Justia Idaho Supreme Court Opinion Summaries

On August 13, 2013, the Idaho Department of Labor (IDOL) mailed two Determinations of Overpayment and an Eligibility Determination to Mitchell Kennedy at the address he had provided when filing for unemployment benefits. The Determinations informed Kennedy that he had the right to appeal, or protest, the Determinations and that the last day to do so was August 27, 2013. On August 21, 2013, Kennedy moved to a new residence. He changed his address with the U.S. Postal Service. Kennedy received the Determinations on August 24, 2013, three days before the deadline. He did not read them until either August 26 or 27. The Industrial Commission made no specific finding as to when Kennedy read the letters but did find that “Claimant did not closely review the Determination to realize the applicable appeal dates due to work and other personal priorities.” Kennedy faxed his protest to IDOL on August 29, 2013, two days after the deadline. In the transmission of that protest, Kennedy informed IDOL of his new address. The appeals examiner found that Kennedy’s request for an appeals hearing was not timely and therefore the examiner had no jurisdiction to hear Kennedy’s appeal. Kennedy appealed, and the Commission affirmed the examiner’s decision. Kennedy then requested reconsideration from the Commission. Finding that Kennedy had not presented any further argument on the relevant issues, the Commission denied the motion. Kennedy timely filed this appeal under Idaho Code section 72-1368(9) and Idaho Appellate Rules 11(d) and 14(b). But finding no reversible error in the Commission's decision, the Supreme Court affirmed. View "Kennedy v. Hagadone Hospitality Co." on Justia Law

This appeal from arose from proposed repairs and improvements to the City of Challis’ water distribution system. In 2013, the City initiated a judicial confirmation proceeding seeking approval to incur $3.2 million in debt without a public vote. The Consent of the Governed Caucus challenged the constitutionality of the City’s request based upon Article VIII, section 3 of the Idaho Constitution. The district court granted the City’s request and the Caucus appealed. Finding that the district court erred by failing to apply the legal standard for what constitutes a "necessary" expense under the Idaho Constitution, the Supreme Court reversed the district court's decision and remanded for further proceedings. View "City of Challis v. Consent of the Governed Caucus" on Justia Law

The Payette County Board of Commissioners approved a conditional rezone of a parcel of land from agricultural to industrial, subject to a development agreement, in connection with a project to build a nuclear power plant. Various parties appealed the approval to the district court. The district court upheld the Commissioners’ actions. H-Hook, LLC, a neighboring landowner, appealed the district court’s decision. Finding no reversible error, the Supreme Court affirmed. View "Burlile v. Bd of Co Commissioners, Payette" on Justia Law

This case was an appeal of a district court order awarding attorney fees to Ascorp, Inc. d/b/a Debco Construction (Debco) against the Idaho Transportation Department (ITD) in a declaratory judgment action filed by ITD to determine rights of the parties with respect to a contract for highway construction services on a project in Twin Falls. The district court dismissed the action upon Debco’s motion under Idaho Rule of Civil Procedure 12(b)(6) and awarded attorney fees to Debco under Idaho Code section 12-120(3). On appeal ITD argued that the district court erred in determining that the declaratory judgment action qualified as a dispute involving a commercial transaction required for the application of Idaho Code section 12-120(3). Finding no reversible error, the Supreme Court affirmed the district court's order. View "Idaho Transportation v. Ascorp, Inc." on Justia Law

This lawsuit arose out of a fatal helicopter crash that occurred on August 31, 2010, in Kamiah, Idaho. The Idaho Department of Fish and Game had contracted with Leading Edge Aviation, LLC, to fly two Department employees from Clarkston, Washington, to the Selway River in Idaho in order to collect data on salmon spawning. The pilot of the helicopter was Perry J. Krinitt, Jr., the son of the Plaintiff. The two Department employees were Larry Barrett and Danielle Schiff. Plaintiff filed this wrongful death action contending that the accident was caused by the negligence of the Department or its employees. Defendants moved for summary judgment, and, after briefing and argument, the district court granted the motion. Plaintiff then appealed. Because there were genuine issues of material fact regarding the liability of the Defendants, the Supreme Court vacated the judgment and reversed the order granting the motion for summary judgment. View "Krinitt v. Dept of Fish and Game" on Justia Law

In 2004 when he was sixteen years old, claimant Terence Fairchild worked for Kentucky Fried Chicken as a cook. While carrying garbage to a dumpster, he slipped on ice and fell onto a concrete barrier, striking his knees. The impact caused his knees to bleed. He went inside the building, bandaged his knees, and informed his supervisor of the accident. Claimant sought medical care. The physician diagnosed his condition as patellofemoral pain following bilateral patella contusions and prescribed knee braces, stretching exercises, Naprosyn, and ice. He saw the physician one week later and continued to suffer pain in both knees. The physician prescribed physical therapy, which failed to alleviate Claimant’s symptoms. The physician ordered an MRI of Claimant’s left knee a few weeks later. The MRI did not reveal any abnormality. After reviewing the results of the MRI with an orthopedist, the physician continued Claimant on physical therapy and anti-inflammatory medication. Approximately one month following the accident, Claimant filed a complaint seeking benefits under the Worker’s Compensation Law. Claimant sought a second, third and fourth opinions, including one from an orthopedic surgeon. These opinions spanned approximately seven years following the initial fall. In 2007, the orthopedic surgeon suspected claimant suffered a partial posterior cruciate ligament injury to his right knee and concluded that Claimant was entitled to a permanent partial impairment of 3%. In 2011, an examining physician agreed Claimant suffered a partial posterior cruciate ligament injury, but estimated the permanent partial impairment of 7%. In a 2012 hearing, the Industrial Commission found Claimant was not a credible witness based upon its observation of him during the hearing and the differences between his hearing testimony and his prior statements in depositions, interviews, and appointments with medical providers. The Commission concluded that it regarded Claimant’s testimony as suspect where it was not supported by other evidence in the record. The Commission found that Claimant had suffered a right posterior cruciate ligament injury in the accident and that as a result of that injury he had a permanent partial impairment rating of 3%. Finally, the Commission found that Claimant had failed to prove that he had a disability in excess of his impairment. Claimant filed a motion for reconsideration, which the Commission denied. Claimant then appealed. Finding no reversible error, the Supreme Court affirmed the Commission's judgment. View "Fairchild v. Kentucky Fried Chicken" on Justia Law

For many years, Idaho County had contracted for solid waste disposal services with Walco, Inc., and Simmons Sanitation Service, Inc., (Simmons Sanitation), with each entity covering a different portion of the county. In July 2012, the County entered into a contract with Simmons Sanitation for another ten-year term beginning on January 1, 2013. However, the County and Walco could not agree upon the terms of another ten-year contract commencing on January 1, 2013. Walco’s counsel informed the County that Walco would not accept the terms proposed by the County and suggested, “given the fact that this contract has not been bid for more than forty (40) years, that the contract should go out for bid.” The County decided not to solicit bids, but instead to solicit proposals for a contract to continue providing solid waste disposal services to that part of the county being served by Walco. The County Recorder received two envelopes containing responses to the request for proposals. One was from Walco and the other was from Simmons Sanitation. The proposals were opened at a public meeting of the county commissioners. Simmons Sanitation submitted a bid lower than that of Walco. A representative from Walco was at the meeting, but no representative of Simmons Sanitation attended. After the Commissioners reviewed the proposals, they had a short discussion with the representative from Walco. At the conclusion of the one meeting, the Commissioners voted to enter into contract negotiations with Simmons Sanitation. They did so, and on November 30, 2012, they entered into a contract for a ten-year term. Thereafter, Walco filed this action against the County and Simmons Sanitation, alleging a claim against the County for tortious interference with a prospective economic advantage and a claim against the County and Simmons Sanitation for misappropriation of Walco’s trade secrets. All of the parties filed motions for summary judgment. In response to the County’s motion, Walco conceded that its tortious interference claim should have been dismissed. The district court granted summary judgment to the Defendants on the claim that they had misappropriated Walco’s trade secrets, concluding that the dollar amount of Walco’s proposal did not constitute a trade secret because Walco had not taken reasonable steps under the circumstances to maintain the secrecy of that information. Walco filed a motion for reconsideration, which the district court denied after briefing and argument. Walco then appealed. Walco contended that one of the provisions in the request for proposals could reasonably be construed as indicating that the dollar amounts of the proposals would not be announced at a public meeting. The Supreme Court concluded that the district court did not err in holding that the dollar amount of Walco’s proposal did not constitute a trade secret because Walco did not make efforts that were reasonable under the circumstances to maintain the secrecy of that information. Therefore, the Court affirmed the district court's dismissal of Walco’s complaint. View "Walco, Inc v. County of Idaho" on Justia Law

The Coeur d’Alene Tribe (Tribe) petitioned the Idaho Supreme Court for a Writ of Mandamus to compel the Secretary of State to certify Senate Bill 1011 (S.B. 1011) as law. On March 30, 2015, both the Senate and the House of Representatives passed S.B. 1011 with supermajorities. S.B. 1011 had one purpose: to repeal Idaho Code section 54-2512A, a law which allowed wagering on “historical” horse races. The Tribe alleged that the Governor did not return his veto for S.B. 1011 within the five-day deadline under the Idaho Constitution. The Tribe argued that because the veto was untimely, the bill automatically became law and the Secretary of State had a non-discretionary duty to certify it as law. The Supreme Court agreed and granted the Writ. View "Coeur d'Alene Tribe v. Denney" on Justia Law

Gooding County appealed the district court’s decision reversing the Gooding County Board of Commissioners’s (BOCC) decision affirming the denial of a third-party medical indigency application. In 2013, Saint Alphonsus Regional Medical Center (Hospital) submitted a third-party medical indigency application to the Department of Health and Welfare on behalf of a patient who had been hospitalized at its facility since July 27, 2013. The County Clerk denied the application on the basis that it was untimely filed, and the BOCC affirmed. The Hospital appealed that decision to the Gooding County district court, which reversed the decision and remanded for further proceedings. Gooding County then appealed to this Court. On appeal, Gooding County argued that the district court erred when it held that the date of admission is excluded when calculating an application’s deadline under Idaho Code section 31-3505(3). Finding no reversible error, the Supreme Court affirmed. View "St. Alphonsus RMC v. Gooding County" on Justia Law

The State appealed the magistrate court's dismissal of the State's motion for contempt brought against Luis Juarez for failing to make payments ordered in a juvenile proceeding. In 2002, Juarez admitted to committing an offense that would have been a misdemeanor if he had been an adult. Much time passed and the court entered several orders directing Juarez to pay fees and restitution in varying sums. Eventually, on October 6, 2005, the magistrate court entered its Amended Financial Judgment and Order directing Juarez to pay restitution. Juarez failed to pay, and would fail to appear twice, resulting in bench warrants for his arrest being issued both times. By the second time Juarez came before the magistrate judge, he was over 26-years old, and outside of the juvenile court's jurisdiction. The court reasoned that now that Juarez had been brought in for an adult felony charge, it could no longer hear the contempt proceedings for failing to pay restitution. The district court reasoned that contempt was not available to compel payment of a restitution obligation arising from a proceeding under the JCA because the magistrate court's jurisdiction was conveyed by operation of Idaho Code section 20-505 and withdrawn by operation of Idaho Code section 20-507. The Supreme Court reversed the district court, concluding: (1) the magistrate court had jurisdiction over a charge of misdemeanor contempt under Idaho Code section 18-1801 (and if the offender was under eighteen years of age at the time of the criminal contempt, and the juvenile court exercises its discretion to treat the offense under the JCA, then Idaho Code section 20-507 would operate to terminate the juvenile court's jurisdiction as the proceedings would arise out of the JCA); (2) based on the State's own affidavit, the alleged crime was committed more than four years before these proceedings were commenced; (3) although this action was processed as a criminal case, no complaint was ever filed; (4) despite the lack of a complaint and without a finding of probable cause, the magistrate court issued warrants which resulted in Juarez's arrest; (5) the court's written "Statement of Rights and Explanation of Procedures for Contempt of Court" erroneously advised Juarez that the State bore the burden of proving the contempt "by a preponderance of the evidence;" (6) the court erroneously advised Juarez of the potential penalties upon conviction for misdemeanor contempt (18-1801 did not prescribe the penalty for misdemeanor contempt); (7) the magistrate court did not appear to recognize that Juarez had a right to a jury trial for misdemeanor contempt; and (8) Juarez appeared before the court without counsel, and Juarez discussed his case with the prosecutor without a knowing and voluntary waiver of the right to the assistance of counsel. The Supreme Court reversed the district court's decision affirming the magistrate court's order dismissing the State's motions for contempt. The case was remanded for further proceedings. View "Idaho v. Juarez" on Justia Law