Justia Constitutional 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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In the case before the Supreme Court of the State of Idaho, the plaintiffs, Dallen and Rachel Worthington, filed an expedited unlawful detainer action against the defendant, Carlene Crazy Thunder, for failure to pay rent. Crazy Thunder requested a jury trial, which was denied by the magistrate court. Following a bench trial, the magistrate court ruled that Crazy Thunder had unlawfully detained the Worthingtons’ property and ordered her to vacate the residence. Crazy Thunder appealed to the district court, arguing she had a right to a jury trial under Idaho’s constitution and Idaho Code section 6313. The district court agreed, concluding that section 6-311A conflicted with section 6-313, and that section 6-311A violated Article I, section 7 of the Idaho Constitution. The Worthingtons then appealed to the Supreme Court of Idaho.The Supreme Court of Idaho held that Idaho Code section 6-311A does not violate the Idaho Constitution. The court reasoned that an action for unlawful detainer is an equitable claim, and under Article I, section 7 of the Idaho Constitution, the right to trial by jury only exists for legal claims, not equitable ones. However, the court also ruled that Crazy Thunder was entitled to a jury trial on her legal claims. The court held that in wrongful detainer cases like this one, when issues of fact are presented by the pleadings, those issues must be tried by a jury, unless such a jury is waived. As such, the Supreme Court of Idaho affirmed the district court’s decision, though on different grounds. The court further ruled that Crazy Thunder, as the prevailing party on appeal, was entitled to costs, but neither party was entitled to attorney fees. View "Worthington v. Crazy Thunder" on Justia Law

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The issue this appeal presented centered on a non-summary contempt proceeding arising out of a divorce, and former litigation in Oregon over spousal support Steven Abell owed his ex-wife Debra Abell. After a judgment of contempt was entered against him in Oregon for failure to pay support, Steven allegedly continued to refuse to pay Debra. Roughly one year later, Debra brought the underlying contempt proceeding in Idaho, charging Steven with contempt for failure to comply with the payment terms in the Oregon contempt judgment, and requesting relief from the Idaho district court, where Steven resided. The district court found Steven in willful contempt of the Oregon contempt judgment, and imposed an unconditional sanction of $5,000, making both determinations through a summary judgment procedure. Steven appealed. The Idaho Supreme Court found the sanction imposed by the district court was criminal in nature, and it was imposed in error because Steven was not afforded certain protections owed an alleged contemnor in a criminal contempt proceeding. In addition, regardless of whether a civil or criminal sanction is sought or imposed, when an alleged contemnor is not in default and denies the charge of contempt, the non-summary contempt proceeding cannot be adjudicated through a summary judgment procedure. Idaho Rule of Civil Procedure 75 requires a trial. Accordingly, the district court’s judgment of contempt was vacated, its decisions underlying its judgment were also vacated, and the case was remanded for further proceedings that had to start over, at the initial pleading stage, in order to proceed appropriately. View "Abell v. Abell" on Justia Law

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Petitioner-appellant John Bradbury was resident of the City of Lewiston, Idaho and was an elected member of its city council. While serving in that capacity, he filed a petition alleging nine causes of action concerning various City funds and services, including those related to water, sanitation, wastewater, city streets, the library, and the municipally-owned Bryden Canyon Golf Course. Bradbury contended the City had been collecting excessive utility fees and improperly spending municipal funds. Bradbury sought declaratory and equitable relief. He appealed when the district court dismissed most of his claims at summary judgment, and raised additional errors for appellate review. The Idaho Supreme Court determined only that the district court erred in determining that the Idaho Tort Claims Act (“ITCA”) precluded recovery on a constitutional claim seeking equitable relief. The Court determined a remand was unnecessary where Bradbury conceded he was seeking no such remedy for himself. The Court affirmed the district court in all other respects. View "Bradbury v. City of Lewiston" on Justia Law

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This case stemmed from a 2019 lease by Respondents the City of Sandpoint (“the City”) to The Festival at Sandpoint (“The Festival”), a nonprofit corporation, to operate a multi-day music concert series in War Memorial Field Park. The Festival had a long-standing policy of prohibiting festival patrons from bringing weapons, including firearms, into the event. On August 9, 2019, Scott Herndon and Jeff Avery purchased tickets to the festival and attempted to enter. Avery openly carried a firearm and Herndon possessed a firearm either on his person or in a bag (the record was unclear on this point). Security personnel for the event denied entry to both. After discussions with a City police officer and the City’s attorney, who was coincidentally attending the same event in his private capacity, Herndon and Avery eventually left the music festival and received a refund for their tickets. Appellants Herndon, Avery, the Idaho Second Amendment Alliance, Inc., and the Second Amendment Foundation, Inc. subsequently sued the City and The Festival, asserting several claims, including seeking injunctive relief prohibiting the Respondents from violating the Idaho and United States Constitutions, particularly the Second Amendment and the Idaho Constitution’s provision securing the right to keep and bear arms in public for all lawful purposes. The district court ultimately granted the Respondents’ motions for summary judgment, awarded both the City and The Festival attorney fees and costs, and dismissed all the Appellants’ claims with prejudice. The issue raised on appeal was whether a private party who leased public property from a municipality may govern those who come and go from the property during the lease. The Idaho Supreme Court responded in the affirmative, and affirmed the district court's judgment. View "Herndon v. City of Sandpoint" on Justia Law

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Petitioner Todd Wood appealed after his driving privileges were suspended following breath alcohol testing (BAC) by the Idaho State Policy. After a lawful traffic stop, Wood submitted to BAC testing. His results were 0.178 and 0.175, both in excess of Idaho’s legal limit of 0.08. However, during the fifteen-minute pretest observation period, the deputy sheriff admittedly did not observe Wood for roughly three minutes to ensure mouth alcohol was not present by way of burp, external contaminant, or otherwise prior to evidentiary testing. Wood challenged his suspension and argued that his BAC results were inadmissible because they had not been obtained in compliance with the required fifteen-minute pretest observation procedure. The ALS hearing officer disagreed, reasoning that ISP had promulgated rules making the pretest observation period only discretionary; thus, Wood’s BAC test results were not based on unlawful procedure. Wood petitioned for judicial review and argued the BAC rules allowing for a discretionary observation period are violative of “due process” and “fundamental fairness.” Wood further argued that the automatic admission of BAC results in his ALS hearing, pursuant to section 18-8004(4), unconstitutionally usurped the judicial branch’s power over the admission of evidence. The district court rejected Wood’s arguments and upheld his administrative license suspension. Wood appealed to the Idaho Supreme Court on the same grounds, which likewise upheld the suspension. View "Wood v. ITD" on Justia Law

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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

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At issue in this appeal was a question of the due process rights of an unwed biological father who had established a relationship with his two-month-old child through frequent visits before the child’s maternal grandfather filed a petition to adopt the child. Under Idaho Code sections 16-1504 and 16-1513, the magistrate court determined that the grandfather’s filing of the adoption petition permanently and irrevocably barred the father from establishing paternity or objecting to the adoption. The Idaho Supreme Court vacated the magistrate court's decision because the father’s relationship with his child may have been sufficient to confer parental rights protected by the due process provisions of the Fourteenth Amendment of the United States Constitution, and the statutes relied upon in the magistrate court’s decision unconstitutionally risk termination of these rights without due process. View "Jane Doe I & John Doe I" on Justia Law

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In 2017, Dennis and Linda Nelson, the maternal grandparents of C.E., S.E., and A.E., filed a petition at magistrate court relying on Idaho Code section 32-719 to establish visitation rights after Stephanie and Brian Evans, the granddaughters’ parents, terminated contact between the children and the grandparents. Although the magistrate court initially dismissed the petition in its entirety, the Idaho Supreme Court reversed the dismissal, concluding that “Idaho Code section 32-719 does not restrict when a grandparent may petition a court for visitation rights” and that “there [wa]s a genuine issue of material fact as to whether the Evanses’ decision to terminate all contact between the Nelsons and their children was in their children’s best interests.” On remand to the magistrate court, the Evanses moved for a determination that Idaho Code section 32-719 unconstitutionally interfered with their fundamental parental rights. The magistrate court denied the motion, and the matter proceeded to trial. After a three-day trial, the magistrate court found that, while the Evanses were fit parents, their decision to terminate all contact between the children and the grandparents was not in the best interests of the children. However, the magistrate court also found that Linda’s actions on the whole had not been in the best interests of her granddaughters and that her actions had undermined the Evanses efforts to parent their children. The magistrate court nevertheless imposed a visitation schedule. The magistrate court ordered that the Nelsons attend counseling to address the issues it identified before the Nelsons could exercise their visitation award. This appeal followed. The Idaho Supreme Court found that “[p]arents have a fundamental right to maintain a familial relationship, and to the ‘custody, care and control’ of their children; this right is protected by the Fourteenth Amendment. ... Because section 32-719 does not limit standing or provide meaningful guidance for how to apply the best interests test, it is not narrowly tailored. As a result, section 32-719 does not pass constitutional muster. We hold that Idaho Code section 32-719 is facially unconstitutional." The magistrate court's visitation order was reversed and the case was dismissed without remand. View "Nelson v. Evans" on Justia Law

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The Idaho Supreme Court held a hearing on August 3, 2022 to address specific procedural matters. The only issues in dispute were whether the Court should stay the enforcement of Idaho Code section 18-622(2) (“Total Abortion Ban”) and whether it should continue to stay the enforcement of Senate Bill 1309 (“Civil Liability Law”). The Court denied Petitioners’ request to stay the enforcement of Idaho Code section 18-622 in Docket No. 49817-2022; and vacated the stay of the enforcement of Senate Bill 1309 entered by the Court on April 8, 2022 in Docket No. 49615-2022. View "Planned Parenthood v. Idaho" on Justia Law