Justia Idaho Supreme Court Opinion Summaries

Eagle Creek Irrigation Company (“Eagle Creek”) appealed a district court's grant of summary judgment in favor of A.C. & C.E. Investments, Inc. The dispute centered on 15 shares of Eagle Creek stock which authorized the holder to divert 30 cfs of water (or 15 miner’s inches) of Eagle Creek’s water right. AC&CE Investments purchased 15 acres (“the Property”) located within Eagle Creek’s boundaries. The prior property owners also owned 15 shares in Eagle Creek stock. The question presented on appeal was whether the 15 shares passed as an appurtenance to the Property. The district court ruled that AC&CE Investments acquired 15 shares in Eagle Creek when it acquired title to the Property because the shares passed as an appurtenance to the Property. Eagle Creek appealed. The Idaho Supreme Court determined the district court erred in granting summary judgment to AC&CE Investments because the district court did not look to Eagle Creek’s governing documents. The Supreme Court therefore vacated the portion of the district court’s final judgment which stated that the 15 shares of the Eagle Creek stock were appurtenant to the Property. View "Eagle Creek Irrigation v. A.C & C.E Investments" on Justia Law

SSI Food Services Inc. (SSI) appealed the district court’s decision rejecting the Board of Tax Appeal’s (BTA) 2016 assessed value of SSI’s food processing facility in favor of the Canyon County Assessor’s (Canyon County) significantly higher valuation. On appeal, SSI argued the district court erred when it modified the BTA’s valuation because: (1) Canyon County did not meet its burden of proving that the BTA’s valuation was erroneous; (2) the modified valuation was not supported by substantial and competent evidence; and (3) the conclusions of law contained in the district court’s findings of fact and conclusions of law are inadequate. SSI also appealed the district court’s decision to allow Canyon County’s expert to testify on rebuttal. Canyon County cross-appealed the district court’s decision that SSI was not obligated to pay penalties and interest on the unpaid amount of property taxes. Finding no reversible error or abuse of discretion, the Idaho Supreme Court affirmed the district court. View "Stender v. SSI Food Services, Inc." on Justia Law

Defendant-appellant Tom Katsilometes challenged the Idaho Senate’s order granting over $18,000 in attorney fees to Senator W. Marcus Nye, awarded after Nye prevailed against Katsilometes in a contest over the results of the 2016 general election. The Senate confirmed Nye’s election and awarded him costs and attorney fees. Because Katsilometes refused to pay the attorney fees, Nye brought an action in district court seeking a declaratory judgment ordering Katsilometes to pay him the amount ordered by the Senate. The district court granted the declaratory judgment and further awarded Nye costs, attorney fees, and prejudgment interest. The Idaho Supreme Court determined the Senate did not have the authority to award attorney fees to Nye at the time of the election contest. Nye was not entitled to recover his litigation costs, attorney fees, and prejudgment interest in the district court action. Therefore, the Idaho Supreme Court reversed the district court’s order enforcing the award of attorney fees to Nye pursuant to the order of the Idaho Senate, and vacated all costs, attorney fees, and prejudgment interest awarded to Nye by the district court. Neither side was entitled to attorney fees on appeal; however, as the prevailing party, Katsilometes was entitled to his costs on appeal. View "Nye v. Katsilometes" on Justia Law

This case arose from the division of a three-member accounting firm, Siddoway, Wadsworth & Reese, PLLC. The three members of the firm were the personal professional corporations solely owned by each accountant. In early 2015, Reese PC signed a purchase agreement to buy a one-half interest in the client base of Siddoway PC for $200,000. This purchase agreement included an arbitration clause. In August of 2015, Siddoway left the accounting firm, taking several employees and the clients’ information with him. Following Siddoway’s departure, the firm (now named Wadsworth Reese, PLLC), along with its remaining members, filed a complaint in the district court against Siddoway and his personal professional corporation and two of the employees who followed him. Siddoway counterclaimed. The parties brought a range of claims. Reese PC and Siddoway PC also went to arbitration for claims related to their purchase agreement, but the arbitrator determined the purchase agreement was void for failure of a condition subsequent. The remaining claims between the parties were tried by the district court. The district court ultimately decided to “leave the parties where it found them.” This included final determinations pertinent to this appeal: (1) dissociation of Siddoway’s personal professional corporation as a firm member; (2) Siddoway and Siddoway PC were not entitled to attorney fees for compelling arbitration; (3) Siddoway PC failed to show unjust enrichment from the void purchase agreement; and (4) the firm could fund Reese’s personal professional corporation’s litigation and arbitration costs because resolving the purchase-agreement dispute served a legitimate business purpose. Siddoway and Siddoway PC appealed. The Idaho Supreme Court affirmed the district court’s judgment: Siddoway and Siddoway PC were not entitled to attorney fees for compelling arbitration, nor did they show unjust enrichment or breach of membership duties. View "Wadsworth Reese v. Siddoway & Co" on Justia Law

Mario Ayala was injured while driving a company truck in 2009, and was injured again in 2013 after falling from a ladder. After the hearing, but before the referee issued “recommended findings and determination” in accordance with Idaho Code section 72-717, the Industrial Commission reassigned the case to itself over Ayala’s objection. Citing the referee’s backlog of cases and a need for efficiency, the Industrial Commission issued an order finding that Ayala’s low-back condition was not causally related to his 2009 truck wreck, that he was not totally and permanently disabled under the odd-lot worker doctrine, and that he suffered disability of 40% of the whole person inclusive of impairment of his 2009 and 2013 industrial accidents. The Idaho Supreme Court set aside the Commission’s findings of fact, conclusions of law and order because Ayala was denied due process when the Industrial Commission reviewed Ayala’s claims and issued a decision without the referee’s recommended findings and determination. The Court also set aside the Industrial Commission’s post-hearing order on motion for reconsideration and order on motion for reconsideration, modification and consolidation, and remanded this matter for a new hearing. View "Ayala v. Meyers Farms" on Justia Law

Jun Yu appealed the dismissal of his claims for alleged violations of 42 U.S.C. section 1983 and breach of contract. Idaho State University dismissed Yu from its doctoral program in clinical psychology in May 2013, with his final administrative appeal denied on October 2, 2013. Yu, a citizen of the People’s Republic of China, was completing his Ph.D. in clinical psychology at Idaho State University. He completed all the requisite coursework, wrote and defended his dissertation, but still had to complete a one-year clinical internship. After not matching any programs with the Association of Psychology Postdoctoral and Internship Centers, Yu set up an alternative internship with the Cleveland Clinic Center for Autism in Ohio. However, he was dismissed from the Ohio internship early due to performance concerns and subsequently dismissed from Idaho State University’s doctoral program. After exhausting his appeals with the university, Yu received a final letter on October 2 that denied his appeal and immediately made his dismissal effective. In March 2014, Yu filed a notice of tort claim against ISU pursuant to the Idaho Tort Claims Act (ITCA), alleging negligent infliction of emotional distress and a violation of Title VI of the 1964 Civil Right Act. Eighteen months later he filed a lawsuit in the U.S. District Court for the District of Idaho alleging violations of Title VI of the Civil Rights Act, deprivation of constitutional rights under 42 U.S.C. section 1983, and negligent infliction of emotional distress. Yu later amended his complaint to include allegations of denial of procedural and substantive due process, promissory estoppel, and breach of contract, totaling 18 claims against ISU. No individual defendants were named in the notice of claim or in his federal action. The Idaho Supreme Court affirmed the district court’s dismissal of Yu’s claims because they were untimely. View "Yu v. ID State University" on Justia Law

Aspen Park, Inc., a nonprofit organization, sought a property tax exemption from Bonneville County, Idaho for its low-income apartments. The County’s Board of Equalization denied an exemption because some of the apartments were leased to tenants with incomes above 60 percent of the county’s median income level, a requirement set forth in Idaho Code section 63-602GG(3)(c). Aspen Park appealed to the Idaho Board of Tax Appeals, arguing that the statute allowed vacant apartments to be leased to higher-income earners. After the Board of Tax Appeals denied tax exempt status, Aspen Park filed a petition for judicial review with the district court. The district court granted Bonneville County summary judgment after deciding that to be eligible for a tax exemption under Idaho Code section 63-602GG, every apartment must be rented to low-income individuals or remain vacant. Aspen Park appealed, but finding no reversible error, the Idaho Supreme Court affirmed. View "Aspen Park v. Bonneville County" on Justia Law

At issue in this case was whether Brent Austin filed a timely complaint for additional worker's compensation benefits with the Idaho Industrial Commission when it was filed more than a year after his employer, Bio Tech Nutrients, and its surety, Employers Compensation Insurance Company, (collectively “Defendants”) stopped paying worker’s compensation benefits. The Commission held that the one-year statute of limitations to file a complaint was tolled because the Defendants did not send a Notice of Claim Status (“NOCS”) when they submitted Austin’s final payment; as such, the Commission concluded Austin’s complaint was timely filed. After review, the Idaho Supreme Court determined the Commission was correct in tolling the statute of limitations, and affirmed. View "Austin v. Bio Tech Nutrients" on Justia Law

This appeal centered on the distribution of water to water right 95-0734 in the Twin Lakes-Rathdrum Creek Drainage Basin. Sylte Ranch, LLC, was the current claimant on water right 95- 0734, which dated from 1875 and provided natural flow stockwater from Rathdrum Creek. In September 2016, Idaho Department of Water Resources (IDWR) issued a letter of instructions to the local watermaster in response to a complaint that he was releasing storage water from Twin Lakes contrary to a 1989 Final Decree that established all existing rights to Twin Lakes’ surface waters, tributaries, and outlets. These instructions led Sylte to file a Petition for Declaratory Ruling, arguing that IDWR should set aside and reverse the instructions because they improperly limited water right 95-0734 to Twin Lakes’ natural tributary inflow. Twin Lakes Improvement Association, et al., and Twin Lakes Flood Control District intervened in the case. Following cross motions for summary judgment, IDWR issued a Final Order, in which it upheld the instructions and granted intervenors’ motion for summary judgment. Sylte then sought judicial review and the district court affirmed IDWR’s Final Order. Sylte timely appealed to the Idaho Supreme Court. The Supreme Court affirmed the district court’s determination to uphold IDWR’s Final Order because the instructions complied with the plain language of the 1989 Final Decree. View "Sylte v. IDWR" on Justia Law

This case involved a dispute over how the Idaho Public Employee Retirement Board calculated the annual cost of living adjustment (COLA) for retirees who participated in the Firemen’s Retirement Fund (FRF). The Idaho Industrial Commission held that the definition of “paid firefighter” included part-time firefighters. The effect of the Commission’s decision resulted in a smaller annual COLA for retired firefighters. On appeal, the Idaho Retired Firefighters Association, and Sharon Koelling and John Anderson alleged the Board’s inclusion of part-time firefighters violated statutory and constitutional provisions. The Association and the Individual Claimants sought a ruling from the Idaho Supreme Court reversing the Commission’s decision, and a ruling that would exclude part-time firefighters from the Board’s annual COLA calculations, the effect of which would be an increase in the annual COLA applicable to retired firefighters. The Supreme Court vacated the Commission’s decision because it lacked the necessary jurisdiction to decide the question presented to it. View "Idaho Retired Firefighters v. Public Employy Retirement Bd" on Justia Law