Articles Posted in Idaho Supreme Court - Civil

The City of Idaho Falls (“Idaho Falls”) appealed an order dismissing its breach of contract and waste claims against H-K Contractors, Inc. (“H-K”). In 2005, H-K entered into a written contract requiring it to convey a parcel of property to Idaho Falls. The contract required that H-K initially grant Idaho Falls a storm drainage easement “over and across” the parcel. H-K was also required to convey fee title to the parcel at a future date, in no event later than March 1, 2010. H-K failed to convey the property to Idaho Falls as required. In 2016, Idaho Falls sent a letter to H-K requesting conveyance of title. H-K responded by refusing to convey title to the property, claiming that in 2009 a city official had orally informed H-K that Idaho Falls was no longer interested in the property. Based on that alleged representation, H-K decided to invest in the property to make it profitable. Idaho Falls filed a complaint against H-K for breach of contract and waste. H-K moved to dismiss the complaint based on the limitation found in Idaho Code section 5-216, alleging Idaho Falls’ claims were time barred because they were not brought within the five-year statute of limitations governing contract actions. Idaho Falls countered that the statute of limitations did not apply to it as a subdivision of the State of Idaho. On January 3, 2017, the district court dismissed Idaho Falls’ complaint as time barred. Idaho Falls timely appealed, claiming the district court erred in enforcing the five-year limitation set forth in section 5-216. The Idaho Supreme Court vacated the district court's judgment, finding it erred when it determined the term “state” in Idaho Code section 5- 216 did not include Idaho’s municipalities. Because Idaho Falls was the “state,” the district court erred when it found its contract claims against H-K were not “for the benefit of the state.” View "City of Idaho Falls v. H-K Contractors" on Justia Law

The Idaho Supreme Court reversed the magistrate court in an expedited appeal regarding the termination of John Doe (2017-32)'s parental rights. John Doe is the father of minor children KB and AB (the “Children”). The Children entered the Idaho Department of Health and Welfare’s (“IDHW”) custody in December 2014 after the Twin Falls Police declared them to be in imminent danger. The Children were in their mother’s (“Mother”) care when the police arrested her for possession of a controlled substance. Law enforcement described the condition of Mother’s home at this time as “filthy, cluttered, and containing numerous safety hazards, including raw sewage being present in the basement.” An Idaho Department of Health and Welfare (IDHW) case plan, filed January 2015, included number of enumerated tasks for both Doe and Mother to complete in order for them to reunite with the Children. The case plan sought to provide Doe and Mother a framework to address “stable housing, sanitary living conditions, the need to obtain controlled substance abuse treatment, to remain clean/sober, and [to] stay out of jail.” Mother relapsed within weeks of a December 2016 order and was arrested for felony possession, kicked out of Drug Court, and went to prison. IDHW sought to terminate Doe and Mother’s parental rights. Doe had not completed his required drug treatment regimen by a first trial, he became more actively involved in his treatment plan by the time of a second trial. Doe showed other encouraging signs between the first and second trial as well, including significant progress on his case plan. However, the magistrate court noted that, despite progress, Doe still had not completed his case plan nor reunified with his children in the intervening period between the first and second trial. The court issued a Memorandum Decision granting termination of Doe and Mother’s parental rights on October 2, 2017, and entered a corresponding judgment ten days later on October 12, 2017. Mother did not appeal, but Doe timely filed his notice of appeal. The Supreme Court found the magistrate court’s December 2016 order stating that termination was not in the Children’s best interest was irreconcilable with IDHW’s first official recommendation following that order that termination “remains” in the Children’s best interest. The magistrate court’s October 2017 decision following the second trial highlighted Doe’s failure to reunify with the Children as a substantial factor in his ultimate decision to terminate. The magistrate court’s procedural error in not entering judgment for Doe and dismissing the petition upon finding that termination was not in the Children’s best interest affected Doe’s fundamental rights in this case. View "Dept. of Health & Welfare v. John Doe (2017-32)" on Justia Law

The issue this case presented for the Idaho Supreme Court’s review centered on whether and to what extent an uphill landowner could send irrigation wastewater across a downhill landowner’s property. This case began when Lemhi County filed suit against the owners of both ranches seeking to relieve flooding along one of its roads. Phillip Moulton owned and operated a ranch that was on higher ground than the adjacent ranch that Verdell Olson operated. Surface and irrigation water that began on Moulton’s ranch made its way to the Lemhi River through various channels. The one at issue in this case was a steep draw that sent water across a county road and through the downhill ranch that Olson operated. Lemhi County reached a settlement with Olson, and the remaining issue for the district court was whether an easement or a natural servitude permitted Moulton to send water down the draw. The district court held that both an easement and natural servitude permit Moulton to send up to 3.25 cubic feet per second of water down the draw. Olson appealed. The Supreme Court affirmed the district court to the extent it provided for an easement and natural servitude, but remanded for specification of the location of the drainage basin on Olson’s property. View "Olson v. Moulton" on Justia Law

John Doe (2017-27) (“the father”) and Jane Doe (2017-27) (“the mother”) appealed magistrate court judgments terminating their parental rights to their daughters (“Z.W.” and “N.W.”). The magistrate court terminated the mother and father’s parental rights on the grounds of neglect, abuse, inability to discharge parental responsibilities, and chronic abuse and/or neglect, and also found termination was in the best interest of the children. The mother only challenged the termination of her parental rights as to N.W., while the father challenged the termination of his parental rights as to both of the children. The sole issue the father argued on appeal was that the magistrate court did not have substantial and competent evidence to find terminating his parental rights was in the best interest of both children. Finding no abuse of discretion in judgments against either parent, the Idaho Supreme Court affirmed the magistrate court. View "Idaho Dept. of Health & Welfare v. John & Jane Doe" on Justia Law

Charles Hartgrave appealed an Idaho Industrial Commission (the Commission) order. Hartgrave sustained injuries to his left knee while working for the City of Twin Falls (the City) on February 3, 2009, and August 23, 2012. Although Hartgrave’s left knee injuries and corresponding treatments were covered by Idaho’s Workers Compensation Act, Hartgrave argued the left knee injuries aggravated preexisting degenerative joint disease in his right knee and ultimately required a total knee arthroplasty (TKA) in his right knee. The Commission rejected Hartgrave’s position and ruled that Hartgrave’s right TKA was not compensable. Finding no reversible error in the Commission's order, the Idaho Supreme Court affirmed. View "Hartgrave v. City of Twin Falls" on Justia Law

Gary and Glenna Eden sought to file a late notice of claim for their Water Right No. 37-864 which was not claimed during the pendency of the Snake River Basin Adjudication (“SRBA”), and therefore was decreed disallowed. In the SRBA, the Edens alleged that the SRBA’s Final Unified Decree and the Closure Order should have been set aside as void because they did not receive sufficient notice of the SRBA proceedings to satisfy due process. Further, the Edens argued they were not personally served with the required notice of default pursuant to Idaho Rule of Civil Procedure 55(b)(2). Furthermore, the Edens claimed that unique and compelling circumstances justify relief from the final judgment under Idaho Rule of Civil Procedure 60(b)(6). The SRBA court disagreed and denied the Edens’ relief on any of these grounds. Finding no reversible error in the SRBA court's judgment, the Idaho Supreme Court affirmed. View "Eden v. Idaho" on Justia Law

Gary and Glenna Eden sought to file a late notice of claim for their Water Right No. 37-864 which was not claimed during the pendency of the Snake River Basin Adjudication (“SRBA”), and therefore was decreed disallowed. In the SRBA, the Edens alleged that the SRBA’s Final Unified Decree and the Closure Order should have been set aside as void because they did not receive sufficient notice of the SRBA proceedings to satisfy due process. Further, the Edens argued they were not personally served with the required notice of default pursuant to Idaho Rule of Civil Procedure 55(b)(2). Furthermore, the Edens claimed that unique and compelling circumstances justify relief from the final judgment under Idaho Rule of Civil Procedure 60(b)(6). The SRBA court disagreed and denied the Edens’ relief on any of these grounds. Finding no reversible error in the SRBA court's judgment, the Idaho Supreme Court affirmed. View "Eden v. Idaho" on Justia Law

Jane Doe (Mother) appealed a magistrate court’s termination of her parental rights to her minor child, A.L. (Child). The Idaho Department of Health and Welfare (IDHW) filed a petition to terminate Mother’s parental rights to Child on August 26, 2016, and an amended petition on June 30, 2017. After a two-day trial, the magistrate court found termination proper on several bases of neglect and entered an order to that effect. On appeal, Mother argued the magistrate court’s decision was not based on substantial, competent evidence, and that termination was in the child’s best interests. Finding no reversible error, the Idaho Supreme Court affirmed the magistrate court’s judgment. View "IDHW v. Doe (2017-36)" on Justia Law

The Idaho Supreme Court answered a certified question of Idaho law from the United States District Court for the District of Idaho. The question certified centered on whether, for purposes of the dispute in this lawsuit, the terms ‘state board of correction’ as used in Idaho Code 20-237B(1) and ‘department of correction’ as used in Idaho Code § 20-237B(2), included privatized correctional medical providers under contract with the Idaho Department of Correction. The Court answered the question certified in the negative. View "In Re: Pocatello Hospital, LLC v. Corazon, LLC" on Justia Law

This water rights appeal stemmed from two consolidated subcases, litigated in the Snake River Basin Adjudication (SRBA). The subcases concerned the United States’ late claims (Late Claims) filed in January 2013, which asserted “supplemental beneficial use storage water rights” claims under the constitutional method of appropriation to store water in priority after flood-control releases. The special master recommended that the State’s motion for summary judgment be granted, concluding the Late Claims should be disallowed because, as the Director of the Idaho Department of Water Resources (Director) recommended, the Late Claims asserted rights that had not been claimed when the underlying water rights were adjudicated and decreed. Alternatively, the special master concluded the Late Claims should be disallowed because, as intervenor Black Canyon Irrigation District (BCID) asserted, the decreed water rights already authorized the rights the Late Claims were asserting, thus, unnecessary. The district court agreed with the special master insofar as the Late Claims were precluded. However, the district court rejected the special master’s alternative recommendation that the Late Claims were duplicative of the rights already decreed and unnecessary. The district court entered judgment reflecting these conclusions. BCID timely appeals and the Idaho Supreme Court affirm the district court’s conclusion the special master exceeded the district court’s orders of reference by making the “alternative basis” recommendation. View "Black Canyon Irrig Dist v. State / Suez Water" on Justia Law