Justia Constitutional Law Opinion Summaries

The Idaho Department of Fish and Game (IDFG) appealed the district court's post-judgment orders (1) refusing to lift a portion of an injunction and (2) declaring the Idaho Outdoor Sport Shooting Range Act unconstitutional. In 2004, IDFG made a public proposal to renovate the Farragut Shooting Range, (owned and operated by IDFG since World War II), based on the "Vargas Master Plan." Citizens Against Range Expansion (CARE), an unincorporated non-profit association comprised of individuals who reside near the range, contended that the plan would greatly increase range usage, and harm the community. CARE sued IDFG in 2005 for nuisance and other related causes of action regarding the range's operation. CARE's claims were grounded in both safety and noise concerns regarding the increased use of the range, and its proposed expansion. Among other relief, CARE sought to enjoin IDFG's operation of the range. The case proceeded to a court trial in December of 2006 and in February of 2007 the court issued its memorandum decision wherein it determined that CARE was entitled to relief enjoining further operation of the Farragut Range until IDFG completed certain safety improvements. Upon completion of its range improvements, IDFG filed a Motion for Partial Lifting of Injunction. CARE then moved for summary judgment, claiming that the Act was a special law in violation of art. III, sec. 19 of the Idaho Constitution, and a deprivation of judicial power in violation of art. V, sec. 13. The district court issued summary judgment in favor of CARE on the constitutional issues in March of 2011. In its order, the court found that the Act was unconstitutional as a special law and a deprivation of judicial power. For this reason alone, it denied IDFG's Relief Motion with regard to the 501-shooter component. The court found that there remained disputed issues of fact regarding range safety. On August 25, 2011, following the evidentiary hearing on safety issues, the district court denied IDFG's Relief Motion with regard to the one component of the injunction. IDFG timely appealed to the Supreme Court. Upon review, the Supreme Court: 1) reversed the district court's order holding that IDFG did not comply with the "500-shooter" component of the injunction; 2) concluded as a matter of law that IDFG complied with the 500-shooter component, and lifted that component of the injunction; 3) reversed the district court's order holding the Act to be unconstitutional; 4) remanded this case to the district court to determine whether IDFG has complied with the "501-shooter" component of the injunction. View "Citizens Against Range Expansion v. Idaho Fish & Game" on Justia Law

Plaintiff Christina Brooksby demanded payment from Defendant GEICO General Insurance Company, her father's liability insurer, alleging that he negligently injured her by crashing the car in which she was riding. After GEICO refused Plaintiff's demand pursuant to an exclusion in its insurance policy with Father, she sued GEICO for a declaratory judgment establishing coverage. The district court dismissed Plaintiff's complaint for lack of standing, holding that Idaho has no common-law direct-action rule that would give an injured third party standing to sue her tortfeasor’s insurer absent some statutory or contractual authorization, and that Idaho's Uniform Declaratory Judgment Act does not confer standing where it does not otherwise exist. Plaintiff appealed. Upon review, the Supreme Court affirmed the district court’s grant of GEICO’s Motion to Dismiss pursuant to Idaho Rule of Civil Procedure 12(b)(6) because the Court concluded Plaintiff lacked standing to seek a declaratory judgment against GEICO.

The appellant had filed a petition for reconsideration of an administrative order issued by the Idaho Department of Water Resources, and, when the Department failed to decide the merits of the petition within twenty-one days, the appellant filed a petition for judicial review of the Department’s order, contending that the petition for reconsideration was deemed denied pursuant to Idaho Code section 67-5246(4). The Department later decided the petition for reconsideration and issued an amended order. The district court held that section 67-5246(4) did not require the Department decide the merits of the petition for reconsideration within twenty-one days; it only had to agree to consider the petition within that time frame. The court therefore dismissed appellant’s petition for judicial review on the ground that the order it sought to have reviewed had been superseded by the amended order. The Supreme Court vacated the dismissal because the petition for reconsideration was deemed denied by section 67-5246(4) when the Department failed to decide it within twenty-one days, and the amended order was therefore a nullity because the Department did not have jurisdiction to issue it.

This case concerned the Director (Director) of the Idaho Department of Water Resources' application of the Rules for Conjunctive Management of Surface and Ground Water Resources (CM Rules) in response to a ground water to ground water delivery call filed by the A&B Irrigation District (A&B). The Director’s Final Order found that A&B was not materially injured and was affirmed by the district court on nearly all points. A&B appealed to the Supreme Court, contending that the Director and the district court erred in their analyses. The City of Pocatello and the Idaho Ground Water Appropriators, Inc. cross-appealed alleging that the district court erred by requiring that the Director's finding of no material injury must be supported by clear and convincing evidence, rather than a preponderance of the evidence. Upon review of the matter, the Supreme Court affirmed the decision of the district court.

Two personal injury actions and one wrongful death action arising out of an automobile accident were consolidated on appeal before the Supreme Court. In 2007, Paul -Smith's vehicle collided with a semi-tractor trailer driven by Robert Petrovich. Nicole Plouffe and Tiffany Ann Marie Fragnella were both passengers in Smith's vehicle. Plouffe was severely injured and Fragnella died as a result of her injuries. At the time of the accident, Petrovich was driving the semi-truck for Swift Transportation Co., Inc., and was training a Swift Transportation employee in driving skills. The Swift Transportation trainee, Thomas Thayer, was a passenger in the semi-truck at the time of the collision. Thayer was covered under Swift Transportation's workers' compensation insurance. Smith and his passengers' Amended Complaint alleged that Petrovich was negligently driving the semi-truck. The district court granted summary judgment in favor of the Petrovich and Swift, finding that there was no evidence that the accident was caused by Petrovich. The district court also concluded that a third party claim for negligence against Petrovich was separately barred by the exclusive remedy rule under Idaho's Workers' Compensation statutes. Smith appealed to the Supreme Court arguing that the district court erred in granting summary judgment, that the court abused its discretion in denying the Motions for Reconsideration, and that the court erred in determining that the exclusive remedy rule barred the third-party claims against Petrovich. Upon review, the Supreme Court affirmed the district court's grant of summary judgment in favor of Petrovich, and found no error in the district court's decision.

This appeal was a consolidation of two actions relating to residential leases on State endowment lands. In one action, the Attorney General sought a declaratory ruling that I.C. 58-310A, which exempts so-called "cottage site" leases from conflict auctions, was unconstitutional in light of Article IX, section 8 of the Idaho Constitution. The district court determined that I.C. 58-310A was constitutional, and thus, dismissed the Attorney General's complaint. The Attorney General appealed that decision. In the other action, Gladys Babcock and several others who lease cottage sites on Payette Lake filed an action against the State Board of Land Commissioners and the Idaho Department of Lands Director. The Payette Lake Lessees alleged that the Board breached their lease agreements when it declined to renew the expiring leases for an additional ten years. The district court granted summary judgment to the Board, finding the Payette Lake Lessees had failed to exhaust their administrative remedies. The Payette Lake Lessees filed a cross-appeal challenging that decision. Upon review of the cases, the Supreme Court reversed the district court's ruling on the Attorney General's claim because I.C. 58-310A was unconstitutional. The Court vacated the district court's holding with respect to the Payette Lake Lessees' claim and remanded both cases for further proceedings.

This case concerned the ownership status of Coolwater Ridge Road in Idaho County. The predecessors in interest of appellant Paddison Scenic Properties, Family Trust, L.C. granted rights of way to the United States for a road which became Coolwater Ridge Road. In the district court, Paddison sought a declaratory judgment that the rights of way did not constitute a public road or highway under Idaho law. That court held that the rights of way were public because the criteria for common law dedication were met. Upon review, the Idaho Supreme Court vacated the district court's judgment because it concluded this case was not ripe for adjudication.

The issue on appeal before the Supreme Court was a challenge to the failure of a district court to give preclusive effect to a California federal district court judgment during a proceeding to grant recognition of a subsequent German judgment. Plaintiff Ron Markin executed a promissory note in 1988 agreeing to pay Defendant Thomas Grohmann $551,292.00 with interest at ten percent per annum. The loan was for a business transaction between the parties. In September 1997, Plaintiff sued Defendant in the United States District Court in the Central District of California in order to collect the promissory note. At that time, Defendant resided in Scottsdale, Arizona. The parties entered into a written settlement agreement to resolve the lawsuit. The agreement provided the principal and interest owing; that the lawsuit would be dismissed if that sum plus interest was paid according to the terms of the agreement; that the court would retain jurisdiction to enforce the agreement; that if the amount due under the agreement was not paid in full as provided in the agreement, Plaintiff could obtain a judgment as provided by California law; and that the agreement "shall be governed by and interpreted under the laws of the State of California." Defendant failed to pay according to the agreement, and Plaintiff obtained an ex parte judgment against Defendant. After learning that Defendant owned real property in Germany, Plaintiff commenced a civil action in Germany to enforce the California judgment. The German trial court dismissed the action on the ground that the judgment was not enforceable under German law. Plaintiff appealed and asserted that if the judgment was not enforceable, he could recover on the settlement agreement upon which that judgment was based. The appellate court agreed, and it issued an opinion ordering Defendant to pay Plaintiff. The court held that it could enter a judgment against Defendant based upon the settlement agreement because he had previously been a German citizen. Upon its review of matter, the Idaho Supreme Court concluded that the German judgment was a final judgment under German law. But because the German judgment did not recognize the effect of a final judgment under California law, it conflicted with the California judgment. The Idaho Court therefore reversed the judgment of the district court that recognized the German judgment.

Plaintiffs Paul Trunell and Bill Lomu appealed a district court's ruling against them in their request for injunctive relief. Plaintiffs' complaint alleged the existence of a public road across Defendant Verna Fergel's property, and that she denied access to the road causing damage to Plaintiffs. The district court held that Defendant was a bona fide purchaser for value, and that she did not have actual or constructive notice of the public nature of the road when she purchased the property. Upon review of the trial court record, the Supreme Court found that the "bona fide purchaser for value" defense was not available to Defendant as it would have constituted an abandonment of the road in contravention to Idaho law. The Court therefore reversed the district court's holding and remanded the case for further proceedings.

Plaintiff-Appellant Victoria Johnson appealed the district court's grant of summary judgment in favor of North Idaho College (NIC) on her claim of discrimination under the Idaho Human Rights Act (IHRA). Plaintiff alleged one of her instructors sexually harassed her, and that NIC was vicariously liable for that harassment. The district court held that NIC's affirmative defense was factually support, and that she failed to establish a genuine issue of material fact. Upon review of the facts of this case, the Supreme Court concluded that the district court did not err in finding that no genuine issue of material fact existed in regard to Plaintiff's claims. Accordingly the Court affirmed the opinion of the district court.