Justia Government & Administrative Law Opinion Summaries

This appeal concerned a district court’s award of attorney fees to Burns Concrete, Inc., and Burns Holdings, LLC (collectively “Burns”). After extensive litigation, Burns prevailed on the merits of its claims and judgment was entered against Teton County, Idaho. The district court awarded Burns attorney fees pursuant to the parties’ development agreement. Both Burns and Teton County appealed, arguing the district court abused its discretion in awarding the fees. Burns argued the district court should have awarded more fees, while Teton County argued it should have denied the fees or awarded less fees. Finding no reversible error in the district court's award, the Idaho Supreme Court affirmed. View "Burns Concrete, Inc. v. Teton County" on Justia Law

In 2018, Terri Richardson Mattson (“Mattson”) and her husband filed this action against the Idaho Department of Health and Welfare, and its employee, Laurie Gallegos, a certified physician assistant (“Defendants”), alleging medical malpractice and failure to obtain informed consent related to outpatient mental health services Mattson received from Defendants. As a part of those services, Gallegos prescribed Mattson Prozac (fluoxetine), an antidepressant. Roughly one month later, the day of her follow up appointment with Gallegos, Mattson woke up, took a firearm from her gun cabinet, went to the liquor store, bought a bottle of vodka, drank the entire bottle while driving to her follow up appointment, and when she arrived in the Department’s parking lot, fired the gun into her head. Mattson survived but suffered extensive injuries. Subsequently, Mattson and her husband filed this action. The district court granted summary judgment to Defendants on two grounds: (1) Defendants were immune from liability under the Idaho Tort Claims Act (“ITCA”) because Mattson’s claims arose out of injuries sustained while she was receiving services from a “mental health center”; and (2) the “reckless, willful and wanton conduct” exception to immunity did not apply as a matter of law. The Idaho Supreme Court affirmed the district court’s decision that Mattson’s and her husband’s claims fell within the purview of the “mental health center, hospital or similar facility” immunity provision in Idaho Code section 6-904A(2). However, the Court reversed the district court’s decision that there was no triable jury question under the “reckless, willful and wanton conduct” exception to immunity. The Supreme Court found Mattson alleged sufficient facts at summary judgment to demonstrate that a reasonable person could find that Defendants’ acts or omissions were “reckless, willful and wanton[.]” Thus, the Court vacated the judgment and remanded this case for further proceedings. View "Mattson v. IDHW" on Justia Law

A group of pro se aggrieved property owners dubbed “Riverton Citizens Group,” timely filed a petition for judicial review challenging the Bingham County Commissioners’ (“the County”) decision to grant a zone change request. The caption of the petition named “Riverton Citizens Group” as the pro se petitioner, but the body of the petition then named the aggrieved property owners individually as the parties petitioning the County’s decision, while also providing that they were proceeding pro se under the title of “Riverton Citizens Group.” The petition was not signed by any of the aggrieved property owners. Instead, it was signed by a non-petitioner who purported to be the “agent” for “Riverton Citizens Group.” The purported “agent” was not licensed to practice law in Idaho. After the district court entered a notice of intent to dismiss the petition because Riverton Citizens Group was not represented by counsel, the aggrieved property owners attempted to correct the petition through five subsequent filings, each signed by only one of the aggrieved property owners. The district court subsequently issued a written decision, concluding the petition was “improperly filed” and therefore was not a “petition” that invoked the district court’s subject matter jurisdiction under Idaho Rule of Civil Procedure 84(n). Because the time for filing a new “petition” under I.R.C.P. 84(n) had passed, the district court dismissed the case with prejudice—reasoning it no longer had jurisdiction. A licensed attorney did not appear on behalf of the aggrieved property owners until after the district court’s decision to dismiss. The Idaho Supreme Court vacated the district court’s order: “the errors in the caption and the omitted signatures were not fatal or so defective as to render the petition a nullity or ‘improperly filed’ such that the district court had no subject matter jurisdiction. Instead, these errors may be corrected through a filing or amended petition on remand that relates back to the date of the timely petition.” View "Riverton Citizens Group v. Bingham County Commissioners" on Justia Law

Appellants were residents of Blaine County, Idaho (the “County”) who opposed a modified conditional use permit that the County granted to Idaho Power to install above-ground power lines. After the County denied Petitioners’ motion to reconsider as untimely, Petitioners sought judicial review of the permit in district court. Intervenor, Idaho Power Company, filed a motion to dismiss the petition, which the County joined, arguing that Petitioners’ underlying motion to reconsider was untimely, thereby precluding the district court from exercising its jurisdiction over the petition. The district court granted the motion to dismiss and concluded that it lacked jurisdiction to consider the petition because the Local Land Use and Planning Act (LLUPA) required aggrieved parties to file a timely motion to reconsider prior to seeking judicial review. The district court further held that no exception to the exhaustion of administrative remedies doctrine applied. Petitioners timely appealed to the Idaho Supreme Court to resolve the question of whether the LLUPA required a timely motion to reconsider to be filed in advance of a petition for judicial review. The Supreme Court concluded the act does require the filing of a timely motion to reconsider in advance of a petition for judicial review, and, therefore, affirmed the district court's order. View "Richardson v. Blaine County" on Justia Law

Stephanie Owens appealed a district court’s order affirming the findings of fact and conclusions of law made by the Ada County Board of Commissioners (the “Board”) in which it determined that Owens was an “applicant” under the Medical Indigency Act (the “Act”) and, therefore, required to pay reimbursement for the medical expenses incurred by her two children at public expense. In 2017, Owens’s children were involved in a serious car accident and suffered substantial injuries, which later resulted in the death of one of the children. Because the children’s father, Corey Jacobs, was unable to pay for the children’s medical bills, he filed two applications for medical indigency with the Board. Owens and Jacobs were never married and did not have a formal custody agreement for their children. At the time of the accident, the children resided with their father. The Board determined that Owens and her children met the statutory requirements for medical indigency. Although Jacobs filed the applications for medical indigency, the Board concluded that Owens was also an “applicant” under the Act and liable to repay the Board. As a result, the Board “recorded notices of statutory liens” against Owens’s real and personal property and ordered Owens to sign a promissory note with Ada County to repay the medical bills. Owens refused to sign the note and instead challenged the sufficiency of her involvement with the applications via a petition for reconsideration with the Board and a subsequent petition for judicial review. Both the Board and the district court ultimately concluded that Owens was an “applicant” and liable for repayment of a portion of the children’s medical bills. Owens timely appealed. The Idaho Supreme Court reversed: because she never signed the medical indigency applications for her children and she did not affirmatively participate in the application process, Owens was not an "applicant" as defined by the Act. As a result, the Board acted outside its authority when it ordered Owens to reimburse Ada County for its expenses and when it placed automatic liens on her property. View "Owens v. Ada County Board of Commissioners" on Justia Law

Jane Doe, a three-year-old child, was in the custody of the Idaho Department of Health and Welfare (the “Department”); she was six days shy of her first birthday when the State removed her from the custody of her mother and placed her with a foster family. Her mother’s attempts to stick to a permanency plan were inconsistent, and while for the majority of the life of this case, the magistrate court held fast to a permanency goal of reunification, it modified that goal in the summer of 2022 so that termination of parental rights and adoption became the primary goals for Jane and reunification became the concurrent goal. Mother appealed the district court’s change of the permanency goals. She also sought a permissive appeal from the magistrate court to appeal to the district court. The magistrate court granted the motion. The district court dismissed the case and remanded it back to the magistrate court sua sponte after determining it did not have jurisdiction to hear the appeal. Mother then appealed to the Idaho Supreme Court. The Supreme Court found no error in the district court’s judgment and affirmed. View "IDHW v. Jane Doe (2022-36)" on Justia Law

The issue this case presented for the Idaho Supreme Court's review centered on whether the Idaho Constitution protects abortion from the legislature's broad power to enact laws concerning the public’s health, welfare, and safety. Planned Parenthood Great Northwest, Hawaii, Alaska, Indiana, Kentucky, and Caitlin Gustafson, M.D., on behalf of herself and her patients (collectively “Petitioners”), brought three petitions, each seeking a writ of prohibition and declaratory relief blocking implementation and enforcement of recently enacted laws in Idaho. Petitioners also raised various facial challenges, claiming these laws offend important constitutional principles, such as equal protection, due process, the special laws provision, the separation of powers doctrine, and purported “informational privacy” protections under the Idaho Constitution. Petitioners further claimed that the Idaho Human Rights Act limited the legislature’s ability to regulate abortion through the Total Abortion Ban and 6-Week Ban. After careful consideration of the issued raised, the Idaho Supreme Court denied Petitioners’ requests for extraordinary writs of prohibition and declaratory relief. View "Planned Parenthood Great Northwest, et al. v. Idaho" on Justia Law

Deborah Dorr requested to reopen an unemployment appeal hearing that was to address Dorr’s appeal of the Idaho Department of Labor’s (“IDOL”) decision denying Dorr’s request to backdate her Pandemic Unemployment Assistance claim. After Dorr failed to appear at the hearing, IDOL dismissed her appeal and subsequently denied her request to reopen the hearing. Dorr appealed IDOL’s denial of her request to reopen, and the Idaho Industrial Commission (“the Commission”) affirmed. The Commission determined due process was satisfied and agreed with IDOL that Dorr’s own negligence was insufficient cause to reopen the hearing. Appealing pro se, Dorr petitioned the Idaho Supreme Court for relief. The Supreme Court concluded Dorr’s briefing did not meet the standard for an appeal under Idaho Appellate Rule 35(a)(6) and as such, her arguments were forfeited. The Commission’s decision upholding the Appeal Examiner’s denial of Dorr’s request to reopen her appeal hearing was affirmed. View "Dorr v. IDOL" on Justia Law

Mother Jane Doe appealed a magistrate court's judgment granting a petition to terminate her parental rights to her two minor children, Jane Doe I and John Doe I (the children). The magistrate court determined that Mother had neglected the children as defined in Idaho Code section 16-2002(3)(b), and that termination was in the best interests of the children. On appeal, Mother argued the definition of “neglect” provided in section 16-2002(3)(b) violated the Idaho and the United States Constitutions, and she argues that the magistrate court’s finding that termination was in the children’s best interests was not supported by substantial and competent evidence. After its review of the magistrate court record, the Idaho Supreme Court found the magistrate court found, by clear and convincing evidence that Mother’s parental rights should be terminated. That decision was supported by substantial and competent evidence in the record. It was therefore affirmed. View "IDHW v. Jane Doe" on Justia Law

This appeal arose from an Idaho district court decision affirming a declaratory ruling issued by Respondent Dave Jeppesen (the Director) in his capacity as Director of the Idaho Department of Health and Welfare (the Department). Appellant Grace at Twin Falls, LLC (Grace), a residential assisted living and memory care facility, partnered with a preferred pharmacy to offset costs associated with a software system that coordinated the tracking and delivery of residents’ prescription medications. Because residents who failed to choose the preferred pharmacy did not receive the offset, Grace sought to charge those residents an additional $10.00 each month to cover the difference. Grace brought a petition for declaratory ruling to the Department, asking the Director to declare that Idaho Code section 39-3316(12)(b) and IDAPA 16.03.22.550.12.b did not prohibit Grace from charging the $10.00 fee to those residents who did not choose the preferred pharmacy. The Director denied the petition, declaring that Grace would not “be permitted to assess a non-preferred-pharmacy fee as such fee violates residents’ right to choose their pharmacy or pharmacist . . . .” Grace sought judicial review before the district court, which affirmed the Director’s declaratory ruling. Grace then appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed the district court. View "Grace at Twin Falls, LLC v. Jeppesen" on Justia Law