Justia Government & Administrative Law Opinion Summaries

Articles Posted in Idaho Supreme Court - Civil
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In this case, the Idaho State Athletic Commission and the Idaho Division of Occupational and Professional Licenses sought a declaratory ruling that provisions of the Idaho Administrative Procedure Act (APA) requiring legislative approval of pending administrative fee rules violated the Idaho Constitution. They also sought a Writ of Mandamus directing the Office of the Administrative Rules Coordinator to publish the Athletic Commission’s 2022 administrative rules in the Idaho Administrative Code. The Idaho Supreme Court held that it had jurisdiction to consider the case, but dismissed the petition for a declaration of unconstitutionality and denied the petition for a Writ of Mandamus. The court concluded that the APA requirement for legislative approval of pending administrative rules did not violate the Idaho Constitution's separation of powers, enactment, presentment, or administrative rules provisions. In reaching this conclusion, the court emphasized that administrative rulemaking authority was a legislative delegation, not a constitutional power, and that the legislature was free to modify the process by which administrative rules were enacted. View "Idaho State Athletic Commission v. Office of the Administrative Rules Coordinator" on Justia Law

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The Supreme Court of the State of Idaho held that the Director of the Idaho Department of Water Resources (IDWR) had the authority under Idaho Code section 42-237a.g. to initiate administrative proceedings to curtail the withdrawal of water from any well during any period where water to fill a water right in said well was not available. The proceedings stemmed from a district court decision involving the adjudication of water rights in the Wood River Valley during an unprecedented drought in 2021. The Director of the IDWR initiated an administrative proceeding to determine whether water was available to fill junior groundwater rights in the aquifer beneath the Bellevue Triangle. After a six-day hearing, the Director issued a Final Order that found water was unavailable to fill the junior rights because pumping from the aquifer was affecting the use of senior surface water rights. The South Valley Ground Water District and Galena Ground Water District challenged the Director's authority to initiate proceedings under Idaho Code section 42-237a.g., arguing that the Director did not comply with the prior appropriation doctrine because the Director had not formally designated an area of common groundwater supply, or determined "material injury" had been sustained by senior surface water rights holders. The Court affirmed in part and reversed in part, ruling that the Director had the authority to initiate administrative proceedings under Idaho Code section 42-237a.g. and that the Director did not violate the prior appropriation doctrine. It held that the Director had the discretion to limit or prohibit the withdrawal of groundwater from any well during any period when water was not available to fill a water right in said well, and was not required to establish an area of common groundwater supply before he is allowed to curtail groundwater pumping. The Court also held that the Director's decision to reject the proposed mitigation plan without a hearing was not properly before the Court on appeal. View "South Valley Ground Water v. Idaho Dept of Water Resources" on Justia Law

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The Supreme Court of the State of Idaho ruled on a dispute between TCR, LLC, a developer, and Teton County. The developer had sought to record a condominium plat for a planned unit development, but the County refused to do so, arguing that the developer had not submitted final site plans, architectural designs, or landscape drawings for review. The developer filed suit, alleging breach of contract and seeking declaratory and injunctive relief to compel the County to record the condominium plat. The district court granted the developer's motion for summary judgment on its declaratory and injunctive relief claim and denied the County's motion for summary judgment on the same claim. The court also denied all motions to reconsider. The Supreme Court of Idaho affirmed the district court's decision in part, reversed in part, and remanded for further proceedings. The court held that the County's refusal to record the condominium plat violated the Idaho Condominium Property Act and that the County did not have a valid reason for its refusal. The court also found that the district court erred in granting summary judgment to the County on the developer's breach of contract claim, concluding that genuine issues of material fact remained. The case was remanded for further proceedings. View "TCR, LLC v. Teton County" on Justia Law

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The Supreme Court of the State of Idaho affirmed the lower court's judgment dismissing a negligence claim filed by GSN Capital, LLC and Dave Zortman against the Shoshone City & Rural Fire District. GSN's sawmill property was destroyed by a wildfire, and they argued that the Fire District was negligent in not calling for additional aid, not deploying fire units to protect their property, and not performing a mitigation and salvage operation to save part of their property. However, the court concluded that the Fire District did not owe GSN a duty in tort for any of the challenged decisions. The court found that the Fire District did not have custody or control over GSN's property and did not owe a duty to protect individual properties within its territory. The court also held that the Fire District did not undertake any firefighting efforts for GSN until after the fire was contained, and thus did not assume a duty to GSN. View "GSN Capital, LLC v. Shoshone City & Rural Fire District" on Justia Law

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In the case before the Supreme Court of Idaho, Michael W. Skehan appealed a decision affirming the Idaho Central Sex Offender Registry's ruling that he must register as a sex offender in Idaho. Skehan had been convicted of sexual abuse in the third degree in Oregon in 2001 and later moved to Idaho. He argued that the procedures used by the Registry were improper and that he should not be required to register.The court affirmed the lower court's decision, holding that Skehan failed to demonstrate that the Registry's ruling was deficient under Idaho Code section 67-5279(3). The court also found that Skehan failed to preserve several arguments for appeal, offered little rebuttal to the Registry's position, and did not provide a sufficient record to substantiate his claims on appeal.The court also held that Skehan failed to demonstrate that the Registry's consideration of other information in addition to the Oregon and Idaho statutes was arbitrary and capricious. Additionally, the court found that the Registry did not abuse its discretion by not considering whether his Oregon conviction was a misdemeanor or felony. Lastly, the court concluded that the Registry was not required to compare Skehan’s Oregon conviction to Idaho offenses that do not require registration.The Registry was awarded its reasonable attorney fees pursuant to Idaho Code section 12-117. View "Skehan v. ISP" on Justia Law

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Amy Shumway was employed as a receptionist at Evans Chiropractic in Idaho. Her employment was terminated by Dr. John Hitchcock, one of the owners, for insubordination. Following her termination, Shumway applied for unemployment benefits. Her application was initially approved by an Appeals Examiner from the Idaho Department of Labor (IDOL) who found Shumway eligible for benefits despite her termination for insubordination. On appeal by Evans Chiropractic, the Industrial Commission affirmed the decision, but on different grounds. Evans Chiropractic then appealed to the Supreme Court of the State of Idaho.In the Supreme Court, Evans Chiropractic argued that Shumway should not be eligible for benefits because her employment was terminated for job-related misconduct, namely her refusal to meet with Dr. Hitchcock for discussions about her behavior at work. The Supreme Court agreed, finding that the Commission erred in its application of the law. The Court noted that the Commission had focused on Shumway's subjective reasons for not meeting with Hitchcock, rather than the employer's expectations. The Court found that Hitchcock directly communicated his expectation for Shumway to meet with him and that her refusal to do so constituted insubordination, which is a form of job-related misconduct. Therefore, the Supreme Court reversed the Commission’s decision and held that Shumway was ineligible for unemployment benefits as a matter of law. View "Shumway v. IDOL" on Justia Law

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In the State of Idaho, Yellowstone Log Homes, LLC ("Yellowstone") owned a rental property in the City of Rigby that was extensively damaged after BorTek Utilities and Construction, LLC bored through a lateral sewer line connected to the rental property. The City of Rigby had failed to mark the service lateral sewer pipe connected to the rental property prior to the excavation. Yellowstone sued the City of Rigby for both negligence per se and common law negligence for failing to mark the service lateral. The district court granted summary judgment in favor of the City of Rigby, determining that Yellowstone did not have standing under the Idaho Underground Facilities Damage Prevention Act, and even if it did, it failed to prove the City breached any duty owed to it.The Supreme Court of Idaho reversed the district court's grant of summary judgment to the City of Rigby. The court found that while the Act does not explicitly provide a private right of action for "end users" like Yellowstone, it does impose a duty on the City to mark underground sewer lines in a public right-of-way, which it did not do. The court also held that whether the City breached this duty by failing to maintain records of the location of service laterals, failing to adequately mark service laterals, or failing to take other precautions to protect customers’ service laterals within the public right of way are questions of fact for a jury to decide. Thus, the court concluded that the City of Rigby owed Yellowstone a duty to act as a reasonable manager of its property under the circumstances. View "Yellowstone Log Homes, LLC v. City of Rigby" on Justia Law

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The Idaho Supreme Court ruled in favor of the Idaho State Appellate Public Defender (SAPD) in a case involving the SAPD's statutory duty to arrange for substitute counsel for indigent defendants when a conflict of interest arises. The SAPD filed a direct action against the Fourth Judicial District Court, alleging that the court infringed on the SAPD’s statutory duty to arrange a new attorney for a defendant named Azad Abdullah. The SAPD had identified a conflict of interest in its own office and tried to substitute an attorney from Pennsylvania, but the district court refused the substitution and appointed a new attorney of its own choosing. The Idaho Supreme Court held that the district court had obstructed the SAPD's statutory duty and authority under Idaho Code section 19-5906. The Court ordered the district court's decisions to be vacated, restored the SAPD as attorney of record for the limited purpose of arranging for substitute counsel, and ordered the appointment of a new district judge to preside over Abdullah’s post-conviction proceeding. View "SAPD v. Fourth Judicial District" on Justia Law

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The parents in this case were brought to the attention of the Idaho Department of Health and Welfare ("Department") regarding reports of neglect and physical abuse to their five children. The child protection case began in February 2023 as a protective supervision case. Nearly three months later, the magistrate court ordered that the children be removed from the home and placed in the legal custody of the Department. John Doe (Father) appealed the magistrate court’s order removing his five children from the parents’ custody and temporarily placing the children in the legal custody of the Department. Father argued the magistrate court’s order failed to contain detailed written findings as required by Idaho law, that the order was not supported by substantial and competent evidence, and that the magistrate court’s actions violated Father’s fundamental rights to the care and custody of his children. Finding no reversible error, the Idaho Supreme Court affirmed the magistrate court. View "IDHW v. John Doe" on Justia Law

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Moranda Morley lost one of her two jobs due to the economic impact of the COVID-19 pandemic in March 2020. Morley applied for and received state unemployment compensation benefits and federal pandemic unemployment assistance through the Idaho Department of Labor. However, it was later determined that Morley was ineligible for benefits because she was still employed full-time at her other job. Morley appealed that determination to the Appeals Bureau of the Idaho Department of Labor, which affirmed her ineligibility. Morley then appealed to the Idaho Industrial Commission (“the Commission”), which dismissed Morley’s initial appeal and later denied her request for reconsideration, finding both to be untimely. Morley then appealed to the Idaho Supreme Court, but her notice of appeal was timely only as to the denial of her request for reconsideration. Thereafter, the Supreme Court issued an order dismissing the appeal as to the issues that were determined to be untimely. What remains was a limited review of whether the Commission properly denied her request for reconsideration. Finding no reversible error, the Supreme Court affirmed the Commission’s denial of reconsideration. View "Morley v. IDOL" on Justia Law