Justia Idaho Supreme Court Opinion Summaries

Appellants were five individuals and one Idaho limited liability company (collectively, “Plaintiffs”) who owned real property in the City of Boise (“City”) and paid ad valorem taxes to Ada County, Idaho. Plaintiffs brought an action in district court challenging ordinances the City passed that allocate tax increment financing (“TIF”) revenues to Capital City Development Corporation (“CCDC”), the City’s urban renewal agency. Specifically, the ordinances approved the allocation of TIF revenues for CCDC’s use in the Shoreline District Urban Renewal Project Area and Gateway East Economic Development District Project Area. Because Plaintiffs’ alleged injuries were solely predicated upon their status as taxpayers, the district court dismissed their complaint for lack of standing. On appeal to the Idaho Supreme Court, Plaintiffs alleged they had standing under Koch v. Canyon County, 177 P.3d 372 (2008), in which the Supreme Court held that no particularized harm was necessary to establish taxpayer standing where a violation of article VIII, section 3 of the Idaho Constitution was alleged. Because the Supreme Court determined here that, as a matter of law, the ordinances Plaintiffs challenged did not violate article VIII, section 3, it affirmed the judgment of the district court. View "Hoffman v. City of Boise" on Justia Law

In this case, the Idaho Supreme Court was asked to revisit its decision in Idaho v. Clarke, 446 P.3d 451 (2019), and determine whether its holding was applicable in an administrative proceeding regarding the suspension of driving privileges based on an alleged case of driving under the influence (“DUI”). The Idaho Transportation Department (“ITD”) appealed a district court’s decision overturning its one-year suspension of Jasmine Reagan’s driving privileges. ITD based the administrative license suspension (“ALS”) on Reagan’s arrest for misdemeanor driving under the influence of alcohol and the results of subsequent testing of her blood alcohol content (“BAC”). The arresting officer, acting on a citizen’s report of a possible intoxicated driver, did not personally witness Reagan operating or in control of a vehicle. Reagan failed field sobriety tests administered at her home and, after being arrested, failed a breathalyzer test. Reagan received notice that her driver’s license was suspended for one year, which she appealed. An administrative hearing officer for ITD, relying on Idaho Code section 49-1405, upheld the license suspension. However, on appeal the district court overturned the suspension pursuant to Clarke, reasoning that because the misdemeanor DUI was completed outside the officer’s presence, the arrest required a warrant. On certiorari review, the issues presented were: (1) whether the breathalyzer test was administered pursuant to a lawful arrest; and (2) if the arrest was unlawful, whether test results obtained pursuant to an unlawful arrest are admissible in an ALS hearing before the ITD. The SupremeCourt concluded Idaho Code section 49-1405, as applied in this case, violated the Idaho Constitution. Accordingly, the Court affirmed the district court's decision to overturn ITD's suspension of Reagan's license. View "Reagan v. Idaho Transportation Department" on Justia Law

Citizens Against Linscott/Interstate Asphalt Plant (“CAL”) challenged a conditional use permit (“CUP”) issued by the Bonner County, Idaho Board of Commissioners (“the County”). The CUP was based on a recent amendment to Bonner County zoning ordinances (“the Amendment”) and authorized Interstate Concrete and Asphalt Company (“Interstate”) to operate an asphalt batch plant within Frank and Carol Linscott’s gravel mine in Sagle, Idaho. In its petition for judicial review by the Bonner County district court, CAL challenged both the validity of the Amendment and the County’s decision to issue the CUP. The district court determined that CAL had standing to file its petition for judicial review of the CUP and that CAL had timely filed its petition. However, the district court concluded that it could not declare the Amendment invalid in a proceeding for judicial review under Idaho Local Land Use Planning Act (“LLUPA”) and the Idaho Administrative Procedure Act (“IDAPA”). Accordingly, the district court upheld the County’s decision to grant the CUP, giving the County deference in applying its own land-use ordinances. During the pendency of this appeal, CAL filed an action for declaratory relief before another district court judge to have the Amendment declared void. In that proceeding, the County admitted that the Amendment had been adopted without proper public notice and stipulated to a judgment and order declaring the Amendment void. On appeal of the administrative decision to the Idaho Supreme Court, CAL argued, among other things, that the subsequent voiding of the Amendment also invalidated the CUP or that the CUP was not issued in conformity with Bonner County zoning laws. After review, the Supreme Court affirmed in part, and reversed in part. The Court found the CUP authorizing the relocation of the Interstate asphalt batch plant to the Linscotts’ gravel mine was invalid because it was based on a void amendment to Bonner County Code. Further, the County acted in a manner that was arbitrary and capricious in refusing to address the gravel pit’s compliance with the nonconforming use provisions of BCRC. View "Citizens Against Linscott v. Bonner County Board of Commissioners" on Justia Law

This case arose from an Idaho company’s attempt to bring an action in Idaho against a resident of Oklahoma and a business located in Oklahoma. Brockett Company, LLC appealed a district court order setting aside a default judgment entered against Scott Crain and Texoma MFG., LLC (collectively, Respondents). The district court set aside the default judgment after determining that it did not have personal jurisdiction over Crain or Texoma. On appeal, Brockett Co. argued that the district court erred in setting aside the default judgment by inappropriately considering an affidavit submitted by Crain, failing to consider facts in the record, and determining that it did not have personal jurisdiction over Crain and Texoma. After review of the trial court record, the Idaho Supreme Court determined he district court erred in granting Respondents’ motion to set aside the default judgment. Accordingly, the Court reversed the district court’s order granting Crain and Texoma’s motion to set aside the default judgment, vacated the district court’s judgment dismissing Brockett Co.’s claims, and remanded with instruction to reinstate the previously entered default judgment against Crain and Texoma. View "Brockett Company LLC v. Crain" on Justia Law

In 2007 and 2008, AgStar Financial Services (AgStar), now Compeer Financial FLCA (Compeer), loaned substantial sums of money to Northwest Sand and Gravel, Inc., Gordon Paving Company, Inc., and Blackrock Land Holdings, LLC (collectively, "Gordon Paving.") As a result of financing these loans, AgStar became a secured creditor of Gordon Paving. In 2012, Gordon Paving defaulted on its $10 million obligation to AgStar, which then resulted in AgStar obtaining a judgment of foreclosure on various parcels of real property Gordon Paving owned. The district court also entered an order allowing the sale of virtually all of Gordon Paving’s business equipment to further satisfy the debt. Gordon Paving appealed the district court’s decision which allowed AgStar to sell the business equipment. In "AgStar I," the Idaho Supreme Court reversed the district court’s order allowing AgStar to liquidate Gordon Paving’s business equipment, but this decision came long after the business equipment had already been sold at auction. On remand, the district court determined that the correct remedy for Gordon Paving was an award of restitution in the amount of the gross proceeds of the sale plus interest from the date of the sale based on its interpretation of Idaho Code section 28-22-104. Compeer appealed the district court’s order denying it an offset for expenses its predecessor, AgStar, incurred in liquidating Gordon Paving’s business equipment. Compeer also appealed the district court’s order awarding Gordon Paving prejudgment interest on the restitution award from the date the collateral was sold. After review, the Supreme Court reversed the district court’s order denying Compeer an offset for the auctioneer’s expenses incurred which were never received by AgStar. The Court affirmed the district court’s order awarding Gordon Paving prejudgment interest; however, the district court’s decision allowing prejudgment interest to run from the date of the sale was vacated. View "Agstar Financial Services v. Northwest Sand & Gravel" on Justia Law

Plaintiff-appellant Cassie Secol and her four minor children (collectively “the Secols”) challenged several evidentiary rulings, jury instructions, and the denial of their motion for a new trial. In late 2016, Damian Secol passed away from a rare form of cancer, T-cell lymphoblastic lymphoma (“T-LBL”). Following his death, the Secols brought a medical malpractice action against Damian’s primary care providers: Kelly Dustin, D.O., Austin Gillette, M.D., and Fall River Medical, PLLC (collectively “Fall River”). At trial, the district court questioned Dr. Jeffery Hancock, Damian’s treating oncologist, in front of the jury concerning the treatment and diagnosis of T-LBL. The Secols moved the district court for a mistrial, arguing the questioning prevented a fair trial. The district court denied the motion. After the jury returned a verdict in Fall River’s favor, the Secols moved the district court for a new trial, which was also denied. The Secols appealed, challenging the district court’s evidentiary rulings, delivery of jury instructions, and the denial of their motion for a new trial. After review, the Idaho Supreme Court reversed the district court, vacated the judgment following the jury verdict, and remanded for a new trial to be conducted by a new district judge. Specifically, the Court determined the district court abused its discretion in denying the Secols’ motion for a new trial because its questioning of Dr. Hancock denied the Secols a fair trial. "Such questioning was an abuse of discretion and necessitates a new trial." Further, the district court abused its discretion in permitting Dr. Hancock to testify as to matters for which no foundation was laid and which were outside the scope of his expertise. And in addition, the district court erred in admitting irrelevant testimony about Dr. Gillette’s and Dr. Dustin’s families and hobbies, and the district court erred in delivering a modified jury instruction on medical negligence, which included prejudicially confusing language concerning direct expert testimony as compared to expert testimony. The district court was affirmed as to the admission of Fall River two experts' testimony on the standard of care because its decision on Fall River’s motion for reconsideration was not part of the record. View "Secol v. Fall River Medical PLLC" on Justia Law

Respondent Mark Radford sued Appellant Jay Van Orden for damages from trespass of lands and trespass of cattle, among other claims, and also sued Appellant Seven J Ranches, Inc. (“Seven J”) for reimbursement for the construction of a partition fence pursuant to Idaho Code section 35-103. The two cases were later consolidated. Upon Van Orden’s motion for summary judgment, the district court determined that Radford had standing to sue Van Orden for trespass, even though Radford was not the property owner when the trespass occurred, because the previous property owner executed an assignment of claims to him. After a five-day bench trial, the district court found Van Orden was liable for trespass and awarded damages to Radford, and required Seven J to reimburse Radford for one half of a constructed partition fence. The district court also found Van Orden was not liable for trespass of cattle and ordered Radford to construct a gate at the southern edge of his property to allow Van Orden to access an easement that runs across Radford’s property. The district court determined Radford to be the overall prevailing party and awarded attorney fees only against Seven J. Van Orden and Seven J appealed the district court’s standing determination on summary judgment, the damages awarded against Van Orden on Radford’s trespass claim, the reimbursement awarded on the partition fence claim against Seven J, and the prevailing party determination for purpose of awarding attorney fees. Radford cross-appealed the district court’s denial of his claim for trespass of cattle damages and the district court’s requirement that he construct a gate for Van Orden at the edge of his property. Concerning Radford and Seven J’s appeal, the Idaho Supreme Court affirmed the district court’s rulings that: (1) Radford had standing; (2) Radford proved the trespass damages with reasonable certainty; (3) Radford’s partition fence notice to Seven J was sufficient and required Seven J to reimburse Radford for the fence; (4) Radford was the prevailing party against Seven J and was entitled to costs and reasonable attorney fees against Seven J. As to Radford’s cross-appeal, the Supreme Court affirmed the district court’s ruling that Radford was required to remove his fence across the prescriptive easement or install a gate for Van Orden’s ingress and egress. However, the Court reversed the district court’s decision denying Radford damages for trespass of cattle against Van Orden, and remanded with instructions to consider whether Van Orden was entitled to relief under his unjust enrichment theory. View "Radford v. Van Orden" on Justia Law

At issue was whether a prescriptive easement existed to provide road access and utilities to a land-locked parcel and mining claim on Lake Pend Oreille in northern Idaho. Matt and Bonnie Latvala purchased the land-locked parcel, known as “Sulphide South,” in 2015 and litigation soon followed. Following a four-day bench trial and site visit, the district court quieted a prescriptive easement to the Latvalas through and over what was known as South Camp Bay Road, as well as confirming and defining an express easement across another parcel known as “Sulphide North.” Some neighboring landowners appealed the district court’s judgment, arguing the court’s findings were not supported by substantial and competent evidence. These neighbors also argued the district court erroneously allowed the prescriptive easement to be unreasonably expanded. After review, the Idaho Supreme Court affirmed the district court’s determination that the use of the road at issue by Latvala’s predecessors in interest during the active mining years (1946 to 1954) created a prescriptive easement; however, the Court reversed the district court’s judgment expanding the scope of the easement.The district court’s award of costs to Latvala as the prevailing party was vacated and the matter remanded so that the district court could consider Latvala’s remaining claims about whether South Camp Bay Road was a public road and whether he has an easement by necessity. View "Latvala v. Green Enterprises Inc." on Justia Law

Greg and Cyndi Gomersall filed suit on behalf of their minor child, W.G.G., claiming he received negligent medical treatment at St. Luke’s Regional Medical Center (SLRMC) in Boise when he was injured in December 2010. W.G.G. was 6 years old at the time of the incident. The Gomersalls filed suit against SLRMC on January 25, 2019, more than eight years after W.G.G. was alleged to have been injured. SLRMC moved for summary judgment on the basis that the Gomersalls’ medical malpractice action was time-barred under Idaho Code sections 5-219(4) and 5-230. The district court granted SLRMC’s motion and dismissed the complaint with prejudice. The Gomersalls contended on appeal to the Idaho Supreme Court that the district court erred because Idaho Code section 5-230 was unconstitutional. Specifically, they argued that section 5-230 violated W.G.G.’s due process and equal protection rights by failing to toll the statute of limitations for medical malpractice claims until the age of majority. They also contended the district court erred when it held that the doctrine of equitable estoppel did not preclude SLRMC’s statute of limitations defense. Finding no reversible error, the Supreme Court affirmed the district court’s decision granting summary judgment in favor of SLRMC. View "Gomersall v. St. Luke's Regional Medical Center" on Justia Law

Fifteen-year-old Lucas Orozco was charged with robbery and burglary, both felonies, for allegedly robbing a convenience store. After a magistrate court determined there was probable cause to charge Orozco with the felonies, it waived juvenile jurisdiction and bound him over to district court as an adult pursuant to Idaho Code section 20-509. Orozco objected to this automatic waiver, filing a motion with the district court challenging the constitutionality of section 20-509. The district court denied the motion, relying on precedent from the Idaho Court of Appeals, which previously upheld the constitutionality of section 20-509. Orozco appealed, arguing that the automatic waiver denied him procedural due process protections afforded to him by the U.S. Constitution. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Idaho v. Orozco" on Justia Law