Justia Idaho Supreme Court Opinion Summaries

Thomas and Rebecca Arnold appealed the grant of summary judgment in favor of the City of Stanley. In 2012, the City provided notice to the Arnolds (and other interested parties) of the date and time for three public hearings and a regular city council meeting, all scheduled to take place on August 9, 2012. The first of the three public hearings was noticed to begin at 5:00 p.m. and was for the purpose of receiving public comment on proposed Ordinance 189, the ordinance that the Arnolds alleged affected their property rights. The second and third hearings were noticed to begin at 5:15 p.m. and 5:30 p.m., respectively (and were for the purpose of public comment on matters not at issue here). The regular city council meeting was noticed to begin at 6:00 p.m. The first two meetings were held at their scheduled times. The third meeting began five minutes early, at 5:25 p.m., and concluded at 5:29 p.m. The regular city council meeting, scheduled to begin at 6:00 p.m., commenced at 5:31 p.m. and adjourned at 6:55 p.m. Prior to the start of the 6:00 p.m. meeting, the City did not amend the notices it had provided or otherwise notify the public that the meetings would begin earlier than scheduled. The early start time of the 6:00 p.m. meeting and the City's failure to provide amended notice of the earlier start time were the issues presented in this appeal to the Supreme Court: it was at the 6:00 p.m. meeting that the mayor and city council deliberated toward a decision on Ordinance 189, eventually voting to adopt the ordinance. Although the Arnolds were fully aware of the agenda items to be discussed at the various meetings, at no time from the outset of the first meeting at 5:03 p.m. until the final meeting adjourned at 6:55 p.m. did they attend the meeting; the Arnolds conceded at oral argument that they had no intention of attending the meeting. Following adoption of Ordinance 189, the Arnolds filed an action against the City under Idaho Code section 67-2347(6), seeking to have the ordinance declared null and void because the City held the 6:00 p.m. meeting in violation of Idaho's open meeting law by starting the meeting early and failing to provide notice of the earlier start time. The district court held the Arnolds lacked standing to bring an enforcement action because the plain language of Section 67-2347(6) allows standing for such an action only to one who is actually affected by a violation of the open meeting law, instead of being affected only by a substantive action taken at the meeting. The court granted the City's motion for summary judgment on this basis. The Arnolds appealed. The Supreme Court affirmed the district court: because a plain reading of the statute contradicted the Arnolds' argument, and because they did not even claim to have been actually harmed by the 6:00 p.m. meeting's early start time, the Court found that their appeal was brought without a reasonable basis in fact or law. View "Arnold v. City of Stanley" on Justia Law

The Nampa Education Association was the local education organization representing teachers within Nampa School District No. 131 for the 2012-13 school year. The Association and the School District attempted unsuccessfully to negotiate the terms of a master employment contract for teachers in the School District. As a result, each teacher was given a contract in a form approved by the state superintendent of public instruction, which stated an amount of compensation for the teacher's services that was the last best offer by the School District. The teachers signed their contracts and began teaching pursuant to them in the fall of 2012. The School District later faced a budget shortfall. The District offered an addendum to the standard teachers' contract by which a teacher could agree to contribute one to four specified furlough days to the District. The addendum also provided that no reduction would be made for any benefits available or accruing for or on behalf of the teacher. Approximately 500 certified teachers signed an addendum to his or her standard contract, volunteering to donate one or more furlough days. After the addenda were signed, about 24 of those teachers later modified his or her respective addendum to increase or reduce the number of days being donated. On March 25, 2013, the Association filed this action seeking a declaratory judgment that the addendum contracts were unlawful and unenforceable. The District moved for summary judgment on the grounds that the Association lacked standing, the issues were moot, and they were not ripe for adjudication. The Association also moved for summary judgment on the ground that the addenda to the teachers' contracts were illegal because they had not been approved by the state superintendent of public instruction as required by Idaho Code section 33-513 and IDAPA 08.02.01.150. The district court granted the Association's motion for summary judgment and denied the School District's motion for summary judgment. The court held that the Association had standing and the issue was not moot. On the merits, the court held that the addenda modified the terms of the teachers' contracts in violation of Idaho Code section 33-513 because the addenda had not been approved by the state superintendent of public instruction. The court also held that the School District negotiating directly with the teachers to modify the terms of their contracts violated the statutory procedures for negotiating the teachers' compensation. The court entered a judgment declaring that the addenda were unlawful and unenforceable, and the School District appealed. Finding no reversible error, the Supreme Court affirmed. View "Nampa Education Association v. Nampa School District No. 131" on Justia Law

William Wolfe appealed the Idaho County district court’s decisions denying: (1) his motion for a hearing on his motion for reconsideration of his I.C.R. 35 motion to correct an illegal sentence; and (2) his successive Rule 35 motion to correct an illegal sentence. Specifically, Wolfe argued the district court denied his motions based on two erroneous conclusions: that the subject matter jurisdiction issue had been previously adjudicated and that Wolfe could not file a successive Rule 35 motion. Wolfe argued that if the district court had properly considered the merits of his motions, the district court would have found it lacked subject matter jurisdiction over Wolfe’s original criminal proceedings. Accordingly, Wolfe petitioned the Supreme Court to vacate his judgment of conviction and sentence, or alternatively, to remand the case for an evidentiary hearing. After careful consideration of the district court record, the Supreme Court found no reversible errors, and affirmed the district court’s decisions denying Wolfe’s motion for a hearing and his successive Rule 35 motion. View "Idaho v. Wolfe" on Justia Law

HJ Grathol ("Grathol") appealed a district court judgment awarding Grathol $675,000 in just compensation from the Idaho Transportation Department ("ITD"). ITD acted to condemn 16.314 acres to improve U.S. Highway 95. Those 16.314 acres were part of 56.8 acres that Grathol owned in Athol. After a bench trial, the district court held that just compensation would be based on the value of the 56.8 acre parcel. The court also held the property remaining after the condemnation suffered no severance damages. Grathol argued on appeal that the district court applied the wrong law and should have instead based just compensation on a 30 acre parcel. Grathol also argued that the district court ignored Grathol's severance damage evidence and improperly excluded testimony about damages from a proposed frontage road. Furthermore, Grathol appealed the district court's award of costs and discretionary fees to ITD, arguing that condemnors were not entitled to costs and that the court did not find ITD's discretionary costs were necessary and exceptional. Upon review, the Supreme Court found only that the district court erred in its award of attorney fees. The Court affirmed in all other respects, and remanded the case for recalculation. View "Dept of Transportation v. HJ Grathol" on Justia Law

917 Lusk, LLC appealed the Boise City Council's decision to grant a conditional use permit to Royal Boulevard Associates, LP to build an apartment complex. Royal's predecessor in interest applied for permission to build a 352,000 square foot, five-story, multi-family apartment complex called River Edge Apartments. The site of the proposed construction was near Boise State University, adjacent to the Boise River, east of Ann Morrison Park, and west of property owned by Lusk. The site was zoned Residential Office with a Design Review Overlay (R-OD). Multi-family housing was an allowed use for this location. However, the Boise City Code (BCC) required a conditional use permit (CUP) in order to construct a building more than 35 feet tall in an R-OD zone. If constructed as planned, River Edge will have been between 59 and 63 feet tall. Lusk appealed the Boise Planning and Zoning Commission's decision to the City Council, contending that the Commission's decision failed to address the requirements for a CUP. The district court affirmed the City Council's decision and Lusk appealed. Lusk argued that because the Commission did not follow the correct procedure for granting a CUP, the City Council erred in affirming the Commission's decision. The Supreme Court agreed, reversed the district court's affirmance of the City Council's approval of the Commission's decision to grant the CUP to Royal. The case was remanded for further proceedings. View "917 LUSK, LLC v. City of Boise" on Justia Law

The issue this appeal presented for the Supreme Court's review arose from a district court’s denial of Dameniel Owens’s motion for credit for time served. The district court specified that Owens would only receive credit for his prejudgment time served in a county jail on one of his eight counts of issuing a check without funds. Owens argued that Idaho Code section 18-309 plainly and unambiguously required the district court to credit his prejudgment time served to each of his eight counts. Owens further argued that the Supreme Court should have overruled "Idaho v. Hoch," (630 P.2d 143 (1981)), because in that case the Court improperly went beyond the statute’s plain meaning to hold that the legislature intended a defendant could not receive credit for each separate crime. The Supreme Court indeed overruled "Hoch," vacated the district court’s order denying Owens’s motion for credit for time served, and remanded the case for further proceedings. View "Idaho v. Owens" on Justia Law

Because no final judgment dissolving the marriage and no judgment regarding custody had ever been entered in this divorce action during the four-year period after the divorce trial, the Supreme Court dismissed the appeal because it did not qualify for an appeal by permission. After the appeal was dismissed, the magistrate court entered a partial judgment purporting to retroactively divorce the parties four years earlier and a partial judgment regarding custody and the division of property and debts. The appellant then filed a motion seeking reconsideration of the order dismissing the appeal. The Supreme Court denied that motion, vacated the partial judgment retroactively terminating the parties’ marriage, and direct the magistrate court to enter a new partial judgment dissolving their marriage. View "Cook v. Arias" on Justia Law

Respondents Alan and Marilyn Golub obtained a judgment against appellants and recorded the judgment. Kirk-Hughes Development, LLC (KHD), owned a parcel of real property in the county and therefore the judgment constituted a lien against its property. KHD claimed to have executed a deed of trust on the property in favor of Kirk-Scott, Ltd. (KS), several years before Golubs acquired their lien. Golubs filed an action for declaratory judgment, seeking a ruling that their judgment lien had priority over KS’ unrecorded deed of trust. The district court granted summary judgment to Golubs, finding that their lien had priority. KHD and the other appellants appealed that decision. After review, the Supreme Court found no reversible error, and affirmed the district court's judgment. View "Golub v. Kirk-Hughes Development" on Justia Law

This appeal arose from three mechanic’s liens that Keith Sims, dba Kasco of Idaho, LLC (“Sims”) filed on property that Dan Jacobson, Sage Holdings, LLC, Steven G. Lazar, the Mitchell A. Martin and Karen C. Martin Family Trust, and Devon Chapman (collectively “the Jacobson group”) had an interest in. The district court granted summary judgment to the Jacobson group on Sims’s lien foreclosure and quantum meruit claims. The court also awarded the Jacobson group their attorney fees and costs. Sims appealed the district court’s (1) grant of summary judgment on the lien foreclosure; (2) denial of a continuance at the quantum meruit hearing; and (3) award of attorney fees. Sims later withdrew his appeal on the lien foreclosure and continuance issues, so the only issue remaining was the district court’s grant of attorney fees to the Jacobson group. Finding no reversible error with regard to the fees issue, the Supreme Court affirmed the district court’s award. View "Sims v. Jacobson" on Justia Law

The issue this case presented for the Supreme Court's review centered on a dispute between two creditors as to whose claim against their debtor's property has priority. Respondents Alan and Marilyn Golub recorded a judgment against their judgment debtor, Kirk-Hughes Development, LLC (KHD), giving Golubs a judgment lien on property owned by KHD in Kootenai County. KHD claimed to have executed a deed of trust on the property in question several years before Golubs acquired their lien. The beneficiary of the deed of trust was another defendant, Kirk-Scott, Ltd. (KS). The district court granted summary judgment to Golubs, finding that Golubs' duly recorded judgment lien had priority over KS' prior, unrecorded deed of trust. KS appealed. Finding not reversible error, the Supreme Court affirmed the district court in all respects. View "Alan Golub v. Kirk-Scott, LTD" on Justia Law