Justia Constitutional Law Opinion Summaries

The issue on appeal in this case came from a decision of a district court which held that in a hearing regarding an administrative license suspension pursuant to Idaho Code section 18-8002A, the hearing officer must consider the margin of error of the breath testing machine when determining whether the test results support suspension. Facing a license suspension, Defendant Alma Elias-Cruz argued at trial that any suspension must be based upon her actual blood alcohol concentration rather than the alcohol concentration as shown by the test because, due to the test's margin of error, her actual blood alcohol content could have been below the statutory limit, and that the testing equipment had not been calibrated once a year as recommended by its manufacturer. The district court ruled sua sponte that her due process rights were violated by the hearing officer's rejection of the equipment's margin of error and that she had a statutory right to present such evidence. The court vacated the hearing officer's decision and ordered the matter remanded. The State then timely appealed. The Supreme Court reversed: "[u]nder Idaho Code section 18-8002A(1)(e), by definition the test results show the alcohol concentration. The issue is not the alcohol concentration in the blood. It is the alcohol concentration as shown by the test results. There is nothing to which to compare the test results. All that is required is that the test results show that the alcohol concentration was above the legal limit." The Supreme Court concluded the district court erred in its interpretation of that statute.

The issue on appeal to the Supreme Court concerned Appellant Daniel Fuchs appeal of a district court's decision which found that the Director of the Idaho State Police Alcohol Beverage Control (ABC) had properly exercised his discretion when he ruled that neither party had been a prevailing party for the purposes of attorney fees. Fuchs was issued a Retail Alcohol Beverage License and subsequently opened Aubrey's House of Ale (Aubrey's) in Coeur d'Alene. The Alcohol Beverage Control Bureau Chief conducted an unannounced inspection of the premises. After this inspection, ABC filed a Complaint for Forfeiture or Revocation of Retail Alcohol Beverage License regarding Fuchs's license. Eventually, the parties filed cross motions for summary judgment in the action before an ABC hearing officer. After oral argument, the hearing officer granted summary judgment to Fuchs. On appeal to the Director of the ABC, the Director did not order Fuchs' license revoked because of confusion surrounding the proper interpretation of the applicable rule under which Fuchs was cited. The Director's Final Order addressed the hearing officer's erroneous application of quasi-estoppel and Fuchs' unsuccessful arguments regarding improper rulemaking and claim that the agency acted arbitrarily. The Director denied attorneys' fees to both parties, declaring neither was the prevailing party because neither acted without a reasonable basis in fact or law. Upon review, the Supreme Court agreed that Fuchs was not a prevailing party and affirmed the district court's decision to deny fees.

This appeal arose from a condemnation action brought by the Idaho Transportation Board (ITB) against HI Boise, LLC. ITB sought to acquire a strip of land as part of a project to improve the I-84/Vista Avenue Interchange in Boise. ITB offered HI Boise the condemned property's appraised value of $38,177, but HI Boise filed a counterclaim for inverse condemnation, claiming damages of $7.5 million for additional lost rights of access and visibility. HI Boise appeals the district court's summary dismissal of those claims. Because the Supreme Court found that neither claim involved a compensable taking, the Supreme Court affirmed.

The issue before the Supreme Court in this case concerned the approval of a permit application for a Livestock Confinement Operation (LCO), also known as a Concentrated Animal Feeding Operation (CAFO), by the Jerome County Board of County Commissioners. The Board approved the application after a remand by the district court of the Board's decision previously denying the permit. Several individuals and organizations opposed to the LCO because of the potential harms to the neighboring farms and to the Minidoka National Historic Site petitioned the district court for review of the Board's decision. The district court affirmed the Board's approval of the permit, finding in the process that four of the organizations concerned with the effects on the Minidoka National Historic Site lacked standing. Several of the objecting parties appealed the district court's decision, asking the Supreme Court to find that these parties had standing to challenge the permit approval, that the Board's procedure for presenting evidence before the Board violated procedural due process rights, and that the Board failed to follow all of the county's relevant zoning ordinances when it approved the application. The issue central to the Court's opinion pertained to standing of all the appellant-organizations, the Board's procedure for presenting evidence throughout the LCO permit application process, the constitutionality of the "one mile rule" of Idaho Code section 67-6529, and the application of the Jerome County Zoning Ordinances. The Court concluded that the Board properly applied its zoning ordinance to the LCO permit application process, that I.C. 67-6529 was not unconstitutional, and that the public was afforded appropriate due process prior to, and during the LCO permit application hearing.

HJ Grathol is a California general partnership that owed real estate in Idaho. Grathol purchased a parcel for development. The Idaho Transportation board later sought to condemn sixteen acres of the parcel in order to realign US Highway 95 and to construct an interchange with State Highway 54. Grathol contended that the Board failed to negotiate for the sixteen acres in good faith because the Board's offer did not account for the extension of two roads which were believed to have significantly increased the property's value. Grathol also asserted that the Board failed to file its complaint and order of condemnation in accordance with Idaho law before moving for early possession of the property pursuant to a "quick take" provision. Upon review, the Supreme Court concluded that the Board indeed did negotiate in good faith for the subject property, and filed its complaint and order of condemnation in accordance with the applicable statute. Therefore, the Supreme Court affirmed the district court's decision that the "quick take" provision in question was satisfied.

This appeal involved a negligence claim arising out of a motor vehicle accident. Appellant Joseph Gerdon was a passenger in an automobile, traveling with Respondent Joshua Rydalch when the vehicle veered off the road and went down an embankment. At the time of the accident, both Gerdon and Rydalch were employees of Con Paulos Chevrolet, Inc., and were transporting a vehicle for their employer. Gerdon and Rydalch were injured during the accident, and both parties received workers' compensation benefits for a work-related injury. Gerdon also filed a Complaint against Rydalch for negligent driving. The district court granted summary judgment in favor of Rydalch, finding that both Gerdon and Rydalch were acting in the course and scope of their employment during the accident. As a result, the district court held that Gerdon's claim of negligence was barred by the exclusive remedy rule under Idaho’s Workers' Compensation statutes. Gerdon appealed to the Supreme Court, arguing that the district court erred in holding that Rydalch was acting in the course and scope of his employment at the time of the accident, and that the court abused its discretion by striking a portion of Gerdon's affidavit. Upon review, the Supreme Court affirmed the district court’s grant of summary judgment in favor of Rydalch because the Court found he was acting in the course of employment when the accident occurred, and therefore, Gerdon's claim of negligence was indeed barred by the exclusive remedy rule. Furthermore, the Court found that the district court did not abuse its discretion in striking a portion of Gerdon's affidavit.

This appeal involed a medical malpractice claim brought against a chiropractor for negligently causing a patient to suffer a stroke after treatment. In 2007, Appellant Martha Arregui sought treatment for her neck and back pain from Respondent Dr. Rosalinda Gallegos-Main. Arregui originally alleged that Dr. Gallegos-Main owed her a duty to treat her in a medically competent manner under Idaho's Medical Malpractice Act, and failed to do so when Arregui was diagnosed several weeks later as having suffered a stroke after a neck manipulation by Dr. Gallegos-Main. Arregui filed suit against the chiropractor and the facility, Full Life Chiropractic, in 2009. Dr. Gallegos-Main deposed Arregui's expert witness and discovered that she had no knowledge of the local standard of care. Consequently, Dr. Gallegos-Main moved for summary judgment, arguing that Arregui failed to meet the requirements for establishing a claim for medical malpractice which requires expert testimony regarding the local standard of care. Three days after the deadline, Arregui filed her Memorandum in Opposition to Defendant's Motion for Summary Judgment and included an affidavit from her expert with a sworn statement that she consulted a local chiropractor and was now familiar with the local standard of care. Dr. Gallegos-Main filed a Motion to Strike the affidavit as untimely and as a sham affidavit. Arregui unsuccessfully moved for reconsideration, arguing the court erred in striking her expert's affidavit and presented a new argument in the alternative that the court improperly granted summary judgment because the Medical Malpractice Act did not apply to chiropractors. The district court entered a final order denying the motion. Upon review, the Supreme Court affirmed the district court.

Washington Trust Bank (WTB) was the trustee of the trust created by Althea Bowman's last will and testament. Althea's four surviving children were the trust beneficiaries. Three of these beneficiaries argued to the district court that the Trustee exceeded its authority by encumbering a commercial property held by the trust with a deed of trust, and advancing funds to a fourth beneficiary. In that transaction, separate divisions of WTB acted as trustee (Trustee) and as the beneficiary of the deed of trust. The district court granted summary judgment in favor of the Trustee. Two of the beneficiaries appealed. Upon review, the Supreme Court affirmed the district court's order of dismissal because the Court concluded the Bowmans lacked standing and they asserted claims that were not ripe.

Security Financial Fund, LLC, ("Security Financial") extended to Byron and Marilynn Thomason ("the Thomasons") a series of loans evidenced by five promissory notes, which were secured by three deeds of trust and two mortgages on real property. As a result of the Thomasons' non-payment on two prornissory notes secured by the mortgages, Security Financial foreclosed on those notes. While the foreclosure was still pending, the Thomasons filed a separate action against Security Financial and others, addressing all the promissory notes executed in favor of Security Financial by the Thomasons. That action sought recovery for breach of contract and fraud, among other theories. Both actions were consolidated. On appeal from the district court's decision to grant Security Financial's Motion for Summary Judgment with regard to the claims that the Thomasons asserted in their fraud case, the Thomasons contended, among other things, that the district court lacked subject matter and personal jurisdiction to foreclose on the secured property and abused its discretion. The Supreme Court concluded that all of the Thomasons' claims were waived or frivolous, and accordingly affirmed the Final Judgment in favor of Security Financial.

Defendants-Appellants David and Pamela Randel appealed the denial of their request for attorney fees under I.C. 12-117, following the dismissal of a zoning enforcement action brought against them by the City of Osburn (City). The district court found the Randels to be the prevailing party but held they were not entitled to a fee award because the City had not pursued the action frivolously or without foundation. The Randels appealed to the Supreme Court and upon review, the Court affirmed: "the court discussed that, having considered the parties' arguments and the issues raised, it 'remain[ed] convinced that the action was not brought frivolously or without foundation.' That conclusion is eminently reasonable, especially since the City moved to dismiss the action when it failed to prevail on its motion for summary judgment. The court was presented with relatively little information about the merits of the action, and the arguments it did consider were fairly characterized as non-frivolous. The court acted within the bounds of its discretion and reached its decision through an exercise of reason. It, therefore, did not abuse its discretion when it denied the Randels' fee request."