Justia Idaho Supreme Court Opinion Summaries

Nicholas Roddy Ramlow and Amanda Marie Mitchell share custody of their minor son. The magistrate court had jurisdiction over their child custody case since 2016. In 2020, a temporary order was issued for the child to attend Kindergarten at Winton Elementary in Coeur d'Alene, Idaho. The parents later entered into a custody agreement that did not specify the child's school. In 2021, Mitchell moved to Pinehurst, Idaho, and enrolled the child in Pinehurst Elementary without informing Ramlow, who was under a no-contact order. Ramlow discovered the change in 2023 and attempted to enroll the child in Bryan Elementary in Coeur d'Alene, but the school secretary, Miriam McBenge, refused without both parents' consent or a court order.Ramlow filed a petition for declaratory judgment and a writ of mandamus in the district court to allow the child's enrollment in Coeur d'Alene. The district court dismissed the petition under Idaho Rule of Civil Procedure 12(b)(8), citing the ongoing child custody case in the magistrate court. Ramlow argued that the district court erred in its dismissal. McBenge and Mitchell requested the district court's decision be affirmed.The Supreme Court of Idaho reviewed the case. The court affirmed the district court's dismissal, agreeing that the magistrate court was better positioned to resolve the issue of the child's school enrollment due to its ongoing jurisdiction over the custody case. The court noted that the district court acted within its discretion and followed the appropriate legal standards. The case was remanded to the district court to amend the judgment to reflect a dismissal without prejudice. Additionally, the court awarded attorney fees on appeal to Mitchell under Idaho Code section 12-121, as Ramlow's appeal was deemed frivolous and without foundation. View "Ramlow v. Mitchell" on Justia Law

Elanore Vaughan purchased a ticket and signed an online liability waiver to go tubing at Eagle Island State Park, operated by Gateway Parks, LLC. The next day, Vaughan was injured when her tube went over an embankment and crashed into a flatbed trailer housing snowmaking equipment. Vaughan sued Gateway, alleging negligence and premises liability, claiming Gateway failed to maintain the tubing hill safely and created a hazard by placing the trailer at the end of the tubing run.The District Court of the Fourth Judicial District of Idaho denied Gateway's motion to dismiss Vaughan's complaint. Gateway argued that Vaughan's claims were barred by the liability waiver she signed and the Responsibilities and Liabilities of Skiers and Ski Area Operators Act. The district court found that while the Act applied, there was a genuine issue of material fact regarding the placement of the snowmaking equipment. The court also concluded that the liability waiver did not preclude Vaughan's claims. Gateway then sought and was granted permission to appeal the denial of its motion for summary judgment.The Supreme Court of the State of Idaho reviewed the case and reversed the district court's decision. The court held that the electronic liability waiver Vaughan signed precluded her claims against Gateway. The waiver explicitly acknowledged the risks of tubing, including collisions with manmade obstacles such as snowmaking equipment. The court determined that the waiver's language was broad enough to encompass Vaughan's accident and injuries. Consequently, the court directed the district court to grant summary judgment in favor of Gateway and dismiss Vaughan's complaint. The court also denied Gateway's request for attorney fees on appeal, as the gravamen of Vaughan's lawsuit was a tort, not a commercial transaction. View "Vaughan v. Gateway Park, LLC" on Justia Law

Laura Milus, on behalf of herself and her minor son, D.L.J., filed a wrongful death action against Sun Valley Company after her husband died from colliding with snowmaking equipment while skiing at Sun Valley Ski Resort. Milus claimed that Sun Valley breached its duties under Idaho Code section 6-1103(2) and (6) by not properly marking the equipment and failing to post a notice about snowmaking operations.The District Court of the Fifth Judicial District of Idaho granted summary judgment in favor of Sun Valley, concluding that the company met its duty under section 6-1103(2) by placing yellow padding on the equipment and had no duty under section 6-1103(6) because the equipment was not actively discharging snow. The court did not address Sun Valley's argument that Milus' claims were barred by section 6-1106, which states that skiers assume the risk of injury from plainly visible or marked snowmaking equipment.The Supreme Court of Idaho reviewed the case and held that ski area operators are held to an ordinarily prudent person standard of care when performing duties under the Ski Area Liability Act. The court found that Milus failed to create a genuine issue of material fact regarding whether Sun Valley met this standard with the yellow padding. However, the court also held that there was a genuine issue of material fact about whether Sun Valley posted the required notice under section 6-1103(6).Despite this, the court affirmed the district court's decision, concluding that Milus' claims were barred by section 6-1106 because Mr. Milus assumed the risk of injury from the plainly marked snowmaking equipment. The court denied Sun Valley's request for attorney fees on appeal, as both parties prevailed on some arguments. View "Milus v. Sun Valley Company" on Justia Law

Petitioners sought to validate a portion of West Fork Pine Creek Road in Shoshone County, Idaho, which runs across private property and into public land managed by the Bureau of Land Management. The road is used by recreationalists to access an area known as "the Roller Coaster." Following disputes between local landowners and recreationalists, a petition was filed with the Shoshone County Board of Commissioners to validate the road. The Board denied the petition, citing concerns about environmental impacts, safety, and costs to taxpayers.The petitioners then sought judicial review in the District Court of the First Judicial District of Idaho, arguing that the Board erred in its decision. The district court affirmed the Board's decision, concluding that the Board's findings were supported by substantial and competent evidence. The petitioners appealed to the Supreme Court of Idaho, arguing that the district court erred in affirming the Board's conclusions.The Supreme Court of Idaho reviewed the case and determined that the Board erred in concluding that the 1909 meeting minutes did not establish the road as a public highway. However, the Court found no error in the Board's determination that validating the road was not in the public interest. The Court noted that the Board had considered various factors, including the availability of alternative access routes, the costs of surveying and maintaining the road, and the concerns of private property owners.Ultimately, the Supreme Court of Idaho affirmed the district court's decision, holding that while the road was established as a public highway in 1909, the Board did not abuse its discretion in determining that validation was not in the public interest. Neither party was awarded attorney fees on appeal. View "Jutila v. County of Shoshone" on Justia Law

A group called Idahoans United for Women and Families filed an original action in the Idaho Supreme Court seeking writs of certiorari and mandamus. They challenged the fiscal impact statement (FIS) and ballot titles prepared for a citizen initiative titled the “Reproductive Freedom and Privacy Act.” The group argued that the FIS and ballot titles did not comply with Idaho law and requested the court to either certify their versions or order the Idaho Division of Financial Management (DFM) and the Attorney General to prepare new ones.The Idaho Supreme Court dismissed the petition against the Secretary of State, as Idahoans United failed to specify the writ or what they sought to compel. The court partially granted the writ of mandamus against DFM, finding that the FIS did not substantially comply with Idaho Code section 34-1812 due to a lack of a reasonable basis for its estimated fiscal impact, unclear language, and unnecessary legal terms. The court also partially granted the writ of mandamus against the Attorney General, concluding that the short ballot title did not substantially comply with Idaho Code section 34-1809 because it failed to capture all distinctive features of the initiative. However, the court found that the long ballot title substantially complied with the statutory requirements.The Idaho Supreme Court retained jurisdiction and ordered DFM to provide a new FIS and the Attorney General to provide a new short ballot title by a specified deadline. The court declined to certify the versions provided by Idahoans United and did not award attorney fees to any party. Upon submission, the court reviewed the new FIS and short ballot title, concluding that both substantially complied with the statutory requirements and certified the new short ballot title to the Idaho Secretary of State. View "Idahoans United for Women and Families v. Labrador" on Justia Law

Lisa Sánchez, a member of the Boise City Council, moved her residence outside of the district she represented. She was informed by the mayor and city council that she had automatically vacated her seat due to this move. The mayor subsequently appointed a new council member to fill her seat. Sánchez sued the City of Boise, claiming improper removal and seeking reinstatement, along with damages for lost salary and benefits. The City moved for judgment on the pleadings, which the district court granted, dismissing her case with prejudice. Sánchez appealed, questioning whether a city council member automatically vacates their seat under Idaho Code section 59-901(1)(e) when they unintentionally move out of their district.The district court concluded that Idaho Code section 59-901(1)(e) applies to city council members and that Sánchez's intent to remain a resident of her district was irrelevant. The court held that the statute's plain language indicated an automatic vacancy upon moving out of the district, regardless of intent. The court also found that Sánchez received all due process required under the statute.The Supreme Court of Idaho affirmed the district court's decision. The court held that Idaho Code section 59-901(1)(e) applies to city council members and that the statute's plain language does not require an inquiry into the official's intent. The court also concluded that no additional due process was required because any potential property interest in Sánchez’s elected position was forfeited when she moved out of her district. Thus, the district court's judgment on the pleadings in favor of the City was affirmed. View "Sanchez v. City of Boise" on Justia Law

A group called Idahoans United for Women and Families filed a petition seeking writs of certiorari and mandamus against the Idaho Division of Financial Management (DFM), the Idaho Attorney General, and the Idaho Secretary of State. The petition concerns the fiscal impact statement (FIS) and ballot titles for a citizen initiative titled the “Reproductive Freedom and Privacy Act.” Idahoans United argued that the FIS and ballot titles did not comply with Idaho law and requested the court to either certify their proposed versions or order the respondents to prepare new compliant versions.The Idaho Supreme Court reviewed the case. The court dismissed the petition against the Secretary of State, finding that Idahoans United failed to properly invoke the court's original jurisdiction against him. However, the court partially granted the writ of mandamus against DFM, concluding that the FIS did not substantially comply with Idaho Code section 34-1812 due to a lack of a reasonable basis for its estimated fiscal impacts, unclear and conflicting statements, and unnecessary legal terms. The court also partially granted the writ of mandamus against the Attorney General, finding that the short ballot title did not substantially comply with Idaho Code section 34-1809 because it failed to capture all distinctive features of the initiative. However, the court found that the long ballot title substantially complied with the statutory requirements.The Idaho Supreme Court retained jurisdiction and ordered DFM to provide a new FIS and the Attorney General to provide a new short ballot title by June 23, 2025. The court denied the request for attorney fees, noting that both parties prevailed in part. View "Idahoans United for Women and Families v. Labrador" on Justia Law

In December 2018, Misty Dawn Rose was charged with Delivery of a Controlled Substance and later indicted on additional charges, to which she pleaded guilty. The district court sentenced her to multiple terms, which were to be served consecutively, but retained jurisdiction and sent her on a rider. After successfully completing the rider, Rose was placed on supervised probation. In November 2021, a Probation Violation Report was filed, citing multiple violations, including failure to attend substance abuse treatment and committing a new misdemeanor. The district court issued a bench warrant and, after a hearing, decided to give Rose another chance with a second rider, specifying that she must be admitted to drug court or mental health court to remain on probation.Rose completed the second rider but was not admitted to either treatment court due to eligibility issues. Despite her efforts, she was not accepted into any program. The district court set a probation review hearing, stating that failure to be accepted into a treatment court would be a violation of probation. Rose failed to appear at the review hearing because she was in custody in another county. The district court found her in violation of probation for not being admitted to a treatment court and for failing to appear at the hearing, and subsequently revoked her probation and imposed her sentences.The Idaho Court of Appeals affirmed in part and reversed in part, concluding that Rose's failure to be admitted to a treatment court was not willful but upheld the finding that her failure to appear was willful. The case was remanded for a probation disposition hearing. Rose petitioned for review, which the Idaho Supreme Court granted.The Idaho Supreme Court reversed the district court's order revoking probation, holding that Rose's non-acceptance into a treatment court was not willful and that she was not given proper notice that her failure to appear at the hearing would be a ground for revocation. The judgment imposing her sentence was vacated, and the case was remanded for further proceedings before a different district judge. View "State v. Rose" on Justia Law

The case involves the City of Lava Hot Springs, which regulates short-term rentals based on whether they are occupied by an owner or manager. Non-owner-occupied short-term rentals are prohibited in residential zones and only allowed in commercial zones. John and Michelle Taylor applied for a business license to operate a non-owner-occupied short-term rental in a residential zone, but the City denied their application. The Taylors, along with the Idaho Association of Realtors, sued the City, claiming that its regulations violated the Short-term Rental and Vacation Rental Act, which limits municipal regulations on short-term rentals.The district court granted summary judgment in favor of the City, finding that the City's regulations did not have the express or practical effect of prohibiting short-term rentals and were permissible under the health, safety, and welfare exception in the Act. The court concluded that because at least one type of short-term rental (owner-occupied) was allowed in residential zones, the City had not violated the Act. The Taylors and the Realtors appealed this decision.The Supreme Court of Idaho reviewed the case and reversed the district court's decision. The Court held that the City's ordinance, which prohibited non-owner-occupied short-term rentals in residential zones, violated the Short-term Rental and Vacation Rental Act. The Act prohibits any city ordinance that has the express or practical effect of prohibiting short-term rentals. The Court found that the City's ordinance amounted to a prohibition rather than a regulation and thus invalidated the ordinance. The Court awarded costs on appeal to the Petitioners but did not grant attorney fees to either party. View "Idaho Association of Realtors, Inc. v. City of Lava Hot Springs" on Justia Law

Chadlen Dewayne Smith was convicted of sexual exploitation of a child by possession of sexually exploitative material. The case began when Smith was arrested for stalking a police dispatcher. Following his arrest, law enforcement impounded his vehicle and conducted an inventory search, during which they seized electronic devices containing sexually exploitative materials. Smith challenged the district court’s denial of his motion to suppress the evidence found on these devices.The District Court of the First Judicial District, Kootenai County, denied Smith’s motion to suppress, concluding that there was probable cause for his arrest for stalking and that the impoundment and subsequent inventory search of his vehicle were reasonable and conducted according to standard police procedures. Smith was convicted by a jury of sexual exploitation of a child but acquitted of distributing obscene material. He appealed the conviction, arguing that the evidence obtained from the inventory search should have been suppressed.The Supreme Court of the State of Idaho reviewed the case and reversed the district court’s decision. The court held that the State did not meet its burden to show that the police officer’s decision to impound Smith’s vehicle served a community caretaking purpose. The impoundment was deemed unreasonable under the Fourth Amendment, making the subsequent inventory search unconstitutional. Consequently, the evidence obtained from the search was inadmissible, leading to the vacating of Smith’s conviction. The court emphasized that the impoundment must be reasonable under all circumstances known to the police at the time and must serve a legitimate community caretaking function. View "State v. Smith" on Justia Law