Justia Government & Administrative Law Opinion Summaries

In 2019, Colby James Bray died while in the custody of the Idaho Department of Juvenile Corrections (IDJC). His parents, Jeffrey and Michelle Bray, acting as personal representatives of his estate, filed a wrongful death suit in federal court one day before the two-year statute of limitations expired. They later voluntarily dismissed the federal case and refiled in state court nearly three years after Colby's death. The defendants moved for summary judgment, arguing the claims were time-barred by the two-year statute of limitations. The district court granted the motions and dismissed the complaint with prejudice.The Brays appealed, arguing that Idaho Code section 5-234 and 28 U.S.C. section 1367(d) tolled the statute of limitations. The district court had concluded that section 5-234 did not toll the time for filing the state complaint and that section 1367(d) did not apply to IDJC due to Eleventh Amendment immunity. The court also awarded costs and attorney fees to the defendants.The Supreme Court of Idaho affirmed the district court's ruling that section 5-234 did not toll the statute of limitations. It also agreed that the claims against Meacham and the Individual Defendants were time-barred under section 1367(d) because the Brays did not file within 30 days after the federal court dismissed those claims. However, the court found that section 1367(d) did toll the time for filing the complaint against IDJC, but IDJC was immune from the claims under Idaho Code section 6-904B(5). The court upheld the district court's award of attorney fees and costs to the defendants and awarded attorney fees and costs on appeal to the respondents. View "Bray v. ID Dept of Juvenile Corrections" on Justia Law

Interfaith Sanctuary Housing Services, Inc. (IFS) applied for a conditional use permit (CUP) to operate a large-scale low-barrier shelter home in Northwest Boise. The Planning and Zoning Commission (PZC) initially denied the application, citing concerns about compatibility with the neighborhood, undue burden on public facilities, adverse effects on nearby properties, and insufficient information on mitigating adverse impacts. IFS appealed to the Boise City Council, which reversed the PZC’s decision and granted the CUP, imposing 30 conditions of approval. The Veterans Park Neighborhood Association, Inc. (VPNA) sought reconsideration, which was denied, and then petitioned the district court for judicial review.The district court upheld the City Council’s decision, finding no error in the Council’s actions. VPNA appealed to the Idaho Supreme Court, arguing that the City Council’s decision was arbitrary and capricious, based on unlawful procedure, and that the Council’s reasoned statement was inadequate under the Local Land Use Planning Act (LLUPA).The Idaho Supreme Court found that the City Council’s decision was arbitrary and capricious and based on unlawful procedure because the PZC’s determination that the CUP could not be conditioned into compliance with the CUP criteria was not an error. The Court also found that the City Council’s reasoned statement was conclusory and failed to adequately resolve pertinent factual disputes, thus violating LLUPA and depriving VPNA of due process. The Court concluded that VPNA demonstrated a prejudice to its substantial rights.The Idaho Supreme Court reversed the district court’s decision and remanded the case with instructions to invalidate the City Council’s approval of the CUP. VPNA was awarded costs but not attorney fees on appeal. View "Veterans Park Neighborhood Association, Inc. v. City of Boise" on Justia Law

Chesla A. Scott challenged the Idaho Department of Labor's service of three determination notices, claiming she did not receive them while temporarily working out-of-state. The Department mailed the notices to her last known address, and Scott missed the fourteen-day appeal period. When she attempted to appeal, the Department's Appeals Examiner dismissed her appeal as untimely. Scott argued that the Department's service by mail did not meet constitutional due process requirements.The Appeals Examiner conducted a hearing and concluded that Scott's appeal was untimely under Idaho Code section 72-1368(3) and (5). The Idaho Industrial Commission affirmed this decision, denying Scott's request for a new hearing and conducting a de novo review of the record. The Commission also concluded that Scott had not timely filed her appeal.Scott appealed to the Idaho Supreme Court, arguing that the Department's service by mail was constitutionally inadequate. The Court reviewed whether Scott exhausted her administrative remedies and preserved her constitutional challenge. The Court held that Scott had exhausted her administrative remedies and preserved her due process claim, allowing it to be reviewed.The Idaho Supreme Court affirmed the Commission's decision, holding that the Department's mailing of the determination notices was reasonable under all the circumstances and did not violate due process. The Court found that the Department's method of service was reasonably calculated to provide notice, and Scott's failure to receive the notices was not due to any fault of the Department. The Court did not award attorney fees to either party but awarded costs to the Department. View "Scott v. Home Depot USA, Inc." on Justia Law

Sherry Cole filed a formal complaint against Rocky Mountain Power (RMP) alleging she had been overbilled due to her power meter being cross-connected with her neighbor’s. Initially, an RMP employee confirmed the cross-connection and credited her account with $1,256.45. However, subsequent tests revealed no cross-connection, leading RMP to remove the credit and instead apply a $450 credit for the inconvenience. Cole then filed a complaint with the Idaho Public Utilities Commission, which dismissed her complaint due to lack of evidence of overcharging. Cole's motion for reconsideration was also denied by the Commission.Cole appealed to the Idaho Supreme Court. The Commission had reviewed Cole’s complaint, RMP’s billing calculations, and an analysis by Jon Kruck, an investigator, which concluded that Cole’s energy usage was consistent and did not indicate a cross-connection. The Commission found no substantial evidence supporting Cole’s claims and dismissed her complaint. Cole’s petition for reconsideration was denied as she failed to present new evidence or demonstrate that the dismissal was unreasonable or unlawful.The Idaho Supreme Court affirmed the Commission’s decision, finding that the Commission’s factual findings were supported by substantial and competent evidence. The Court noted that Cole relied on anecdotal evidence and did not provide sufficient proof to counter the Commission’s findings. Additionally, the Court held that Cole’s constitutional arguments were waived as they were raised for the first time on appeal and were not supported by sufficient legal authority. The Court also denied Cole’s request for attorney fees, as pro se litigants are not entitled to such fees.The Idaho Supreme Court affirmed the orders of the Idaho Public Utilities Commission dismissing Cole’s complaint and denying her petition for reconsideration. View "Cole v. IPUC" on Justia Law

The Idaho State Board of Education approved a proposal for the University of Idaho to purchase the University of Phoenix for $550 million, funded by a $685 million bond. This decision followed three closed-door executive sessions. Idaho Attorney General Raúl R. Labrador filed a suit to void the sale, alleging violations of the Idaho Open Meetings Law, which mandates that public policy formation be conducted openly. The district court dismissed the suit, finding no violations.The district court ruled that the Board's actions during the executive sessions were lawful under the exception in Idaho Code section 74-206(1)(e), which allows closed meetings for preliminary negotiations involving trade or commerce when in competition with other states. The court interpreted "preliminary negotiations" to include all negotiations before contracting and applied a "reasonable belief" standard to determine if the Board believed it was in competition with another governing body.The Idaho Supreme Court reviewed the case and found that the district court erred in its broad interpretation of "preliminary negotiations" and the application of the "reasonable belief" standard. The Supreme Court held that "preliminary negotiations" should be narrowly construed to mean a phase of negotiations before final negotiations, and the statute requires actual competition, not just a reasonable belief of competition. The court vacated the district court's summary judgment, its judgment following the bench trial, and the award of attorney fees and costs to the Board. The case was remanded for further proceedings consistent with the Supreme Court's interpretation of Idaho Code section 74-206(1)(e). View "Labrador v. Board of Education" on Justia Law

Catherine Sullivan, trustee of the Catherine Sullivan Family Trust of 2000, owns residential property adjacent to Megan Gruver's equestrian facility, Silver Bell Ranch, in Blaine County, Idaho. Gruver was issued a conditional use permit (CUP) in 2019 to operate the facility, which Sullivan did not appeal. In 2021, Gruver sought modifications to the CUP to hold three events per year, board additional horses, and hire more staff. Sullivan objected, citing concerns about noise, traffic, and property devaluation, but the Blaine County Board of Commissioners approved the modified CUP with conditions.Sullivan appealed the Board's decision to the district court, arguing that the Board erred in categorizing Silver Bell Ranch as an "Outdoor Recreational Facility" rather than an "Agricultural Business" and that the modifications would prejudice her substantial rights. The district court affirmed the Board's decision, finding that Sullivan failed to show how the modifications prejudiced her substantial rights and that her arguments regarding the categorization of the facility were time-barred because she did not appeal the 2019 CUP.The Idaho Supreme Court reviewed the case and affirmed the district court's decision. The Court held that Sullivan's arguments regarding the categorization of Silver Bell Ranch were time-barred and that she failed to establish prejudice to her substantial rights under Idaho Code section 67-5279(4). The Court also found that the district court acted within its discretion in excluding Sullivan's arguments related to prejudice that were raised for the first time in her reply brief. Blaine County was awarded attorney fees on appeal under Idaho Code section 12-117(1), while Gruver was not entitled to attorney fees as she was not an adverse party to Blaine County. Both Blaine County and Gruver were awarded costs on appeal. View "Sullivan v. Blaine County" on Justia Law

In this case, the appellant, Chitta Roy, challenged the Idaho Department of Health and Welfare's (the "Department") denial of her criminal history background clearance during her certified family home (CFH) recertification. Roy had a 2008 conviction for involuntary manslaughter, which was dismissed in 2011 under Idaho Code section 19-2604 after she successfully completed probation. Despite this, the Department denied her 2021 application for background clearance, citing the conviction as a disqualifying crime under its updated rules.The District Court of the Seventh Judicial District of Idaho upheld the Department's decision, rejecting Roy's arguments that the dismissal of her conviction should preclude the Department from denying her clearance and that the Department should be bound by its 2009 decision to grant her an exemption. The district court also determined that Roy failed to show substantial prejudice from the denial, as the Department could still approve her CFH recertification through a separate process.The Supreme Court of Idaho reviewed the case and found that the district court erred in its conclusions. The Supreme Court held that the Department improperly based its denial on the dismissed conviction, which, under Idaho Code section 19-2604, should be treated as if it never existed. The Court also determined that the case was ripe for adjudication and that Roy's substantial rights were prejudiced by the Department's denial. The Supreme Court reversed the district court's decision and remanded the case for further proceedings consistent with its opinion. Roy was awarded costs on appeal. View "Roy v. Idaho Department of Health and Welfare" on Justia Law

John David Wurdemann was convicted of seven felonies related to a 2000 attack on a woman in Canyon County, Idaho. Sixteen years later, a district court granted his petition for post-conviction relief, vacating his convictions due to ineffective assistance of counsel. This decision was affirmed by the Idaho Supreme Court in 2017. Wurdemann was not retried. In 2021, Idaho enacted the Idaho Wrongful Conviction Act, which allows for compensation for wrongfully convicted individuals who meet specific criteria. Wurdemann filed a petition under this Act seeking compensation and a certificate of innocence.The district court granted the State's motion for summary judgment, concluding that Wurdemann had not established that the basis for vacating his conviction was not legal error unrelated to his factual innocence, as required by the Act. Wurdemann appealed this decision.The Idaho Supreme Court reviewed the case and interpreted the statutory language of the Idaho Wrongful Conviction Act. The Court held that the phrase “not legal error unrelated to his factual innocence” means “legal error related to his factual innocence.” The Court concluded that the legal error in Wurdemann’s case—ineffective assistance of counsel due to failure to challenge a suggestive police lineup—did not establish his factual innocence. The reversal of his convictions was based on the deficient performance of his trial attorneys, not on evidence proving his innocence. Therefore, Wurdemann did not meet the statutory requirement for compensation under the Act.The Idaho Supreme Court affirmed the district court’s grant of summary judgment in favor of the State, concluding that Wurdemann could not satisfy the necessary element of showing that the basis for reversing his conviction was related to his factual innocence. View "Wurdemann v. State" on Justia Law

The Idaho Attorney General filed a petition seeking to prevent an initiative from appearing on the 2024 general election ballot. The initiative, proposed by Idahoans for Open Primaries, aims to replace Idaho’s closed party primary system with a non-partisan "top four primary" and implement ranked-choice voting for the general election. The Attorney General argued that the signatures supporting the initiative were obtained through false statements, violating Idaho Code section 34-1815, and that the initiative violated the single-subject rule of the Idaho Constitution by proposing two distinct changes to election laws.The Idaho Supreme Court dismissed the Attorney General’s petition on procedural grounds. The court held that allegations of fraud in the signature-gathering process must first be adjudicated in the district court. The court emphasized that its original jurisdiction to issue writs of prohibition and mandamus is limited and that the Secretary of State has no clear legal duty to invalidate signatures based on alleged fraud without a prior judicial determination. The court also found that the Attorney General’s challenge to the initiative on the grounds that it violated the single-subject rule was not ripe for review, as the initiative had not yet been approved by voters.The Idaho Supreme Court concluded that the Secretary of State’s role in the initiative process is ministerial and does not include adjudicating the validity of signatures based on alleged misrepresentations. The court dismissed the petition, allowing the initiative to proceed to the ballot, but noted that the Attorney General could pursue his claims in the appropriate district court. View "Labrador v. Idahoans for Open Primaries" on Justia Law

This case involves a dispute over the sale of surplus state property owned by the Idaho Transportation Department (ITD). The property, located at 3311 West State Street in Boise, was declared surplus after a flood rendered its largest building unusable. The Idaho Department of Administration (DOA) initiated a bidding process, and the petitioners, a group of business entities, submitted the highest bid. Despite negotiating a purchase and sale agreement, the DOA did not finalize the sale due to legislative actions that revoked its authority to dispose of the property and transferred control back to the ITD Board.The petitioners filed an original action in the Idaho Supreme Court seeking writs of prohibition and mandate. They argued that the legislative provisions revoking the DOA's authority were unconstitutional, violating the single-subject rule of the Idaho Constitution. They sought a declaratory judgment to invalidate these provisions and compel the DOA to complete the sale. The Idaho House of Representatives and its Speaker intervened, and the State Board of Examiners disclaimed further participation, having fulfilled its statutory duties.The Idaho Supreme Court held that the petitioners lacked standing to bring the action. The court found that while the petitioners demonstrated a distinct and palpable injury from the halted sale, they failed to show that a favorable decision would redress their injury. The court noted that the petitioners did not have a legally enforceable right to purchase the property, as the DOA had discretion in concluding the sale. Additionally, the court determined that the petitioners did not meet the criteria for relaxed standing, as other parties, such as the DOA and ITD, could potentially bring the constitutional claim. Consequently, the court dismissed the petition for writs of prohibition and mandate. View "Hawkins Companies, LLC v. State" on Justia Law