Justia Constitutional Law Opinion Summaries

Greg and Cyndi Gomersall filed suit on behalf of their minor child, W.G.G., claiming he received negligent medical treatment at St. Luke’s Regional Medical Center (SLRMC) in Boise when he was injured in December 2010. W.G.G. was 6 years old at the time of the incident. The Gomersalls filed suit against SLRMC on January 25, 2019, more than eight years after W.G.G. was alleged to have been injured. SLRMC moved for summary judgment on the basis that the Gomersalls’ medical malpractice action was time-barred under Idaho Code sections 5-219(4) and 5-230. The district court granted SLRMC’s motion and dismissed the complaint with prejudice. The Gomersalls contended on appeal to the Idaho Supreme Court that the district court erred because Idaho Code section 5-230 was unconstitutional. Specifically, they argued that section 5-230 violated W.G.G.’s due process and equal protection rights by failing to toll the statute of limitations for medical malpractice claims until the age of majority. They also contended the district court erred when it held that the doctrine of equitable estoppel did not preclude SLRMC’s statute of limitations defense. Finding no reversible error, the Supreme Court affirmed the district court’s decision granting summary judgment in favor of SLRMC. View "Gomersall v. St. Luke's Regional Medical Center" on Justia Law

This case arose from an Idaho Industrial Commission determination denying an application for unemployment benefits. William Wittkopf appealed pro se the Commission’s determination that he was ineligible for unemployment benefits because he voluntarily quit his job without good cause and he willfully made a false statement or willfully failed to report a material fact in his unemployment application. On appeal, Wittkopf challenged the factual findings made by the Commission and argued it violated his right to due process by taking into consideration the fact that he voluntarily terminated his employment approximately two and a half years prior to applying for unemployment benefits. After review, the Idaho Supreme Court concluded: (1) Wittkopf failed to provide a cogent argument on appeal regarding whether his right to due process was violated; (2) the Commission’s determination that Wittkopf voluntarily terminated his employment at Stewart’s Firefighter without good cause and without exhausting all reasonable alternatives was supported by substantial and competent evidence; and (3) the Commission’s determination that Wittkopf willfully made a false statement or willfully failed to report a material fact in order to obtain benefits was supported by substantial and competent evidence. Accordingly, the Commission’s decision and order denying Wittkopf’s application for unemployment benefits was affirmed. View "Wittkopf v. Stewart's Firefighter Food Catering, Inc." on Justia Law

In 1985, Gerald Pizzuto Jr. murdered Berta and Delbert Herndon. Pizzuto was convicted of two counts of murder in the first degree, two counts of felony murder, one count of robbery, and one count of grand theft. He was sentenced to death for the murders. Between 1986 and 2003, Pizzuto filed five petitions for post-conviction relief. His fifth petition for post-conviction relief was predicated on the holding in Atkins v. Virginia, 536 U.S. 304 (2002), in which the U.S. Supreme Court held that the execution of an intellectually disabled person constituted cruel and unusual punishment in violation of the Eighth Amendment to the United States Constitution. In his fifth petition, Pizzuto asserted that his death sentence should be “reversed and vacated” because he was intellectually disabled. The district court summarily dismissed Pizzuto’s petition. The Idaho Supreme Court held that the district court did not err when it dismissed Pizzuto’s fifth petition for post-conviction relief on the basis that Pizzuto had failed to raise a genuine issue of material fact supporting his claim that he was intellectually disabled at the time of the murders and prior to his eighteenth birthday. Pizzuto pursued this same claim in a federal habeas corpus action. In 2016, the U.S. District Court for the District of Idaho denied Pizzuto’s successive petition for writ of habeas corpus after holding a four-day evidentiary hearing in 2010. Although it affirmed the federal district court’s decision denying Pizzuto’s successive petition for writ of habeas corpus, the Ninth Circuit stated in dicta that its decision does not preclude Idaho courts from reconsidering whether Pizzuto was intellectually disabled at the time of the murders. Based on this dicta, Pizzuto filed a motion with the district court to alter or amend the judgment dismissing his fifth petition for post-conviction relief in accordance with Idaho Rule of Civil Procedure 60(b)(6). The district court denied Pizzuto’s Motion in early 2020. Because the district court did not abuse its discretion in denying Pizzuto’s Motion, the Idaho Supreme Court affirmed the district court’s decision. View "Pizzuto v. Idaho" on Justia Law

Daniel Chernobieff appealed a district court’s decision on intermediate appeal to uphold a magistrate court’s summary dismissal of his petition for post-conviction relief. Chernobieff was convicted of a misdemeanor for driving under the influence with an excessive blood alcohol content in June 2014. After the Idaho Supreme Court upheld his conviction on direct appeal, Chernobieff filed a petition for post-conviction relief on the basis of ineffective assistance of counsel. He alleged that his defense counsel’s decision to object to testimony at a suppression hearing suggesting that the on-call magistrate could not be reached to obtain a warrant because his cell phone ringer was off was unreasonable and prejudicial. He argued that the objection to the ringer testimony prevented him from arguing at trial that the State did not have good cause for the on-call magistrate's unavailability. The magistrate court granted the State's motion for summary dismissal, reasoning the objection was an unreviewable strategic decision and would not have changed the outcome of the case. The district court, sitting in an appellate capacity, affirmed. Finding no reversible error, the Supreme Court also affirmed. View "Chernobieff v. Idaho" on Justia Law

A group of prisoners (“Petitioners”) sought a writ of habeas corpus based on the conditions of their confinement during the COVID-19 pandemic. The Petitioners were all incarcerated at the Elmore County Jail (“Jail”), contending the conditions of confinement constituted cruel and unusual punishment in violation of the Eighth Amendment to the United States Constitution. More specifically, the Petitioners claimed they were in imminent danger because officials at the Jail did not implement any discernable mitigation measures in response to the COVID-19 pandemic. Elmore County Sheriff Mike Hollinshead and Lieutenant Shauna Gavin (collectively “Officials”) denied this assertion, contending that Petitioners’ request for a writ of habeas corpus should have been denied because the Petitioners did not exhaust their administrative remedies. The Officials filed a motion for summary judgment with the district court, which was granted. The district court also awarded the Officials their attorney fees. Petitioners timely appealed the district court’s decisions to the Idaho Supreme Court, which agreed to hear the appeal on an expedited basis. After that review, the Supreme Court affirmed the district court’s decision granting summary judgment, but reversed the district court’s award of attorney fees. View "Williams v. Hollinshead" on Justia Law

The Idaho Department of Finance ("Department") filed a civil enforcement action against appellant appellant, Sean Zarinegar, Performance Realty Management LLC ("PRM") and other nominal defendants, alleging Zarinegar and PRM committed securities fraud. The Department moved for summary judgment; Zarinegar and PRM responded with their own motion for partial summary judgment and a motion to strike several documents submitted by the Department in support of its motion for summary judgment. A few days before the district court was set to hear arguments on the motions, counsel for Zarinegar and PRM moved the district court for leave to withdraw as counsel of record. At the hearing, the district court preliminary denied the motion to withdraw, entertained the parties’ arguments, and took all matters under advisement. The district court later issued a memorandum decision and order denying, in part, Zarinegar’s, and PRM’s motions to strike. The district court also denied Zarinegar’s and PRM’s motion for partial summary judgment. The district court granted summary judgment for the Department after finding Zarinegar and PRM had misrepresented and omitted material facts in violation of Idaho Code section 30-14-501(2) and fraudulently diverted investor funds for personal use in violation of section 30-14-501(4). The district court then granted the motion to withdraw. The district court entered its final judgment against Zarinegar and PRM September 30, 2019. Zarinegar, representing himself pro se, appealed the judgment, arguing: (1) the district court lacked jurisdiction to enter judgment against him; (2) the district court violated his constitutional right to a jury trial and right to proceed pro se; (3) the district court’s denial of Zarinegar’s motions to strike as to certain documents was an abuse of discretion; and (4) the district court erroneously granted summary judgment for the Department. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgment. View "Idaho v. Zarinegar" on Justia Law

A guardian ad litem (GAL) for two minor children appealed after a magistrate court determined the children should have been placed with their biological father in Mexico. Jane Doe I (Daughter) and John Doe II (Son) were removed from the care of their mother (Mother) along with another half-sibling on after a preliminary investigation revealed the children were homeless and living in a car. At the time Daughter and Son were taken into foster care, the specific whereabouts of their biological father, John Doe (Father), were unknown, other than that he had been deported to Mexico in December 2014. Father had last seen the children at that time. In addition, his paternity had not yet been established and he had not had any contact with his children since his deportation. A little more than a year after the proceedings had begun, Father’s paternity was established. Shortly after the Department filed an amended petition, it sought a case plan for Father. The Department also attempted to obtain a home study for Father but faced difficulty accomplishing this task because he lived in Mexico. The children’s GAL opposed placing the children with Father without more information about him and his living situation. Ultimately, the magistrate court ordered that the children be placed with Father as soon as possible without a home study being conducted, apparently relying on In re Doe, 281 P.3d 95 (2012). On motions to reconsider filed by the Department and the GAL, newly-discovered evidence was presented that Father was a registered sex offender who had previously pleaded guilty to failing to register as such. Nevertheless, the magistrate court denied the motions to reconsider. The GAL appealed. After review, the Idaho Supreme Court reversed the magistrate court, holding that while it continued "to recognize that the biological parent’s presumption of fitness is and should be very strong. However, it is not irrefutable. . . . Where the legislature has unequivocally placed a duty on the court and the Department to consider its primary concern 'the health and safety of the child,' it is incumbent on a court to ensure that diligent investigation occurs regarding questions pertaining to children’s safety." View "IDHW & John Doe v. GAL & 4th Judicial District Casa" on Justia Law

In 2016, John Doe was cited for petit theft. Doe’s disposition hearing was held, and the magistrate court committed Doe to the custody of Idaho Department of Juvenile Corrections (“IDJC”). the magistrate court ordered Doe’s father, Dennis Dudley, to reimburse IDJC for expenses incurred in caring for and treating Doe pursuant to Idaho Code section 20-524(1). Doe and Dudley appealed the reimbursement order to the district court. The district court, acting in its intermediate appellate capacity, affirmed. Doe and Dudley timely appealed the district court’s decision. The Idaho Supreme Court dismissed the appeal, finding the reimbursement order against Dudley was not a final appealable order. View "IDJC v. Dudley" on Justia Law

Petitioner Sherri Ybarra, the Idaho Superintendent of Public Instruction, petitioned the Idaho Supreme Court for a declaratory judgment, writ of mandamus, or writ of prohibition to remedy various alleged constitutional violations by the Idaho Legislature and the Idaho State Board of Education related to the funding and supervision of eighteen employees currently working in the Idaho Department of Education. During the 2020 legislative session, the Idaho Legislature passed two appropriation bills - Senate Bills 1409 and 1410 - which transferred supervision of eighteen full-time job positions within the Department’s Technology Group to the Board along with approximately $2.7 million in funding for those positions. The Superintendent argues that “by splitting eighteen employees away from three other workers and eliminating all funding for the office space, rent, and the maintenance and upgrading of the Department’s computers, this line item appropriation decentralizes and damages operations.” She also claimed these bills were the Legislature’s attempt to “strip the Superintendent of her authority through the budget process,” in retaliation for her failure to support a 2019 revised school funding formula. To effectuate such relief, the Superintendent invoked the Supreme Court's original jurisdiction, seeking a declaratory judgment that the Appropriation Bills were unconstitutional. The Superintendent sought a writ of mandamus and/or prohibition that would allow SB 1409's funding appropriation to the Board remain intact, but would restore the Superintendent's full management authority over the Technology Group. The Supreme Court found the Appropriations Bills constitutional, thereby declining to address requests for writs of mandamus and/or prohibition. View "Ybarra v. Legislature of the State of Idaho" on Justia Law

Natalie Shubert sued her former public defender, Michael Lojek, former Ada County chief public defender Alan Trimming, and Ada County (collectively the “Ada County Defendants”). In 2008, Shubert was charged with two felonies and pleaded guilty to both charges. Her sentences were suspended in each case, and she was placed on probation. After a probation violation in 2011, the Ada County district court entered an order extending Shubert’s probation beyond the time period allowed by law. The mistake was not caught. After Shubert’s probation should have ended in both cases, she was charged and incarcerated for a subsequent probation violation in 2014. Thereafter, in 2016, Shubert was charged with a new probation violation. Shubert was assigned a new public defender, who discovered the error that unlawfully kept Shubert on probation. Shubert’s new public defender filed a motion to correct the illegal sentence, raising the error that had improperly extended her probation. The district court granted Shubert’s motion to correct the illegal sentence and released Shubert from custody. Shubert then sued the Ada County Defendants, alleging false imprisonment, intentional infliction of emotional distress, negligence per se, negligence, and state and federal constitutional violations. The district court dismissed all of Shubert’s claims except for negligence. In denying the Ada County Defendants’ motion for summary judgment, the district court held that public defenders were not entitled to common law quasi judicial immunity from civil malpractice liability, and two provisions of the Idaho Tort Claims Act (ITCA) did not exempt public defenders from civil malpractice liability. The Ada County Defendants petitioned the Idaho Supreme Court pursuant to Idaho Appellate Rule 12. Finding no reversible error in the district court's judgment, the Supreme Court affirmed the district court’s order granting summary judgment, and remanded for further proceedings. View "Shubert v. Ada County" on Justia Law