Justia Idaho Supreme Court Opinion Summaries

The Idaho Ground Water Appropriators, Inc. (“IGWA”) and the City of Pocatello filed separate appeals to a district court order, affirming in part and vacating in part an order issued by the Director of the Idaho Department of Water Resources (“IDWR”) that curtailed junior ground water pumping in the Eastern Snake Plains Aquifer (“ESPA”). In late 2011, Rangen, Inc. petitioned for a delivery call, alleging that junior ground water pumping in the ESPA was materially injuring its water rights sourced from the Martin-Curren Tunnel. The Director held an evidentiary hearing in the Spring of 2013. As relevant to these appeals, the Director concluded: (1) that the Martin-Curren Tunnel was a surface water source and, therefore, not subject to the Ground Water Act; (2) ground water pumping in the ESPA was materially injuring Rangen’s water rights and that a curtailment order was appropriate; (3) however, the benefits of curtailment diminished significantly if the order extended to pumping east of a volcanic rift zone in the ESPA known as the Great Rift. The Director issued a curtailment order on January 24, 2014, mandating that ground water users located west of the Great Rift, with water rights junior to Rangen’s, refrain from diverting water from the ESPA. Rangen and IGWA petitioned for judicial review of the Director’s decision. The district court upheld the Director’s decision in significant part but vacated the Director’s application of a trim line at the Great Rift, concluding that the Director did not have a legal basis to apply a trim line in this case. Rangen, IGWA, and Pocatello each appealed. After review, the Idaho Supreme Court affirmed the decision of the district court, save and except for the district court’s vacation of the Great Rift trim line, which was reversed. View "Idaho Ground Water Appropriators v. Dept of Water Resources" on Justia Law

Plaintiff-appellant Patricia McKay appealed the grant of summary judgment in favor of Thomas Walker and Cosho Humphrey, LLP, in a legal malpractice action. McKay contended that Walker negligently drafted a property settlement agreement by failing to include provisions that would have resulted in a judgment lien against payments owed to her husband which were secured by a mortgage. The district court concluded that because a mortgage was personal property and not real property, the failure to include a description of the real property subject to the mortgage and the mortgage’s instrument number would not have resulted in the creation of a security interest. Based upon this legal conclusion, the district court held that Walker had not breached a duty to McKay and the alleged breach was not the proximate cause of any damages. McKay argued the district court erred in its conclusion. Finding no reversible error, the Supreme Court affirmed. View "McKay v. Walker" on Justia Law

Robert Mena was licensed to practice medicine and surgery in Idaho in 2003. In 2007, staff members at the hospital in Jerome where he had privileges reported behaviors that suggested to them that Dr. Mena might have been abusing drugs or alcohol. Dr. Mena was evaluated and tested negative for chemical dependency. But staff, still concerned about Dr. Mena's psychological status, opined that he was not then currently fit to practice medicine. After further evaluation, it was recommended that Dr. Mena curtail his work-weeks to 40 to 50 hours. The Idaho State Board of Medicine ("Board") also had begun an investigation regarding Dr. Mena's training and ability to perform certain medical procedures. The Board and Dr. Mena entered into a Stipulation and Order in 2009, in which he admitted that he had violated the Medical Practice Act by failing to provide health care that met the required standard and in which he agreed to specific conditions of probation and restrictions on his license to practice medicine. On September 26, 2011, the Board issued an order terminating the Stipulation and Order. That same day, the hospital in Jerome gave Dr. Mena written notification that it had granted him limited medical privileges on the condition that he obtain additional training, that he had failed to do so, and that his privileges were forfeited. A month later, the Board sent Dr. Mena a letter asking him to respond to the hospital's action. He eventually submitted a thirteen-page written response that was rambling with many obscure references, grammatical and syntax errors, and vague sentences. More evaluations were ordered. The Board issued its Final Order in early 2014, finding that Dr. Mena suffered from "some level of impairment," and it stated that "sanctions were necessary upon [Dr. Mena's] license." Dr. Mena filed a petition for judicial review to the district court, arguing: (1) the Board initiated proceedings pursuant to the Disabled Physician Act and then imposed sanctions that were not permitted by that Act; (2) the Board's order was not supported by substantial evidence; and (3) the hearing officer erred in holding that certain evidence was inadmissible. The district court upheld the Board's action, and Dr. Mena then appealed to the Idaho Supreme Court. The Supreme Court reversed and remanded, finding that Board's own evaluation of the evidence showed that there was insufficient evidence to support the Board's order. View "Mena v. Idaho Bd. of Medicine" on Justia Law

Appellant-State charged respondent Jamie Lynn Pachosa with felony possession of a controlled substance, possession of paraphernalia, and providing false information to a law enforcement officer. Before the trial, Pachosa moved to suppress all evidence against her, arguing that the officers in the case violated her Fourth Amendment rights by seizing her for an investigatory detention without the required reasonable suspicion. The district court granted Pachosa’s motion to suppress all evidence gathered against her. The State appealed that decision. After review, the Supreme Court concluded the district court erred in interpreting the controlling case law of this matter, and as such, erred in finding there was no reasonable suspicion to detain Pachosa. Therefore, the district court’s order granting Pachosa’s motion to suppress all evidence gathered against her was vacated and the case was remanded for further proceedings. View "Idaho v. Pachosa" on Justia Law

Plaintiffs-appellants Charles and Janice Lepper filed a medical malpractice suit against defendants Eastern Idaho Health Service, Inc. d/b/a Eastern Idaho Regional Medical Center (EIRMC) and Dr. Stephen R. Marano, (Dr. Marano). The Leppers alleged Dr. Marano rendered Charles a paraplegic. The Leppers appealed a district court's grant of summary judgment to defendants, arguing that the trial court erred in ruling that based on the language of its Scheduling Order, the Leppers’ expert witness disclosures required disclosure of all expert witness opinions, including foundational facts required by statute. After review, the Idaho Supreme Court vacated and remanded."We decline to hold the Leppers to a higher disclosure standard than what was required by the plain language of the Scheduling Order. Again, the district court was free to issue a more detailed scheduling order explicitly requiring such foundational facts, but without doing so, the Leppers could not be held to more demanding disclosure requirements that they had no prior notice of. We note that the supplemental affidavits in this case detailing the applicable standard of care for both experts were provided well before the discovery deadline. In any event, we hold that because the district court read requirements into its Scheduling Order that did not appear on the face of the order, the court abused its discretion in excluding [The Leppers'] experts." Because the district court's decision regarding the experts carried through and was the basis of the denial of the Leppers' motions for reconsideration, the Court determined the district court abused its discretion in those decisions too. View "Lepper v. Eastern Idaho Health Services" on Justia Law

Appellant Bradley Morgan appealed declaratory judgment determining where to measure the sixteen-foot width of an easement held by Respondent New Sweden Irrigation District, which bordered an irrigation canal that ran the length of a piece of appellant's property. Appellant did not dispute the existence of New Sweden’s easement, but rather argued that: (1) the district court erred by denying appellant's request for a jury trial; (2) the district court abused its discretion by refusing to admit new evidence at trial; (3) the district court erred by failing to incorporate the holdings of a previous judgment identifying the boundaries of the easement, the access points to the easement, the encroachments on the easement, and the party responsible for removing those encroachments; and (4) the district court erred by failing to limit the removal of encroachments and the uses of the easement to that which was reasonable. Finding no reversible error in the district court's decision, the Supreme Court affirmed. View "Morgan v. New Sweden Irrigation Dist" on Justia Law

Appellants Thomas Strong and Brian Hawk appealed a district court's order dismissing their case pursuant to Idaho Rule of Civil Procedure 41(b) for failing to prosecute, and 40(c) for unjustified inaction for over six months. The case arose out of neuron simulator implant procedures, in which both appellant alleged he received an inappropriate amount of anesthesia from respondents, causing complications after the surgeries. Initially, in 2006, appellants commenced their claims by filing a prelitigation screening with the State Board of Medicine. Several months later, Hawk filed for bankruptcy. The district court stayed the medical malpractice claim until the bankruptcy proceedings had concluded. In 2007, respondents sent appellate counsel a stipulation to bifurcate the case so that Strong's case could proceed. Appellants' counsel did not agree to the bifurcation. Hawk's bankruptcy case closed in 2008. In 2010, respondents moved to lift the stay and dismiss the case for failure to prosecute. Appellants noted that Hawk had not disclosed the present underlying cause of action during his bankruptcy proceedings. The district court granted Appellants sixty days to rectify the bankruptcy matters. Appellants then requested the bankruptcy court to reopen the case and the district court again stayed its proceedings pending the resolution of the disclosure issue in the bankruptcy schedules. In 2013, the bankruptcy trustee ultimately determined that the action was of no value to the bankruptcy estate and reclosed the case. In 2014, respondents filed a renewed motion to dismiss, which was ultimately granted. Because there was no showing of actual demonstrated prejudice, the district court’s dismissal under Rule 41(b) was reversed, but the dismissal under Rule 40(c) was affirmed. View "Strong v. Intermountain Anesthesia" on Justia Law

In 2010, Gerald Durk Simpson shot Ryan Mitchell in the back outside of a coffee shop in Pocatello. Prior to the shooting, Simpson had been receiving mental health services from the Idaho Department of Health and Welfare’s Adult Mental Health program. In fact, Simpson had been receiving services from the Idaho Department of Health and Welfare (IDHW) for most of his adult life. In June of that year, IDHW sent a letter to Simpson informing him that he was being released from its program. The shooting occurred a little over three months after Simpson was released from IDHW’s care and custody. The Bannock County Prosecuting Attorney’s Office filed a charge of Aggravated Battery against Simpson with notice that the State would seek an enhancement penalty for the use of a deadly weapon in the commission of a crime. Approximately ten days after the shooting, psychologist Daniel Traughber, Ph.D., prepared a memorandum on behalf of the IDHW, explaining the processes and procedures that were used to implement the budget cuts so that patient mental health services would be terminated in a way that “reduced the risk of harm to patients and/or the community.” Mitchell appealed a district court order granting summary judgment in favor of the State after he brought suit alleging the State violated his constitutional and statutory victims’ rights and that the State was negligent when it discontinued Simpson’s services. Mitchell sought declaratory and injunctive relief for his victims’ rights claim and sought damages for his negligence claim. Mitchell argued: (1) the Idaho Tort Claims Act (ITCA) did not shield the State from liability for its decision to discontinue mental health services for Simpson; and (2) the victims’ rights laws provided a private cause of action for declaratory and injunctive relief against a state agency. After review, the Idaho Supreme Court concluded the district court erred in granting summary judgment on Mitchell's negligence claim: " It is clear that the complaint alleges that when IDHW made the decision to close Simpson’s file, it negligently followed, or failed to follow, procedures that were put into place to determine whether a client’s file should be closed. The evidence does not indicate who made the decision to close Simpson’s file in particular or how that decision was made." The Court reversed with respect to the negligence claim, affirmed in all other respects, and remanded the case for further proceedings. View "Mitchell v. Idaho" on Justia Law

This case involved a second set of appeals arising from an action challenging the bidding process for the Idaho Education Network (“IEN”). Syringa Networks, LLC, sued Qwest Communications, LLC, ENA Services, LLC, and the Idaho Department of Administration (“DOA”) and certain DOA employees, alleging injury arising from contract awards and amendments that DOA issued to Qwest and ENA related to the IEN. The district court dismissed all of Syringa’s claims. On appeal the Idaho Supreme Court held that Syringa had standing to pursue Count Three, which alleged that DOA violated Idaho Code section 67-5718A. Count Three was remanded to the district court for further proceedings. On remand, the district court entered partial summary judgment for Syringa on Count Three, holding that the amendments and the underlying contracts were void for violating state procurement law. The district court denied Syringa’s motion to order DOA to demand repayment of money advanced under the void contracts. The district court also awarded Syringa attorney fees. Syringa, Qwest, ENA, and DOA each appealed: Syringa appealed the district court’s denial of its request to order DOA to demand repayment from Qwest and ENA; the other parties appealed the district court’s grant of partial summary judgment to Syringa, arguing that the district court’s conclusions were procedurally improper and substantively incorrect for a variety of reasons. DOA also challenges the district court’s award of attorney fees to Syringa. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Syringa Networks v. Dept of Administration" on Justia Law

Appellant Rangen, Inc., filed a petition before the Director of the Idaho Department of Water Resources, alleging that junior ground water pumping in the Eastern Snake Plains Aquifer was materially injuring its water rights. The Director issued an order granting Rangen a curtailment of certain junior priority ground water pumping affecting Rangen’s water rights. The Director also interpreted the source and point of diversion elements of Rangen’s water rights to have a scope smaller than Rangen’s actual historical use. Rangen and intervenor Idaho Ground Water Appropriators, Inc. (“IGWA”) each filed petitions for judicial review. The issues raised by IGWA in its petition for judicial review were not at issue here; rather Rangen raised various issues related to the interpretation of its water rights and the sufficiency of the evidence before the agency. Specifically, Rangen appealed the Director’s determinations that Rangen could divert water only from the mouth of the Martin-Curren Tunnel and only within the ten-acre tract listed on its water right partial decrees. Rangen also appealed the Director’s adoption of an adverse expert’s analysis and the Director’s conclusion that junior priority ground water users are using water efficiently and without waste. The district court affirmed the Director’s orders, and Rangen appealed to the Idaho Supreme Court on substantially the same issues with substantially the same arguments. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Rangen, Inc. v. Idaho Dept of Water Resources" on Justia Law