Justia Constitutional Law Opinion Summaries

In 2011, plaintiff-respondent Jamee Wade was shot twice by a Fruitland police officer after an altercation. Intending to file a claim under the Idaho Tort Claims Act, Wade sought copies of investigatory records related to the incident pursuant to the Idaho Public Records Act (IPRA). This appeal arose from a Petition for Access to Public Records filed by plaintiff seeking the disclosure of investigatory records in the possession of the Canyon County Prosecuting Attorney’s Office (CCPA). The district court ordered CCPA to produce the records pursuant to the request, but limited disclosure to Wade and his counsel. CCPA timely appealed. Upon review, the Supreme Court vacated the district court's judgment: the district court applied an erroneous legal standard in its analysis under I.C. 9-335. The records Wade requested were active investigatory records. View "Wade v. Taylor" on Justia Law

The issue before the Supreme Court in this case was a judgment dismissing an action wherein the plaintiff sought damages for injuries sustained as a result of contracting certain infections. The district court employed a differential diagnosis analysis and held that plaintiff's medical experts were required to rule out possible sources of the infections, other than the defendant's care. The district court determined that plaintiff's medical experts' opinions were inadmissible because they did not address the other possible sources of the infections that were suggested by defendant's medical expert. After its review, the Supreme Court concluded that the district court's determination was in error. Accordingly, the Court vacated the district court's judgment and remanded the case for further proceedings. View "Nield v. Pocatello Health Services" on Justia Law

This appeal arose from the dismissal of a petition for adoption filed by Jane Doe, the long-time domestic partner of Jane Doe I. Jane Doe I is the legally recognized parent of the two children subject to the adoption: John Doe and John Doe I. The magistrate court dismissed on the grounds that "petitioner must be in a lawfully recognized union, i.e. married to the prospective adoptee's parent, to have legal standing to file a petition to adopt that person's biological or adopted child." The magistrate dismissed the petition "sua sponte, without any motion or opposition to the Petition, without prior notice to any of the affected parties, without inviting legal briefing, without any apparent consideration of the Pre-Adoptive Home Study and without hearing." A Final Judgment was entered the same day. Jane Doe moved for reconsideration, but before a ruling on that motion was made, I.A.R. 12.2 compelled her to file a Notice of Appeal to the Supreme Court. Upon review, the Supreme Court concluded the district court violated Jane Doe's rights to due process by dismissing the petition without the opportunity to be heard in a meaningful manner. Furthermore, the Court found that Idaho's adoption statutes unambiguously allow a second, prospective parent to adopt, regardless of marital status. Therefore, the Court reversed the district court's judgment and remanded the case for further proceedings. View "In the Matter of Adoption of John Doe" on Justia Law

The State appealed the district court’s decision to affirm the magistrate court’s holding that it did not have jurisdiction over John (2012-10) Doe because he was twenty-one years of age when the State filed its petition in juvenile court. Upon review, the Supreme Court reversed the decision of the district court. View "Idaho v. John Doe (2012-10)" on Justia Law

This appeal arose from an action filed against Defendant-Respondent Mallory Martinez, a National Guard member, by Plaintiff-Appellant William Teurlings. Plaintiff alleged he suffered personal injury and economic damage resulting from a vehicle collision caused by defendant's negligence. Defendant moved for summary judgment asserting immunity under I.C. 6-904(4), which provides immunity to National Guard members for claims arising out of certain federal training or duty. The district court granted the motion after concluding defendant fell within the scope of the statutory immunity. Teurlings appealed, arguing that defendant was not immune because she was not "engaged in training or duty" and she was not acting within the course of her employment at the time of the collision. Finding that the district court erred in granting defendant immunity, the Supreme Court vacated the judgment in her favor and remanded the case for further proceedings. View "Teurlings v. Larson" on Justia Law

This appeal arose from a termination of parental rights based on a Consent in Abeyance. The Idaho Department of Health and Welfare (IDHW) filed a Petition for the Termination of Parental Rights after a prolonged child protection proceeding involving John Doe and his two children, S.M. and C.M. In the Consent, Doe agreed to the conditional termination of his parental rights in exchange for the magistrate court vacating the hearing set on the termination petition and having his children returned to his care on an extended home visit. Doe was subsequently arrested and the magistrate court entered a judgment terminating Doe’s parental rights to both children on the grounds that Doe had signed the Consent and failed to substantially comply with its terms. Doe appealed. The Supreme Court held that Idaho does not recognize conditional consent to the termination of parental rights, and a termination of parental rights based on conditional consent is invalid. The magistrate erred by involuntarily terminating Doe’s parental rights without a showing by clear and convincing evidence of grounds for termination. Accordingly, the Court vacated the trial court's judgment and remanded the case for further proceedings. View "RE: Termination of Parental Rights" on Justia Law

Dale Piercy appealed the district court’s dismissal of his amended action for declaratory relief, which challenged the validity of a herd district ordinance enacted in 1982 by the Canyon County Commissioners. The district court dismissed Piercy’s claim on the basis that it was barred by a seven-year statute of limitations or, in the alternative, a four-year statute of limitations. Piercy challenged the application of both statutes, and argued that Respondents Jennifer Sutton, Luis Guzman, and Canyon County waived any statute of limitations defense. Upon review, the Supreme Court found no reversible error, and affirmed the district court. View "Guzman v. Piercy" on Justia Law

In 1994, an en banc panel of the district judges of the Fourth Judicial District ordered Garden City and Meridian to provide suitable and adequate quarters for the magistrate’s division of the Fourth Judicial District. In addition to providing quarters, the Cities were ordered to provide for the equipment, staff, supplies, and other expenses necessary for the quarters to function properly. The Cities have never complied with the order. In 2010, Ada County brought a declaratory action asking the district judges to find that the 1994 Order was still valid and to require the Cities to comply with it. The Cities responded by filing a motion to vacate the 1994 Order, claiming that the order was invalid because it was entered on an ex parte basis. The en banc panel dismissed Ada County’s complaint, holding that a declaratory judgment action was not the appropriate means to determine the validity of the 1994 Order. The panel also denied the Cities’ motion to vacate on the grounds that before the 1994 Order was entered, the Cities had received all the process to which they were entitled. The Cities appealed. Finding that the appeal did not present a justiciable controversy, the Supreme Court dismissed the appeal. View "Ada County v. Garden City" on Justia Law

Appellant Farmers National Bank (FNB) appealed the district court's grant of declaratory judgment in favor of Green River Dairy, LLC, and four commodities dealers: Ernest Carter, Lewis Becker, Jack McCall, and Hull Farms (Sellers). FNB argued the district court misinterpreted I.C. 45-1802 (a statutory lien provision) and as a result, erred in granting Sellers a priority lien on collateral securing a loan previously made by FNB. Upon review, the Supreme Court agreed with FNB about the misinterpretation and vacated the district court's grant of declaratory judgment in favor of the Sellers. View "Farmers Nat'l Bank v. Green River Dairy" on Justia Law

Rita Turner petitioned the magistrate court for a protection order for her and her son against her then-husband Robert Turner. The magistrate court found that there was reasonable cause to believe that bodily harm might result to Rita and her son and issued a 90-day order. Robert appealed to the district court, which affirmed the magistrate court’s decision. Robert then appealed that decision. Because Robert failed to develop an argument, offered scarce citation to authority, and ignored the aspects of the law unfavorable to him, the Supreme Court concluded he brought this appeal frivolously, unreasonably, or without foundation. View "Turner v. Turner" on Justia Law