Justia Constitutional Law Opinion Summaries

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.