Justia Constitutional Law Opinion Summaries

This case involved a custody dispute between Charles Hernandez, the biological father of two minor children, and Janice Ausburn, the children's maternal grandmother. In 2001, the children's mother Kerri left the children with her mother Janice because she was struggling with drug addiction. The children continued to live with Janice and she raised them without physical help from Charles or Kerri. Charles had no physical contact with the children between November 2002 and early 2008. Kerri continued to struggle with personal issues and had nothing to do with the children after turning them over to Janice. Despite acting as the children's primary custodian, Janice never petitioned a court for guardianship. In 2008, Charles and Kerri stipulated to a change in the custody arrangement, whereby Charles would have sole physical custody of the children and Kerri would have visitation each summer. The court entered a modification order based on the stipulation. The court was unaware that the children were actually residing with Janice when it entered the order. Janice was not made aware of either the stipulation or the order. Janice found out about the plan and kept the boys home from school on the day Charles was to take them. Janice then filed a separate action for custody. In the subsequent proceeding, the court considered whether Charles or Janice should be the children's primary custodian. The court ultimately granted Charles sole legal custody and Charles and Janice shared physical custody, with Charles having primary custody and Janice having custody for six weeks during the summers. The court based its decision largely on a court-ordered assessment prepared by a third-party evaluator. Charles appealed the magistrate court's decision to the district court. He did not challenge the magistrate judge's factual findings but, rather, argued the award of limited custodial rights to Janice violated the Due Process Clause of the Fourteenth Amendment to the United States Constitution. Upon review of the trial court record and the applicable legal authority, the Supreme Court affirmed the district court's order.

Petitioner-Appellant Stan Hawkins appealed a decision by the Bonneville County Board of Commissioners that granted his neighbors Dale and Mary Meyers variances to replace aging homes on two parcels of their land. The parcels in question were originally zoned as agriculture, and each contained homes built before the 1940s. People living on the Meyers' land regularly used a road over Mr. Hawkins' land for access. Bonneville County enacted its zoning ordinance in 1959, after the homes on the Meyers' land were built and occupied. The ordinance required dwellings to have frontage along a county-approved road. No easement was ever granted across Mr. Hawkins' land, nor was a public road officially designated to the Meyers' property. The Meyers filed for variances in 2007 believing that they needed to comply with the frontage requirement. At a hearing, the Commissioners found that the Meyers' did not need variances because their property had been "grandfathered in" so that the frontage requirement did not apply. However, the Commissioners granted the variance anyway. A trial court dismissed Mr. Hawkins' petition for review, holding that he did not have standing to file a petition for judicial review, and he did not show that the County had prejudiced any of his substantial rights. Upon review of the trial court record, the Supreme Court found that Mr. Hawkins had standing to pursue his petition for judicial review. However, the Court dismissed his petition because he did not show any prejudice to his substantial rights. Accordingly, the Court affirmed the trial court's order dismissing Mr. Hawkins' petition.

Petitioner-Appellant Roger Steele and several residents appealed a district court order that dismissed their claim that the City of Shelley (City) illegally annexed land in Bingham County known as "Kelley Acres." The district court found that there was no statutory authorization for the district court's review of the annexation. On appeal to the Supreme Court, Appellants argued that the annexation was "arbitrary and capricious" and procedurally defective. Upon careful consideration of the arguments and the applicable legal authority, the Supreme Court found that there was indeed, no statutory authority for judicial review of the annexation. Furthermore, the Court found substantial evidence that supported the City's annexation of Kelley Acres. The Court affirmed the lower court's decision.

Plaintiff-Appellant James Wylie owned a subdivision in the City of Meridian. He sought a declaration from the district court that the City and the Idaho Transportation Department improperly denied access for his property directly onto a nearby state highway. The district court dismissed Plaintiffâs complaint on the ground that he failed to present a âjusticiable issue.â The Supreme Courtâs review of the record revealed that Plaintiff acquired the land in question subject to certain conditions recorded in the plat for the subdivision. The plat listed plainly that âthe subject property does have frontage along [the state highway] but . . . not direct access [to the highway].â The Court reasoned that Plaintiff failed to bring an issue for the Court to resolve since Plaintiffâs recorded deed clearly listed the frontage road as access to his property. Therefore, the Court reasoned that the case was ânon-justiciableâ and affirmed the lower courtâs decision to dismiss Plaintiffâs case.

A State trooper arrested Respondent Jason Miller for DUI. The trooper observed that Respondentâs pupils were dilated and asked that Respondent perform some field sobriety tests, which Respondent ultimately failed. The trooper discovered scissors in Respondentâs pocket that were used for cleaning a marijuana pipe. Respondent admitted to smoking marijuana âevery day.â The trooper took respondent to a hospital for a urine test, but at the hospital, Respondent refused to willingly provide a sample. A registered nurse at the hospital then catheterized Respondent at the trooperâs request, and extracted the sample. Respondent later pled guilty to possession of drugs, drug paraphernalia and to DUI. Respondent appealed the trial courtâs grant of summary judgment to the State. He argued that his civil rights under 42 U.S.C 1983 and state tort laws were violated when he was âunreasonablyâ catheterized. The Supreme Court found that because âAmerican search-and-seizure law is undeveloped as to when an officer may administer an involuntary warrantless catheterization on a suspect,â the state trooper was entitled to qualified immunity for both of Respondentâs the federal and state law claims.