Justia Government & Administrative Law Opinion Summaries

Benjamin Morris appealed an order of the Idaho Industrial Commission that denied his motion to set aside a lump sum settlement agreement he made with his employer's surety, Liberty Northwest Insurance. Morris initiated his workers' compensation action after he suffered injuries while working construction for his employer, Hap Taylor & Sons, Inc. Morris sustained a serious head injury on when a twenty-five pound rock thrown by a piece of heavy machinery struck him in the head. Morris initiated settlement discussions with Liberty Northwest Insurance, Hap Taylor & Sons' insurer. Liberty responded with a counter-offer—a single lump sum payment which Morris accepted "with the clear understanding this is a partial settlement and does not resolve the medical side." The parties executed a Stipulation and Agreement of Partial Lump Sum Discharge (LSSA) and submitted it to the Commission for approval. Approximately eighteen months later, on July 8, 2011, a Notice of Appearance was filed with the Commission whereby Morris substituted attorney Michael Walker with his then present counsel, attorney Starr Kelso. On the same day, Morris filed a motion to review the LSSA, accompanied by an affidavit signed by Kelso. Kelso's affidavit expressed concern that Morris may not have been "competent to testify" due to his injury—though, no credible evidence of incompetence was ever offered. Liberty filed an objection to Morris' motion to review. Ultimately, the Commission denied Morris' motion. Following the Commission's refusal to review the LSSA, Morris filed a Motion to Set Aside Lump Sum Settlement Agreement, seeking to void the LSSA on grounds of illegality and constructive fraud. The Commission issued an order denying Morris' motion to set the LSSA. Morris filed a timely appeal to the Supreme Court. After its review, the Supreme Court concluded that the Commission did not err in denying Morris' request for a hearing on his fraud claim. Furthermore, the Court affirmed the Commission's decision to deny Morris' motion to set the LSSA. View "Morris v. Hap Taylor & Sons" on Justia Law

At issue before the Supreme Court in this case was appeal and cross-appeal of summary judgments dismissing claims against Defendants Ada County, Deputy Jeremy Wroblewski, Kate Pape, and James Johnson in a 42 U.S.C. 1983 civil rights action brought by Rita Hoagland on behalf of herself and the estate of her deceased son, Bradley Munroe ("Munroe"), claiming a violation of a Fourteenth Amendment right to medical care and safety while Munroe was detained at Ada County Jail where he committed suicide. Munroe had a history of incarceration at Ada County Jail ("ACJ"). During the evening of September 28, 2008, Munroe was arrested and charged with the armed robbery of a convenience store. Munroe was intoxicated and uncooperative. During booking, Munroe was screaming and being rowdy. Munroe took a string and wrapped it around his neck. Because of his bizarre behavior throughout the night, Munroe was placed in a holding cell for observation until he was sober. The next morning booking continued. At that time, Munroe requested protective custody. Munroe was placed in a cell by himself and a well-being check was scheduled to occur every thirty minutes. Later that evening during a well-being check, the performing deputy found Munroe hanging from his top bunk by a bed sheet. Munroe was pronounced dead later that evening. Among the issues on appeal were: whether the decedent's estate could assert a 42 U.S.C 1983 action for alleged violations of the decedent's constitutional rights; whether the parent had standing to assert a 42 U.S.C. 1983 action for the death of her adult child while incarcerated; and whether the district court erred in awarding costs to Defendants. Upon review, the Supreme Court concluded that the district court: (1) was affirmed in dismissing Hoagland's 1983 claim on behalf of Munroe's estate; (2) was reversed in finding that Hoagland had a 1983 cause of action for violations of her own constitutional rights; (3) was partially affirmed in its award of costs as a matter of right; (4) was reversed in its award of discretionary costs; and (5) was affirmed in denying attorney fees. The case was remanded for the reconsideration and entry of express findings regarding the district court's award of discretionary costs. View "Hoagland v. Ada County" on Justia Law

In 2011, Gordon Ravenscroft filed a Petition for Judicial Review against Boise County, its Board of Commissioners, and other individual defendants. The petition sought review of the Board's final decision terminating Ravenscroft's employment. The petition claimed Ravenscroft was denied his constitutional right to due process, the board acted outside the bounds of its authority, and his firing was arbitrary, capricious, and an abuse of discretion. In response, the Board filed a motion to dismiss arguing that the district court was without jurisdiction to hear an appeal of a county personnel determination. The district court determined that it had jurisdiction over the Board's decision to terminate Ravenscroft because the decision was an "action" under I.C. 31-1506. The Board then sought permission to appeal this decision, which the district court granted. The question in this case is whether the Board's decision to terminate Ravenscroft is subject to the judicial review provisions of the Idaho Administrative Procedure Act [IAPA]. The IAPA and its judicial review provisions do not apply to the actions of local governing bodies, unless expressly authorized by statute. The Supreme Court concluded that the Board's decision to terminate Ravenscroft was an "Act" under I.C. 31-1506, and that his at-will status did not change the scope of Ravenscroft's claim. "If the employment is at will, judicial review will not enable the court to change it to employment terminable only for cause." The Court affirmed the district court's determination that the Board's decision to terminate Ravenscroft was an action under 31-1506. View "Ravenscroft v. Boise County" on Justia Law

Petitioner Peter Kaseburg was a littoral owner on Lake Pend Oreille who held an encroachment permit for a series of decaying wooden pilings that were driven into the lakebed in the 1930s. With the exception of a single piling that a neighboring marina uses to anchor one of its docks, the pilings never had any known navigational purpose. Petitioner applied to the Idaho Department of Lands (IDL) for a permit to replace ten of the wooden pilings with steel pilings, but failed to specify any navigational purpose for this proposal. The IDL considered the application a request for a nonnavigational encroachment permit and denied it after receiving several objections. While a final decision was still pending on the first permit application, Petitioner filed a second application for a permit to install a mobile dock system and mooring buoy. The IDL considered the second application a request for a permit for a navigational encroachment extending beyond the line of navigability. Again, the IDL received many objections and denied the application. Petitioner then sought judicial review, which reversed the IDL. The court held that all pilings were navigational encroachments as a matter of law, regardless of whether they have ever been used to aid navigation. The district court set aside both denials. The IDL appealed to the Supreme Court. Upon review, the Supreme Court reversed the district court with respect to the first application, but affirmed the district court with respect to the second. View "Idaho Bd of Land Comm v. Kaseburg" on Justia Law

Appellant Matthew Mazzone appealed an Idaho Industrial Commission's order that denied him workers' compensation for psychological injuries allegedly arising as a result of an industrial accident wherein appellant tripped and fell into a deep fat fryer while employed at Texas Roadhouse. Appellant contended the Commission’s order was not based on substantial and competent evidence. During his time at a Burn Center, appellant was twice noted in medical records to be exhibiting exaggerated pain behaviors. At one point during his treatment, appellant stayed at a hotel in Salt Lake City so as to receive follow-up care. In a follow-up at the Burn Center, appellant had quit "cold turkey" his opioid medication, at which point he began to experience nightmares and flashbacks. Appellant was referred to an Idaho psychiatrist. The Idaho psychiatrist clarified that appellant's nightmares and anxiety were related to returning to work; appellant was assessed a GAF score of 55/85, the same assessment he had before the industrial accident. Three months after accident, appellant returned to work, but he was allegedly so overwhelmed that he asked to transfer to another Texas Roadhouse location in Massachusetts because he was nervous, sick, worried, and nauseous working at the site of the accident. Subsequent years following the accident, appellant sought additional counseling and medical treatment. He was eventually diagnosed with post-traumatic stress disorder (PTSD) and general anxiety and memory loss. Appellant then filed a complaint against Texas Roadhouse and its insurer. Upon review, the Supreme Court concluded that appellant did not suffer a compensable psychological injury, and that the evidence presented was substantial enough to support the Industrial Commission's order. View "Mazzone v. Texas Roadhouse" on Justia Law

This appeal stemmed from a protracted contract dispute arising out of the construction of Meridian’s new City Hall. The City brought suit against the project’s construction manager, Petra, Inc., alleging that Petra breached the parties’ agreement in a number of ways. The City further claimed that Petra was not entitled to any additional fees for its work. Petra counterclaimed, seeking an equitable adjustment of its construction manager fee. After trial, the district court entered its findings of fact and conclusions of law, ruling against the City on all but one of its claims and awarding Petra an additional fee for its services. The court awarded Petra $595,896.17 in costs and $1,275,416.50 in attorney fees, but stayed enforcement of the judgment pending appeal. The City appealed. Finding no error in the district court's judgment in favor of Petra, the Supreme Court affirmed. View "City of Meridian v. PETRA Inc." on Justia Law

Plaintiff-Appellant Brian Woodworth brought suit against the State and the City of Nampa to recover damages for injuries he sustained while pushing a shopping cart across a state highway. Both defendants moved for summary judgment. Following a motion hearing, the court granted both motions. The district court granted summary judgment in favor of the State on two separate grounds: (1) the State was entitled to immunity from suit; and (2) regardless of immunity, the court found that Woodworth failed to raise a genuine issue of material fact that the State acted negligently. Following the summary judgment ruling, Woodworth reached a settlement with Nampa whereby the City was dismissed from the case. Woodworth filed an appeal with regard to the court’s dismissal of his claim against the State. Upon review of the district court record, the Supreme Court concluded that the district court correctly applied the immunity test as outlined in applicable precedent. Because Woodworth failed to present a viable negligence claim against the State, the Court affirmed the district court's judgment. View "Woodworth v. Idaho Transportation Bd" on Justia Law

In 2008, the legislature enacted legislation to establish the Idaho Education Network (IEN), which was to be a high-bandwidth telecommunications distribution system for distance learning in every public school in the state. Syringa Networks, LLC (Syringa), an Idaho telecommunications company, entered into a “teaming agreement” with ENA Services, LLC (ENA). Pursuant to their agreement, ENA submitted a proposal in response to a request-for-proposals (RFP) with the Department of Administration, although the cover letter stated that both ENA and Syringa were responding jointly to the proposal. Qwest Communications Company, LLC, and Verizon Business Network Services, Inc., also submitted responsive proposals. The proposals were then scored based upon specific criteria; the ENA and Qwest proposals received the highest scores. The Department issued a letter of intent to award contracts to Qwest and ENA. One month later, it issued amendments to the two purchase orders to alter the scope of work that each would perform. Qwest became "the general contractor for all IEN technical network services" (providing the “backbone”) and ENA became "the Service Provider." The effect of these amendments was to make Qwest the exclusive provider of the backbone, which was what Syringa intended to provide as a subcontractor of ENA. Syringa filed this lawsuit against the Department, its director, the chief technology officer, ENA and Qwest. The district court ultimately dismissed Syringa’s lawsuit against all of the Defendants on their respective motions for summary judgment. Syringa then appealed the grants of summary judgment, and the State Defendants cross-appealed the refusal to award them attorney fees. Upon review, the Supreme Court affirmed the judgment dismissing all counts of the complaint except count three seeking to set aside the State's contract with Qwest on the ground that it was awarded in violation of the applicable statutes. Furthermore, the Court reversed Qwest’s award of attorney fees against Syringa. We remand to the trial court the determination of whether any of the State Defendants were entitled to an award of attorney fees against Syringa for proceedings in the district court. The Court awarded costs and attorney fees on appeal to ENA. Because the State Defendants and Syringa both prevailed only in part on appeal, the Court did not award them either costs or attorney fees on appeal. View "Syringa Networks v. Idaho Dept of Admin" on Justia Law

This was an appeal of an order setting aside a sheriff's sale of real property. The respondents, Earline Chance and Leon Phillips who were deed of trust beneficiaries and judgment creditors, failed to attend or bid at the sheriff's sale but claimed the successful bidder, appellant Roy Jacobson, obtained the property for a grossly inadequate price. The district court agreed and set the sale aside. Upon review, the Supreme Court found that the district court indeed erred in setting aside the sheriff's sale, and reversed. View "Phillips v. Jacobson" on Justia Law

Appellant Altrua HealthShare appealed the district court's decision affirming the Idaho Department of Insurance's (Department) determination that Altrua transacted insurance without a certificate of authority. Altrua argued that both the Department and the Ada County district court erred in finding that Altrua was an insurer because Altrua never assumed the risk of paying its members' medical bills. The Department found, and the district court affirmed, that when members make their predetermined monthly payments into the escrow account Altrua operates, the risk of payment shifts from the individual members to the escrow account, and in turn to Altrua. Altrua also contended that the Department's determination that it is an insurer despite the disclaimers in its membership contract to the contrary is an unconstitutional interference with Altrua's right to contract. Upon review, the Supreme Court found that the Department's conclusion that Altrua's membership contract was an insurance contract was clearly erroneous, and reversed the findings. The case was remanded for further proceedings. View "Altrua Healthshare v. Deal" on Justia Law