Justia Idaho Supreme Court Opinion Summaries

The Jefferson County, Idaho Board of Commissioners (“the County”) granted Appellant Tina Gilgen a conditional use permit that allowed her to place a mobile home on real property she owned with her husband, Kelly Gilgen. The Gilgen property fell within the City of Ririe’s area of impact (“AOI”). The City of Ririe (“the City”) petitioned for judicial review, claiming the County erroneously approved Gilgen’s application by applying Jefferson County zoning ordinances within the AOI instead of City ordinances, which would have resulted in a denial of Gilgen’s application. The City relied on an area of impact agreement between Jefferson County and the City of Ririe, in which the County specifically agreed to apply the City’s ordinances to property located within the AOI (“AOI Agreement”). After the County filed a notice of non-objection, the district court entered an order granting the City’s petition, reversing the County’s original decision, and remanding the matter to the County. On remand, the County issued an amended decision that denied Gilgen’s application for a conditional use permit. Several months later, Gilgen filed three motions for reconsideration of the district court’s order remanding the case, alleging the district court did not have jurisdiction to consider the City’s petition. Each of the motions was denied. The Idaho Supreme Court determined the City did not have standing to petition the district court for review of the County’s decision. The trial court’s judgment was vacated. View "City of Ririe v. Gilgen" on Justia Law

John Doe (Father) appealed a magistrate court’s decision to terminate his parental rights to his three children: John Doe I (age 12), Jane Doe (age 11), and John Doe II (age 7). The children and their biological mother (Mother) lived in Idaho when the Idaho Department of Health and Welfare (the Department) petitioned to terminate Mother’s parental rights. Mother eventually voluntarily stipulated to the termination of her rights. Father resided in Tennessee during these proceedings and could not be located by the Department for several months. The Department amended its original petition in Idaho to establish jurisdiction over Father. The Department then moved to obtain authorization to serve the petition on Father by publication in the Tennessee city where Father resided. The magistrate court granted the Department’s request. Ultimately, Father was located in Tennessee and accepted personal service. The Department then filed petitioned to terminate his parental rights. Father participated in the termination trial via Zoom from Tennessee. Throughout the proceeding, Father’s internet connection proved to be unreliable, and he was repeatedly disconnected from the proceeding. Father rejoined the proceeding when the connection was reestablished. Father moved to continue the trial because of the connectivity issue, which the magistrate court denied, noting that it had given the parties the option of joining the proceedings remotely, but that they were required to ensure they had a reliable internet connection. Following the trial, the magistrate court terminated Father’s parental rights based on the grounds of abandonment, neglect, and the inability to discharge parental responsibilities. Father appealed. Finding no reversible error in the magistrate court's judgment, the Idaho Supreme Court affirmed it. View "IDHW v. John Doe" on Justia Law

Black Diamond Compost, LLC (“Black Diamond”), filed a “Claim of Ownership” with the Ada County, Idaho Recorder’s Office to notify the public of its ownership of compost and humus located on real property in Ada County. Black Diamond disputed the ownership of the land and deemed it necessary to notify the public that the compost and humus located on the real property belonged to it. Ford Elsaesser, personal representative of the Estate of Victoria Smith, attempted to sell the real property but could not secure “clear title” in a preliminary title report and claimed this was due to Black Diamond’s Claim of Ownership. Elsaesser filed an action against Black Diamond, alleging the Claim of Ownership was a nonconsensual common law lien prohibited under Idaho Code section 45-811. The court agreed and ordered the release and discharge of the recorded Claim of Ownership. It also awarded Elsaesser a $5,000 civil penalty and granted his request for costs and attorney fees. The Idaho Supreme Court affirmed the district court, holding it did not err in: (1) determining the Claim of Ownership to be a prohibited nonconsensual common law lien; (2) ordering the lien to be released and discharged; (3) imposing a $5,000 civil penalty against Black Diamond; and (4) awarding attorney fees to the Personal Representative pursuant to Idaho Code section 45-811(4). View "Elsaesser v. Black Diamond Compost, LLC" on Justia Law

This appeal arose from an action in which the personal representative of the Estate of Victoria Smith (the “Personal Representative”) sought to eject Riverside Farms, LLC, (“Riverside”) from its real property, referred to by the parties as the “Chinden Property,” after the term of Riverside’s lease expired. Riverside argued that the Personal Representative lacked standing to bring the ejectment action because it was not the true owner of the land. The Personal Representative was earlier granted ownership of the “Chinden Property” pursuant to a Rule 70(b) judgment issued during the probate proceedings following Victoria’s death. Riverside argued that the Rule 70(b) judgment was barred by res judicata because a prior action, which concerned removal of trees along an easement on the property, had already confirmed that the Personal Representative was not the true owner of the Chinden Property. The district court determined that ejectment of Riverside was proper because the dismissal of the prior case did not preclude the Rule 70(b) judgment issued in the probate case. Riverside filed a motion asking the district court to reconsider its decision, but the district court declined to do so. Riverside appealed to the Idaho Supreme Court, arguing that the denial of its motion to reconsider was in error and renewing its argument that the personal representative lacked standing to seek removal of Riverside from the property because the Rule 70(b) judgment was barred by res judicata. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgment. View "Elsaesser v. Riverside Farms, Inc." on Justia Law

This appeal arose from conflicting interpretations of the statutory provisions that govern the Public Employee Retirement System of Idaho (“PERSI”) and the administration of employer contributions to the Firefighters’ Retirement Fund (“FRF”). Under Idaho Code sections 59-1391 and 59-1394, a city or fire district that “employs” firefighters participating in the FRF on October 1, 1980, was considered an “employer” and required to make additional contributions to ensure the FRF remains solvent. Having employed only a single firefighter who received funds from the FRF, Kuna Rural Fire District (“KRFD”) argued it was not an employer under the code and not required to contribute to the fund because that employee retired in 1985 and received a lump-sum benefit. KRFD notified PERSI of its intent to cease contributions, but PERSI denied this request. KRFD filed a notice of appeal to the PERSI Retirement Board (“Board”). A hearing officer issued a recommended decision concluding KRFD had to continue contributing under section 59-1394. The Board adopted this decision. KRFD petitioned for judicial review under the Idaho Administrative Procedure Act (“IDAPA”) with the district court, which affirmed the Board’s decision. KRFD timely appealed to the Idaho Supreme Court. Finding no error, the Supreme Court also affirmed the Board's decision. View "Kuna Rural Fire District v. PERSI" on Justia Law

In 2017, Appellant Shoshone County assessed properties owned by Respondents S&W OPS, LLC; POWDER, LLC; H2O, LLC; GOLF, LLC; APARTMENT, LLC; F&B, LLC; and VILLAGE MANAGEMENT, LLC (collectively “Taxpayers”). Taxpayers disputed the valuation and sought review by the Board of Equalization, and subsequently the Board of Tax Appeals (“BTA”). The BTA reduced the assessed value, and the County appealed to the district court. After a four-day bench trial, the district court upheld the BTA decision, determining that the County’s appraisal evidence was more credible than Taxpayers’ evidence; however, the district court ultimately held the County had not satisfied its burden of showing how the BTA decision was erroneous by a preponderance of the evidence. The County appealed to the Idaho Supreme Court, arguing that the district court applied the wrong standard of review by requiring the County to prove “how or why” the BTA decision was erroneous instead of simply concluding that the market value of the property was different than what was found by the BTA. After review, the Supreme Court agreed with the County’s position. The district court’s decision was reversed, the judgment was vacated, and the case was remanded with instructions for the district court to consider whether the BTA’s decision on valuation was erroneous given the evidence submitted during the de novo trial. If that decision on valuation was erroneous, the district court, as the fact-finder, had to set the valuation. View "Shoshone County v. S&W OPS, LLC" on Justia Law

Patricia Allen appealed the Idaho Industrial Commission’s (the “Commission”) decision denying unemployment benefits. Allen was employed by Partners in Healthcare, Inc., doing business as North Canyon Medical Center (“NCMC”), between February 5, 1999, and May 8, 2020. On May 8, 2020, the CEO of NCMC and the HR director met with Allen to discuss her job performance. Allen was presented with a performance improvement plan (“PIP”), which outlined examples of Allen’s poor job performance and identified expectations for improving her performance. It was explained to Allen that if she wanted to forego the PIP, she could sign a severance agreement. Allen was then presented with a proposed severance agreement. Allen asked if she could discuss her options with her husband, but was pressed to make her decision then and there. The CEO told Allen that he thought it was in her best interest to take the severance package. Allen decided to forgo the PIP and took the severance agreement. After separating from NCMC, Allen filed an unemployment claim with the Idaho Department of Labor (“IDOL”). NCMC’s response to the Idaho Department of Labor was prepared by the Idaho Hospital Association (“IHA”), NCMC’s third-party administrator. IHA’s human resources director identified Allen’s reason for separation as “Fired/Discharged” and indicated Allen did not receive any compensation after her separation. IDOL determined Allen was eligible for unemployment benefits. NCMC’s HR director appealed the IDOL decision; IDOL sent NCMC and Allen a hearing notice on whether Allen quit voluntarily and, if so, whether she quit for good cause or was discharged for misconduct in connection with her employment. Following the hearing, the appeals examiner issued a written decision that denied Allen unemployment benefits. The examiner also found that Allen did not follow the grievance procedures to report her issues with her supervisor prior to quitting. In reversing the Commission’s decision, the Idaho Supreme Court concluded the Commission erred in failing to analyze whether the PIP was a viable option that would have allowed Allen to continue working. The matter was remanded for further proceedings. View "Allen v. Partners in Healthcare, Inc." on Justia Law

This appeal arose from the dismissal of a stepfather’s petition for custody and support of a child filed three years after the stepfather and mother divorced. The stepfather based his petition on the underlying divorce and the Idaho Supreme Court’s decision in Stockwell v. Stockwell, 775 P.2d 611 (1989). The magistrate court ultimately dismissed the stepfather’s petition for failure to state a claim upon which relief could be granted, reasoning that the stepfather, who never adopted the child, had brought a common law custody claim under Stockwell, which was specifically prohibited in Doe v. Doe, 395 P.3d 1287 (2017). The Idaho Supreme Court agreed with the magistrate court’s decision and affirmed the judgment of dismissal. View "Glatte v. Hernandez" on Justia Law

Petitioner-appellant Melvin Savage was convicted of first-degree arson. He filed a post-conviction petition alleging his trial counsel was ineffective for failing to advise him of his right against self-incrimination during a deposition that took place in a civil lawsuit involving the arson allegation. Following an evidentiary hearing, the district court found that counsel’s failure to advise Savage of his right to remain silent constituted deficient performance; however, Savage failed to prove he was prejudiced by that deficient performance because he was already intent on resolving his criminal case by entering a guilty plea at the time of the civil deposition. Savage unsuccessfully moved for reconsideration. Appealing to the Idaho Supreme Court Savage argued the district court erred by limiting its prejudice analysis to an evaluation of whether Savage would have gone to trial instead of considering whether Savage demonstrated that the outcome of the plea process would have been different with competent advice. Finding no reversible error, the Supreme Court affirmed the district court. View "Savage v. Idaho" on Justia Law

Daniel Sharp suffered an injury to his lower back from an accident at work in 2015. After surgery, he was repeatedly advised to lose weight by the medical providers treating his injury. However, Sharp gained considerable weight instead. The Industrial Commission found that Sharp’s functional ability had diminished between 2016, when he reached maximal medical improvement (MMI) after surgery, and 2019, when his permanent disability hearing was held. The Commission attributed the worsening of Sharp’s condition to his weight gain, which it held to be a superseding cause of any increase in Sharp’s disability post-MMI. Accordingly, the Commission evaluated Sharp’s disability based on his condition at MMI, despite the Idaho Supreme Court's opinion in Brown v. Home Depot, 272 P.3d 577 (2012), requiring that a claimant’s disability be evaluated based on circumstances at time of the hearing. After review in this case, the Supreme Court held that the Commission erred by departing from "Brown," by applying an incorrect standard to determine that Sharp was not entitled to compensation due to the aggravation of his injury, and by reaching certain factual conclusions not supported by substantial and competent evidence. Therefore, the Commission’s decision was vacated and the matter remanded for further proceedings. View "Sharp v. Thomas Bros Plumbing" on Justia Law