Idaho affirmed the district court's dismissal of the Association’s counterclaims, concluding that the Association failed to establish its breach of contract counterclaim because it had not established two elements of the prima facie case: breach of the contract and damages resulting from the breach. The Supreme Court of the State of Idaho also vacated and remanded the district court's award of attorney fees to the Association for further proceedings, finding that the Association was not entitled to recover attorney fees for the counterclaims on which it did not prevail. View "Miller v. Rocking Ranch No. 3" on Justia Law

The Supreme Court of the State of Idaho ruled on a dispute between TCR, LLC, a developer, and Teton County. The developer had sought to record a condominium plat for a planned unit development, but the County refused to do so, arguing that the developer had not submitted final site plans, architectural designs, or landscape drawings for review. The developer filed suit, alleging breach of contract and seeking declaratory and injunctive relief to compel the County to record the condominium plat. The district court granted the developer's motion for summary judgment on its declaratory and injunctive relief claim and denied the County's motion for summary judgment on the same claim. The court also denied all motions to reconsider. The Supreme Court of Idaho affirmed the district court's decision in part, reversed in part, and remanded for further proceedings. The court held that the County's refusal to record the condominium plat violated the Idaho Condominium Property Act and that the County did not have a valid reason for its refusal. The court also found that the district court erred in granting summary judgment to the County on the developer's breach of contract claim, concluding that genuine issues of material fact remained. The case was remanded for further proceedings. View "TCR, LLC v. Teton County" on Justia Law

The Supreme Court of the State of Idaho affirmed the lower court's judgment dismissing a negligence claim filed by GSN Capital, LLC and Dave Zortman against the Shoshone City & Rural Fire District. GSN's sawmill property was destroyed by a wildfire, and they argued that the Fire District was negligent in not calling for additional aid, not deploying fire units to protect their property, and not performing a mitigation and salvage operation to save part of their property. However, the court concluded that the Fire District did not owe GSN a duty in tort for any of the challenged decisions. The court found that the Fire District did not have custody or control over GSN's property and did not owe a duty to protect individual properties within its territory. The court also held that the Fire District did not undertake any firefighting efforts for GSN until after the fire was contained, and thus did not assume a duty to GSN. View "GSN Capital, LLC v. Shoshone City & Rural Fire District" on Justia Law

In the case before the Supreme Court of Idaho, Michael W. Skehan appealed a decision affirming the Idaho Central Sex Offender Registry's ruling that he must register as a sex offender in Idaho. Skehan had been convicted of sexual abuse in the third degree in Oregon in 2001 and later moved to Idaho. He argued that the procedures used by the Registry were improper and that he should not be required to register.The court affirmed the lower court's decision, holding that Skehan failed to demonstrate that the Registry's ruling was deficient under Idaho Code section 67-5279(3). The court also found that Skehan failed to preserve several arguments for appeal, offered little rebuttal to the Registry's position, and did not provide a sufficient record to substantiate his claims on appeal.The court also held that Skehan failed to demonstrate that the Registry's consideration of other information in addition to the Oregon and Idaho statutes was arbitrary and capricious. Additionally, the court found that the Registry did not abuse its discretion by not considering whether his Oregon conviction was a misdemeanor or felony. Lastly, the court concluded that the Registry was not required to compare Skehan’s Oregon conviction to Idaho offenses that do not require registration.The Registry was awarded its reasonable attorney fees pursuant to Idaho Code section 12-117. View "Skehan v. ISP" on Justia Law

In the case before the Supreme Court of the State of Idaho, the plaintiffs, Dallen and Rachel Worthington, filed an expedited unlawful detainer action against the defendant, Carlene Crazy Thunder, for failure to pay rent. Crazy Thunder requested a jury trial, which was denied by the magistrate court. Following a bench trial, the magistrate court ruled that Crazy Thunder had unlawfully detained the Worthingtons’ property and ordered her to vacate the residence. Crazy Thunder appealed to the district court, arguing she had a right to a jury trial under Idaho’s constitution and Idaho Code section 6313. The district court agreed, concluding that section 6-311A conflicted with section 6-313, and that section 6-311A violated Article I, section 7 of the Idaho Constitution. The Worthingtons then appealed to the Supreme Court of Idaho.The Supreme Court of Idaho held that Idaho Code section 6-311A does not violate the Idaho Constitution. The court reasoned that an action for unlawful detainer is an equitable claim, and under Article I, section 7 of the Idaho Constitution, the right to trial by jury only exists for legal claims, not equitable ones. However, the court also ruled that Crazy Thunder was entitled to a jury trial on her legal claims. The court held that in wrongful detainer cases like this one, when issues of fact are presented by the pleadings, those issues must be tried by a jury, unless such a jury is waived. As such, the Supreme Court of Idaho affirmed the district court’s decision, though on different grounds. The court further ruled that Crazy Thunder, as the prevailing party on appeal, was entitled to costs, but neither party was entitled to attorney fees. View "Worthington v. Crazy Thunder" on Justia Law