Justia Government & Administrative Law Opinion Summaries

In 2016, St. Luke’s Health System, Ltd. accepted an indigent patient suffering from meningitis, seizures, and brain lesions. The patient was ready for transfer to another medical facility by February 18, 2016, but was refused by multiple care providers because they did not want to admit an indigent patient without a payor source. St. Luke’s finally contracted with Life Care, another medical facility, to take the patient on the condition that St. Luke’s would guarantee payment for a thirty day period. The patient was transferred to Life Care on March 9, 2016. St. Luke’s applied for medical indigency benefits covering the period of time from the patient’s initial hospitalization until she was transferred to the Life Care facility. Gem County initially approved the application for benefits through February 3, 2016. St. Luke’s appealed that determination, and after a hearing, the Board approved medical indigency benefits from January 26, 2016, until February 18, 2016. The Board entered a written determination titled “Amended Determination of Approval for County Assistance” which set forth the various bills that were approved for payment, but did not in any way reflect the denial of benefits or the reasoning of the Board. St. Luke’s then sought judicial review of the Amended Determination before the district court, which affirmed the Board’s decision. St. Luke’s appealed. The Idaho Supreme Court vacated the Board’s Amended Determination because it did not reflect the partial denial of benefits and because there were no findings of fact or conclusions of law setting forth the basis for the Board’s denial. View "St. Lukes v. Bd of Commissioners of Gem Co" on Justia Law

This appeal stemmed from a dispute between SilverWing at Sandpoint, LLC (“SilverWing”) and Appellant Bonner County, Idaho (the “County”). SilverWing sought to develop a residential hangar and taxiway adjacent to the Sandpoint Airport for residents who wished to park their aircraft in their home garage. SilverWing alleged that “[i]n 2007, the County provided to SilverWing an ALP that reflected the existing location of the Airport’s runway, and made no mention or reference to any plans for the runway to be moved. At the same time, the County promised that there were no plans regarding changes to runway location which would be incompatible with SilverWing’s development.” During the initial stages of engineering for the development, the County informed SilverWing that it needed to move the taxiway from where it was originally planned onto County-owned airport property, to accord with the County’s Airport Layout Plan (ALP). SilverWing proceeded with its development based on the County’s assurances, and built a taxiway and other infrastructure, including streets, to support its development. Once the taxiway was built, SilverWing learned that the placement of the taxiway was not approved by the FAA. After several years of legal maneuvering, SilverWing proceeded against the County in court, ultimately on a theory of promissory estoppel. After trial, a jury returned a verdict in favor of SilverWing. The County filed a motion for judgment notwithstanding the verdict (“JNOV”), which the district court denied. The County appealed. The Idaho Supreme Court reversed the district court’s ruling on the JNOV and vacated its ruling regarding attorney fees. The Court determined the district court erred with respect to JNOV on the claim of promissory estoppel: "SilverWing actually got what it claims the County promised—an FAA approved taxiway in the location where SilverWing built it. SilverWing can now sell its development with no regulatory uncertainty." View "SilverWing v. Bonner County" on Justia Law

AmeriTel Inns, Inc. appealed an Idaho Industrial Commission decision granting Megan Keller unemployment benefits after her employment with AmeriTel ended in June 2017. AmeriTel asked the Idaho Supreme Court to adopt a bright line rule that a one-day absence without notice was a voluntary quit under Idaho Code section 72- 1366(5). In the event that the Court declined to do so, AmeriTel argued the Commission’s factual findings that rendered Keller eligible for unemployment compensation benefits were not supported by substantial and competent evidence. Finding no reversible error, the Idaho Supreme Court affirmed the Commission's decision. View "Keller v. Ameritel Inns; IDOL" on Justia Law

On November 20, 2018, the Acting Governor of Idaho issued a proclamation that Proposition 2 had passed, and subsequently the Idaho Code was amended to add section 56-267, a statute to expand Medicaid eligibility in Idaho. Petitioner Brent Regan argued 56-267 violated Idaho’s Constitution by delegating future lawmaking authority regarding Medicaid expansion to the federal government. Regan requested the Idaho Supreme Court declare section 56-267 unconstitutional and issue a writ of mandamus to direct the Secretary of State Lawerence Denney to remove section 56-267 from the Idaho Code. Finding the statute constitutional, the Supreme Court dismissed Regan’s petition and denied his request for a writ of mandamus. View "Regan v. Denney" on Justia Law

2M Company Inc. (“2M”) appealed an Industrial Commission (“Commission”) decision that determined Matthew Atkinson was entitled to reasonable medical benefits for injuries he sustained in an accident on his way to work. The Commission found that an exception to the “going and coming” rule applied based on 2M’s intent to compensate Atkinson for his travel time while going to or coming from work. 2M and its surety, Employer Assurance Company, appealed. Finding no reversible error, the Idaho Supreme Court affirmed the Commission's determination. View "Atkinson v. 2M Company, Inc." on Justia Law

This appeal arose out of an Ada County Board of Commissioners’ decision to direct issuance of a tax deed. The property owner, James Floyd, was incarcerated in the county jail throughout the proceedings, and alleged he never received official notice of the pending tax deed until a month before his hearing. Despite having his jail address on file, the County Treasurer delivered statutory notices to Floyd’s vacant home. However, she also sent Floyd letters at the jail apprising him of the tax deed proceedings and delinquent taxes owed. The Board of Commissioners determined that Floyd received sufficient due process, and directed the tax deed to issue. The district court affirmed, holding that Floyd had actual notice despite the Treasurer’s failure to comply with statutory notice requirements. The Idaho Supreme Court affirmed the district court’s determination because it found Floyd had actual notice of the pending tax deed. View "Floyd v. Bd of Ada County Commissioners" on Justia Law

This case was brought by the North Idaho Building Contractors Association, Termac Construction, Inc., and other class members (collectively, “NIBCA”), to declare a sewer connection/capitalization fee the City of Hayden enacted in 2007 to be an impermissible tax. The action was originally dismissed on the City’s motion for summary judgment; but, on appeal the Idaho Supreme Court vacated the district court's judgment and remanded for further proceedings because the record did not contain sufficient evidence to establish that the 2007 Cap Fee complied with controlling Idaho statutes and case law. On remand, the parties filed cross motions for summary judgment and the district court found that the 2007 Cap Fee was an impermissible tax and taking of property without just compensation in violation of federal takings law. In doing so, the district court refused to consider expert evidence propounded by the City which opined that the 2007 Cap Fee complied with the applicable Idaho legal standards and was reasonable. The district court subsequently ruled on stipulated facts that NIBCA was entitled to damages in the amount paid above $774 per connection, together with interest, costs, and attorney fees. The City appealed the district court’s refusal to consider its evidence and NIBCA cross-appealed the award of damages. The Idaho Supreme Court again vacated the judgment because the district court improperly refused to consider the City’s evidence on remand. View "No ID Bldg Cont Assoc v. City of Hayden" on Justia Law

Kiki Leslie Tidwell appealed an Idaho Public Utility Commission order denying her request for intervenor funding. The underlying administrative proceeding involved an application by the Idaho Power Company for a Certificate of Public Convenience and Necessity to construct a high-voltage electric transmission line in Blaine County. The Commission granted Tidwell’s petition to intervene in December 2016. In September 2017, Tidwell submitted a request for intervenor funding, which the Commission denied as untimely. Tidwell filed a petition for reconsideration, which the Commission also denied. Finding the Commission's denial of Tidwell's petition for reconsideration not "unreasonable, unlawful, erroneous or not in conformity with the law," the Idaho Supreme Court affirmed. View "Idaho Power and IPUC v. Tidwell" on Justia Law

Jane Doe (Mother) appealed a magistrate court judgment terminating her parental rights to her three minor children: PG, KG, and BG. Near the end of February 2017, Mother, who was thirty-five weeks pregnant with BG, went into preterm labor while in jail. She was transported to a hospital but did not have the baby at that time. While at the hospital, she tested positive for methamphetamines. Around that time, KG was hospitalized to receive treatment for Respiratory Syncytial Virus (RSV). Because Mother appeared to be under the influence of drugs when she visited KG in the hospital, the doctor called Child Protective Services over concerns that Mother could not adequately care for her child. After an investigation, the State of Idaho filed a petition to remove PG and KG from their home and they were placed into emergency shelter care on March 1, 2017. The children were three years old and one year old, respectively. BG was then born and placed in emergency shelter care on March 29, 2017, after testing positive for three kinds of opiates. Because Mother continued to use drugs, have other criminal issues, and made only minimal progress on her case plan after eight months, the State filed a petition to terminate her parental rights on November 28, 2017. Mother argued the magistrate court abused its discretion in determining that she neglected her children and that it was in the children’s best interest to terminate the parent-child relationship. Although Mother did not describe how the magistrate court abused its discretion or recite the abuse of discretion standard in her brief, the Idaho Supreme Court took her argument to be that substantial and competent evidence did not support the magistrate court’s findings. To this end, the Supreme Court disagreed and affirmed termination of her parental rights. View "DHW v. Jane Doe" on Justia Law

Val Westover filed this action seeking a declaration that the existence of the Idaho Counties Risk Management Program (ICRMP) violated Idaho law. This litigation followed an earlier dispute between Westover and Jase Cundick, the Franklin County, Idaho Assessor. That dispute came before the Idaho Supreme Court in which Westover advanced claims for slander of title and intentional interference with existing or potential economic relations and sought writs of mandate and prohibition. After Westover voluntarily dismissed the slander of title and tortious interference claims, the district court denied his requests for extraordinary writs and dismissed the action. Westover appealed and the Supreme Court affirmed the judgment of the district court and declined to award attorney fees to either party. Westover then brought this action, seeking a declaration that ICRMP’s existence and relationship with county governments violates the directive in Idaho Code section 12-117(3) that attorney fees awarded against a state agency or political subdivision “shall be paid from funds in the regular operating budget . . . .” ICRMP moved for summary judgment, contending that Westover lacked standing to pursue his claim. Finding no reversible error, the Supreme Court affirmed dismissal of Westover’s declaratory judgment action. View "Westover v. Idaho Counties Risk Mgmt" on Justia Law