Justia Constitutional Law Opinion Summaries

This appeal came from a district court’s decision to bar Steven Picatti’s 42 U.S.C. section 1983 claims against two deputies on the basis of collateral estoppel. In 2014, Picatti struggled to drive home because road access was blocked for the Eagle Fun Days parade. After circumventing some orange barricades, Picatti drove toward two uniformed deputies who were on foot patrol by a crosswalk, which was marked with a large sign reading: “road closed to thru traffic.” Picatti contended Deputy Miner hit the hood of his car, then pulled Picatti out of his truck to tase and arrest him. The deputies contended Picatti “bumped” Deputy Miner with his truck and then resisted arrest, forcing them to tase him into submission. Picatti was ultimately arrested on two charges: resisting and obstructing officers (I.C. § 18-705), and aggravated battery on law enforcement. Ultimately, Picatti was convicted, accepting a plea agreement to disturbing the peace and failure to obey a traffic sign. Two years later, Picatti brought his 42 U.S.C. 1983 suit, claiming he was deprived of his rights to be free from (1) unreasonable seizure, (2) excessive force, and (3) felony arrest without probable cause. The district court granted summary judgment to the deputies, holding that collateral estoppel barred Picatti from relitigating probable cause once it was determined at the preliminary hearing. The Idaho Supreme Court affirmed summary judgment to the deputies as to Picatti’s claims of false arrest and unreasonable seizure; however, the Court vacated summary judgment as to Picatti’s excessive force claim. The district court correctly applied the doctrine of collateral estoppel to Picatti’s claims of false arrest and unreasonable seizure, but not as to excessive force. In addition, the Court could not find as a matter of law that the deputies were entitled to qualified immunity on Picatti’s excessive force claim when there was a genuine issue of material fact. View "Picatti v. Miner" on Justia Law

The Idaho Supreme Court considered a permissive appeal that presented a case of first impression regarding whether the tort of defamation by implication existed in Idaho. Respondent James Verity was a school teacher in Oregon who lost his teaching license after engaging in an inappropriate relationship with an eighteen-year-old female student, whom he coached at the local high school. He eventually obtained a teaching license in Idaho, and began teaching shortly thereafter. When he was forced to resign his teaching job in Idaho after USA TODAY, KTVB, KGW, Tami Tremblay, and Stephen Reilly published articles and broadcast news reports describing Verity’s misdeeds, he and his wife Sarahna Verity filed a lawsuit alleging defamation by implication. The district court denied the media’s motion for summary judgment and ruled that despite the actual truth of the statements, reasonable minds could find that the media impliedly defamed the Veritys. The media appealed that decision as a permissive appeal under Idaho Appellate Rule 12. The Supreme Court affirmed the district court’s conclusion that Verity was not a public official or a public figure, and affirmed the district court’s conclusion that a reasonable jury could find that KGW impliedly defamed Verity about his having a sexual relationship with a minor. The Court reversed the district court on all of Verity’s remaining claims and remanded for further proceedings. View "Verity v. USA Today, et al" on Justia Law

On November 20, 2018, the Acting Governor of Idaho issued a proclamation that Proposition 2 had passed, and subsequently the Idaho Code was amended to add section 56-267, a statute to expand Medicaid eligibility in Idaho. Petitioner Brent Regan argued 56-267 violated Idaho’s Constitution by delegating future lawmaking authority regarding Medicaid expansion to the federal government. Regan requested the Idaho Supreme Court declare section 56-267 unconstitutional and issue a writ of mandamus to direct the Secretary of State Lawerence Denney to remove section 56-267 from the Idaho Code. Finding the statute constitutional, the Supreme Court dismissed Regan’s petition and denied his request for a writ of mandamus. View "Regan v. Denney" on Justia Law

This case was brought by the North Idaho Building Contractors Association, Termac Construction, Inc., and other class members (collectively, “NIBCA”), to declare a sewer connection/capitalization fee the City of Hayden enacted in 2007 to be an impermissible tax. The action was originally dismissed on the City’s motion for summary judgment; but, on appeal the Idaho Supreme Court vacated the district court's judgment and remanded for further proceedings because the record did not contain sufficient evidence to establish that the 2007 Cap Fee complied with controlling Idaho statutes and case law. On remand, the parties filed cross motions for summary judgment and the district court found that the 2007 Cap Fee was an impermissible tax and taking of property without just compensation in violation of federal takings law. In doing so, the district court refused to consider expert evidence propounded by the City which opined that the 2007 Cap Fee complied with the applicable Idaho legal standards and was reasonable. The district court subsequently ruled on stipulated facts that NIBCA was entitled to damages in the amount paid above $774 per connection, together with interest, costs, and attorney fees. The City appealed the district court’s refusal to consider its evidence and NIBCA cross-appealed the award of damages. The Idaho Supreme Court again vacated the judgment because the district court improperly refused to consider the City’s evidence on remand. View "No ID Bldg Cont Assoc v. City of Hayden" on Justia Law

Dennis and Wanda Irish appealed a district court order granting a directed verdict in favor of Jeffrey and Dona Hall. The Irishes brought a defamation action against the Halls after the Halls changed their home wireless internet designation to read, “[D]ennis & [W]anda Irish stocking u2.” The complaint requested an injunction, damages, attorney fees and costs. This followed an acrimonious history between the parties stemming from Wanda Irish’s role as the mayor of the city of Harrison. The district court granted the Halls’ motion for a directed verdict, concluding the statement conveyed via the wireless designation was an opinion, and as such was protected under the First Amendment. The Irishes appealed the district court’s order, and the Halls cross-appealed, challenging the district court’s denial of attorney fees. The Idaho Supreme Court determined the district court erred in granting the Halls’ motion for a directed verdict, finding the phrase “[D]ennis & [W]anda Irish stocking u2” was not a statement of opinion, political criticism, or hyperbole. The Court vacated the directed verdict, affirmed the denial of attorney fees, and remanded for further proceedings. View "Irish v. Hall" on Justia Law

This cases involved the statutory termination of parental rights by two adoptive parents after John Doe I (“Child”) was alleged to have sexually assaulted a sibling. John and Jane Doe adopted Child in June 2016. The Does’ adoption came after a previous out-of-state adoption of Child was ended through legal termination of parental rights (a “disrupted adoption”). In September 2016, the Idaho Department of Health and Welfare (“the Department”) received a report from Jane Doe that Child had sexually assaulted his younger sister (aged nine), another adoptive child of the Does. Child was twelve years old at the time of the incident. Thereafter, the Does worked with the Department and juvenile corrections personnel to determine the best course of action with regard to Child. In October 2016, Child’s juvenile corrections proceeding was expanded to a child protective proceeding, and he was placed in shelter care with the Department. The expansion order specified that “[t]he parents indicate [Child] will never be able to return to their home due to the safety of the other children.” Child was subsequently taken to a residential care facility in Utah (“the Utah facility”) to receive treatment, including mental health services. The treatment program was not permanent placement, but Child’s completion of the program was expected to take up to a year. Shortly after Child was taken to the Utah facility, the magistrate court decreed that Child was to be placed under the protective custody of the Department because it would be contrary to Child’s welfare to remain in the Does’ home. The magistrate court then held a hearing on the case plan submitted by the Department and approved the plan without any objections from the parties. The magistrate court ultimately entered judgments (one for each parent) terminating the Does’ parental rights on three grounds: inability to discharge parental responsibilities, best interest of the Does and Child, and voluntary consent. Child appealed. The Idaho Supreme Court determined the magistrate court record did not support the finding of termination: “[w]ithout compelling substantive evidence, the primary argument for the Does’ unfitness appears to be premised on the same idea that undergirded the Department’s argument as to Child’s best interest: namely, Child cannot return to the Does’ home due to the nature of the sexual assault incident and the presence of the victim and other children in the home.” The Supreme Court reversed the termination of parental rights and the order of guardianship, and remanded this case for further proceedings. View "Dept. of Health & Welfare v. Doe I (2017-21)" on Justia Law

In 2016, the Economic Advisory Council (“the EAC”), a body created under authority of Idaho Code section 67-4704, granted a tax credit of $6.5 million to Paylocity, an Illinois corporation. Employers' Resource Management ("Employers") complaint alleged that this tax credit was a governmental subsidy to Paylocity that would give it a competitive advantage over Employers. Employers challenged the Idaho Reimbursement Incentive Act ("IRIA") program as unconstitutional, alleging that the Legislature unconstitutionally delegated its authority over tax matters to the Executive Branch. The district court dismissed Employers' complaint for declaratory relief for lack of standing. The district court’s rejection of Employers’ claim of competitor standing was, in part, based upon its view that “even when competitor standing has been recognized, ‘it is only when a successful challenge will set up an absolute bar to competition, not merely an additional hurdle, that competitor standing exists.’ ” The Idaho Supreme Court was not persuaded that view was an accurate statement of the law of competitor standing, and vacated the district court's judgment.The case was remanded for further proceedings. View "Employers Resuorce Mgmt Co v. Ronk" on Justia Law

Kenneth and Donna Johnson appealed a district court judgment recognizing a tribal judgment from the Coeur d’Alene Tribal Court (Tribal Court). The Johnsons owned land within the Coeur d’Alene Reservation (Reservation) on the banks of the St. Joe River and had a dock and pilings on the river. The Coeur d’Alene Tribe (Tribe) initiated an action in Tribal Court to enforce a tribal statute which required a permit for docks on the St. Joe River within the Reservation. The Johnsons did not appear and a default judgment was entered against them. The judgment imposed a civil penalty of $17,400 and declared that the Tribe was entitled to remove the dock and pilings. On January 2016, the Tribe filed a petition to have the Tribal Court judgment recognized in Idaho pursuant to the Enforcement of Foreign Judgments Act. I.C. sections 10-1301, et seq. The district court held the Tribal Judgment was valid and enforceable, entitled to full faith and credit. However, the Idaho Supreme Court determined the district court was incorrect in holding the Tribal Judgment was entitled to full faith and credit, and the civil penalty was not entitled to recognition in Idaho courts. However, the Idaho Supreme Court held the Tribal Court had jurisdiction over the Johnsons and the subject matter of this case; the Johnsons did not meet their burden of establishing the Tribal Court did not have jurisdiction, and the Johnsons were afforded due process in Tribal Court. In this case the judgment comprised two parts: (1) the civil penalty of $17,400; and (2) the declaration that the Tribe had the right to remove the offending encroachment. The civil penalty was not enforceable under principles of comity. However, the penal law rule does not prevent courts from recognizing declaratory judgments of foreign courts. Therefore, the Idaho Supreme Court vacated the district court’s judgment to the extent that it recognized the Tribal Court’s judgment imposing the civil penalty of $17,400. The Court affirmed the judgment recognizing the Tribal Court judgment regarding the Tribe’s right to remove the dock and pilings. View "Coeur d' Alene Tribe v. Johnson" on Justia Law

Manwaring Investments, L.C., owner of a commercial building in the City of Blackfoot, appealed a district court order granting summary judgment to the City. Manwaring sued the City in October 2014, alleging the City was overcharging it for wastewater utilities ​and stopped paying the disputed portion of fees. Manwaring’s complaint alleged that the assessment of two Equivalent Dwelling Units (EDUs) on the Building: (1) violated the Idaho Revenue Bond Act; (2) constituted an unconstitutional tax; and (3) violated due process. In addition to requesting a declaratory judgment and an injunction, Manwaring requested damages in the amount of $1,803.66, which reflected the amount Manwaring allegedly overpaid for wastewater utilities. The magistrate granted the City’s motion for summary judgment. Manwaring moved for reconsideration, which the magistrate denied. Manwaring then appealed the magistrate’s rulings to the district court, which affirmed the magistrate. Manwaring timely appeals the decision of the district court. Finding no reversible error, the Idaho Supreme Court affirmed. View "Manwaring Investments, L.C. v. City of Blackfoot" on Justia Law

At issue in this appeal was a judgment dismissing an action seeking to recover money unlawfully collected by the City of Pocatello from users of the City’s water and sewer systems. In 2005, the city government decided that the City should be able to operate its water and sewer systems at a profit like private utilities. By law, the City was required to charge and collect sufficient fees so that its water and sewer systems “shall be and always remain self-supporting.” Those fees had to be sufficient to pay when due all bonds and interest as required by Idaho Code section 50-1032(a) and “to provide for all expenses of operation and maintenance of such works . . . , including reserves therefor,” as required by Idaho Code section 50-1032(b). The City wanted to obtain a profit in excess of the amounts necessary for the water and sewer systems to remain self-supporting. This profit was paid into the general fund. The City instituted a program called "PILOT," which stood for payment in lieu of taxes, under which city-owned water and sewer departments paid "property taxes" to the City as if they were private entities, and the departments then passed this cost on to their customers. The “property taxes” were then paid into the City’s general fund. Plaintiffs sought a refund of the PILOT sums that they had paid. In granting summary judgment, the district court held that the imposition of the PILOT was not a compensable taking. The district court appeared to rely upon two grounds for that decision: (1) "Some courts have made that determination on the grounds that money is not 'property' within the meaning of the Takings Clause," and (2) "Other courts ‘have concluded that governmental-imposed obligations to pay money are not the sort of governmental actions subject to a takings analysis.?” The Idaho Supreme Court determined both of these rationales were incorrect, reversed and remanded for further proceedings. View "Hill-Vu Mobile Home Pk v. City of Pocatello" on Justia Law