Justia Government & Administrative Law Opinion Summaries

Douglas Waite appealed an Idaho Industrial Commission (“Commission”) decision requiring him to repay unemployment benefits he received, along with interest and penalties. Waite claimed the Commission’s determination that he willfully misstated a material fact for the purpose of obtaining unemployment benefits was not supported by substantial and competent evidence and was incorrect as a matter of law. Additionally, Waite argued the Commission erred when it concluded that Idaho Code section 72-1366(12) required him to repay the unemployment benefits he received. Finding no reversible error, the Idaho Supreme Court affirmed the Commission’s decision and order. View "Waite v. Moto One KTM, LLC" on Justia Law

This appeal stemmed from a years-long dispute between Robert Elgee and the Retirement Board of the Public Employee Retirement System of Idaho (“PERSI”) regarding the payment of retirement benefits accrued during Elgee’s service as a magistrate judge. Elgee became eligible for PERSI benefits in 2010, but operating under an erroneous interpretation of the statutes it administers, PERSI maintained Elgee was not then entitled to receive benefits. Eleven years, numerous administrative determinations, and two judicial review actions later, the parties continued to disagree on issues relating to the calculation of benefits, the interest due on benefits, and whether Elgee was entitled to damages for the tax consequences of receiving a lump sum payment of retroactive benefits. After review, the Idaho Supreme Court affirmed the district court as to the applicable rate of interest, reversed as to the remaining issues, and remanded for entry of judgment. On remand the district court was directed to enter judgment that reflected: (1) the PERSI Board’s determination that Elgee was due interest at the regular rate of interest under the PERSI statutes was affirmed; (2) the PERSI Board’s determination that Elgee was due interest from 2013, rather than 2010, was set aside; (3) the PERSI Board’s determination that Elgee was due benefits under the contingent annuitant option, rather than the regular retirement option was affirmed; (4) the PERSI Board’s determination that Elgee failed to prove his tax loss claim in 2018 was set aside; and (5) the PERSI Board’s determination that tax loss damages were not available under the PERSI statutes was affirmed. View "Elgee v. Retirement Brd. of the Public Employee (PERSI)" on Justia Law

In December 2014, Steve Tenny sustained a right-sided lumbar disc herniation injury during the course of his employment with Loomis Armored US (Loomis). He immediately began treatment, receiving a series of right-sided steroid injections in his back. At some point shortly after the second injection, Tenny began to complain of increasing left hip and groin pain and underwent testing and treatment for these symptoms. However, the worker’s compensation insurance surety, Ace American Insurance Co., ultimately denied payment for treatment related to the left-side groin pain. Following the matter going to hearing, the Referee recommended that the Industrial Commission find that the left-sided symptoms were causally related to Tenny’s December 2014 industrial accident. The Industrial Commission adopted the Referee’s findings, and after unsuccessfully moving for reconsideration, the employer and surety (collectively, "Defendants") appealed to the Idaho Supreme Court. At issue before the Supreme Court was the question of causation: Was the left-side groin pain experienced by Tenny causally related to his industrial accident? Finding no reversible error, the Idaho Supreme Court affirmed the Industrial Commission's decision. View "Tenny v. Loomis Armored US, LLC" on Justia Law

Loyd Eugene Ware filed suit against the City of Kendrick (the City) alleging that in December 2016, a water pipe maintained by the City failed and flooded his property, causing damage. The City answered, claiming that Ware had failed to file a timely notice of tort claim within 180 days of the City’s alleged negligence, a statutory prerequisite to filing suit against a governmental entity under Idaho Code section 6-906. The City averred the flooding occurred on December 17, 2016, and the notice of tort claim was not filed until two hundred twenty-two days later. The City thus moved for summary judgment, which was granted by the district court. Ware timely appealed. Finding no reversible error, the Idaho Supreme Court affirmed the grant of summary judgment in favor of the City. View "Ware v. City of Kendrick" on Justia Law

St. Luke’s Meridian Medical Center (St. Luke’s) provided inpatient hospital care for an indigent patient from January 26, 2016, until March 9, 2016. St. Luke’s sought payment from the Board by submitting a medical indigency application. In September 2016, the Board issued an initial determination, only approving payment from January 26 through February 2, 2016. St. Luke’s appealed the denial. The Board amended its determination by only partially extending payment approval through February 18, 2016. St. Luke’s petitioned for judicial review. In October 2017, the district court affirmed the Board’s decision. St. Luke’s appealed to the Idaho Supreme Court, and the Supreme Court held that the Board’s findings did not provide a reasoned analysis, as required by the Idaho Administrative Procedures Act (IDAPA). The case was remanded back to the Board for it to make the required findings of fact and conclusions of law. On remand, the Board entered its findings of fact, conclusions of law, and order, again denying payment and finding that the services provided were not the most cost-effective services as required under the Idaho Medical Indigency Act. St. Luke’s again filed a petition for judicial review, and the district court again affirmed the Board’s decision. Once more, St. Luke’s timely appealed. The Idaho Supreme Court determined the Board’s decision reflected a misinterpretation of the definition of “medically necessary services;” the Board’s decision was set aside and the matter remanded for further proceedings. View "St. Luke's Health System v. Board of Commissioners of Gem County" on Justia Law

An indigent patient was admitted to St. Alphonsus Regional Medical Center (St. Alphonsus) on October 7, 2017, and continued to receive treatment in the hospital until she was discharged on January 12, 2018. During her stay, St. Alphonsus filed a third-party medical indigency application on her behalf, and later filed two additional requests for payment of services. The Board of Ada County Commissioners (the Board) approved payment for dates of service from October 7 until October 10, 2017, but denied payments for services provided from October 11 until December 31, 2017, relying on the opinion of the Ada County Medical Advisor that the services provided on those dates were not “medically necessary” under the definition in Idaho Code section 31-3502(18)A(e). St. Alphonsus appealed the Board’s initial determination, but the final determination upheld the denial for payment beyond October 11. Upon St. Alphonsus’ petition, a district court reversed the Board’s decision, finding that the services “currently available” to a patient were to be considered as a “necessary medical service.” The Board argued “there did exist options for the Patient to proceed to rehabilitation at a facility other than St. Alphonsus, but for the Patient’s lack of funding.” Furthermore, the Board asserted that Idaho Code section 31-3502(18)A(e) is unambiguous in that “[t]here is no wording in [sub]section (e) of the statute that limits the ‘most cost-effective services’ to services that the Patient can afford to pay for.” After review, the Idaho Supreme Court determined the Board exceeded its statutory authority in denying St. Alphonsus reimbursement for providing medically necessary services. “The Board’s denial of payment was not based on substantial evidence and prejudiced St. Alphonsus’ substantial right to compensation for services rendered to an indigent patient.” View "St. Alphonsus Regional Medical v. Ada County" on Justia Law

John and Deborah Rouwenhorst, on behalf of Desert Foothills Wet, LLC, and Desert Foothills Dry, LLC, submitted a rezoning application seeking to reclassify 696 acres in Gem County (the Property) from A-1, Prime Agriculture to A-2, Rural Transitional Agriculture. Although the Gem County Zoning Commission recommended approval of the rezone, the Board of County Commissioners denied the application. After unsuccessfully moving for reconsideration, the Rouwenhorsts petitioned for judicial review. The district court reversed the Board’s denial of the rezoning application and awarded attorney fees and costs to the Rouwenhorsts. Gem County appealed. The Idaho Supreme Court reversed, finding the Board's decision was not arbitrary or capricious because it applied the standards set forth in the Gem County Code for rezoning applications, and was supported by substantial evidence. The district court's decision was reversed, and the attorney fee award vacated. View "Rouwenhorst v. Gem County" on Justia Law

The plaintiffs were indigent defendants represented in criminal actions by attorneys provided through Idaho’s public defense system. They alleged that numerous inadequacies in Idaho’s public defense system, as administered by the State and the Idaho Public Defense Commission (“PDC” or together “Respondents”), violated the rights of the named plaintiffs, as well as those of similarly situated criminal defendants across Idaho, under the Sixth and Fourteenth Amendments to the U.S. Constitution and Article I, Section 13 of the Idaho Constitution. In 2019, the district court denied cross motions for summary judgment, citing a lack of precedent as to the controlling legal standard to be applied, and requested this appeal. The Idaho Supreme Court granted the district court’s request for permissive appeal to determine the standard of review. The central issue presented for the Supreme Court's review centered on how to properly evaluate the deficiencies in Idaho’s public defense systems alleged by Appellants. In sum, Appellants insisted that a broader view was sufficient, while Respondents demanded the district court examine this issue closely. The Supreme Court held that both views were necessary: "a close up view, which allows for greater specificity, must be applied to the individual claims of at least one of the named plaintiffs whose allegations formed the basis of standing; however, a more distant view, which allows for greater overall perspective, is permissible for the examination of the systemic constitutional shortcomings alleged by Appellants." View "Tucker v. Idaho" on Justia Law

In this case, the Idaho Supreme Court was asked to revisit its decision in Idaho v. Clarke, 446 P.3d 451 (2019), and determine whether its holding was applicable in an administrative proceeding regarding the suspension of driving privileges based on an alleged case of driving under the influence (“DUI”). The Idaho Transportation Department (“ITD”) appealed a district court’s decision overturning its one-year suspension of Jasmine Reagan’s driving privileges. ITD based the administrative license suspension (“ALS”) on Reagan’s arrest for misdemeanor driving under the influence of alcohol and the results of subsequent testing of her blood alcohol content (“BAC”). The arresting officer, acting on a citizen’s report of a possible intoxicated driver, did not personally witness Reagan operating or in control of a vehicle. Reagan failed field sobriety tests administered at her home and, after being arrested, failed a breathalyzer test. Reagan received notice that her driver’s license was suspended for one year, which she appealed. An administrative hearing officer for ITD, relying on Idaho Code section 49-1405, upheld the license suspension. However, on appeal the district court overturned the suspension pursuant to Clarke, reasoning that because the misdemeanor DUI was completed outside the officer’s presence, the arrest required a warrant. On certiorari review, the issues presented were: (1) whether the breathalyzer test was administered pursuant to a lawful arrest; and (2) if the arrest was unlawful, whether test results obtained pursuant to an unlawful arrest are admissible in an ALS hearing before the ITD. The SupremeCourt concluded Idaho Code section 49-1405, as applied in this case, violated the Idaho Constitution. Accordingly, the Court affirmed the district court's decision to overturn ITD's suspension of Reagan's license. View "Reagan v. Idaho Transportation Department" on Justia Law

Citizens Against Linscott/Interstate Asphalt Plant (“CAL”) challenged a conditional use permit (“CUP”) issued by the Bonner County, Idaho Board of Commissioners (“the County”). The CUP was based on a recent amendment to Bonner County zoning ordinances (“the Amendment”) and authorized Interstate Concrete and Asphalt Company (“Interstate”) to operate an asphalt batch plant within Frank and Carol Linscott’s gravel mine in Sagle, Idaho. In its petition for judicial review by the Bonner County district court, CAL challenged both the validity of the Amendment and the County’s decision to issue the CUP. The district court determined that CAL had standing to file its petition for judicial review of the CUP and that CAL had timely filed its petition. However, the district court concluded that it could not declare the Amendment invalid in a proceeding for judicial review under Idaho Local Land Use Planning Act (“LLUPA”) and the Idaho Administrative Procedure Act (“IDAPA”). Accordingly, the district court upheld the County’s decision to grant the CUP, giving the County deference in applying its own land-use ordinances. During the pendency of this appeal, CAL filed an action for declaratory relief before another district court judge to have the Amendment declared void. In that proceeding, the County admitted that the Amendment had been adopted without proper public notice and stipulated to a judgment and order declaring the Amendment void. On appeal of the administrative decision to the Idaho Supreme Court, CAL argued, among other things, that the subsequent voiding of the Amendment also invalidated the CUP or that the CUP was not issued in conformity with Bonner County zoning laws. After review, the Supreme Court affirmed in part, and reversed in part. The Court found the CUP authorizing the relocation of the Interstate asphalt batch plant to the Linscotts’ gravel mine was invalid because it was based on a void amendment to Bonner County Code. Further, the County acted in a manner that was arbitrary and capricious in refusing to address the gravel pit’s compliance with the nonconforming use provisions of BCRC. View "Citizens Against Linscott v. Bonner County Board of Commissioners" on Justia Law