Justia Constitutional Law Opinion Summaries

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

BV Beverage Company, LLC appealed the dismissal of its petition regarding the expiration of its liquor license. Idaho Alcohol Beverage Control (ABC) contended that BV Beverage's interest in its license expired by operation of law when BV Beverage's lessee failed to timely renew. BV Beverage argued that the agency’s procedures deprived it of adequate procedural due process. The district court dismissed BV Beverage's petition because there was no agency action to review; even if there was agency action, the action did not violate procedural due process because BV Beverage had actual knowledge of the expiration date of the liquor license. Finding no reversible error, the Supreme Court affirmed. View "BV Beverage Company v. Idaho Alcohol Beverage Control." on Justia Law

This appeal arose from the termination of Jeffry Black, the former Executive Director of the Idaho Peace Officer Standards and Training Council (POST). Black asserted that the Idaho State Police (ISP) violated two provisions of the Idaho Protection of Public Employees Act ("the "Whistleblower Act") when it terminated him. The district court granted summary judgment in favor of ISP, holding that Black failed to engage in activity protected under the Act. Black appealed the district court's decision to the Supreme Court. Finding no reversible error, the Supreme Court affirmed. View "Black v. Idaho State Police" on Justia Law

Plaintiff Wade Frogley appealed the district court's grant of summary judgment in favor of Respondents Meridian Joint School District No. 2, Aaron Maybon, and Linda Clark, on Frogley's complaint of retaliation in violation of Title VII of the Civil Rights Act and the Idaho Human Rights Act. Plaintiff also appealed the district court's grant of summary judgment in favor of Respondents on his claim of negligent infliction of emotional distress. Plaintiff's claims stemmed from his work as an Assistant Principal at Mountain View High School within the Meridian School District. He alleged that within weeks of his hire, he was subject to continuous sexual harassment at the school from the principal and other assistant principals. Upon review, the Supreme Court concluded genuine issues of material facts existed with regard to both of Plaintiff's claims. As a result, the Supreme Court reversed the district court's judgment and remanded the case for further proceedings. View "Frogley v. Meridian Joint School Dist 2" on Justia Law

The issue before the Supreme Court in this case related to the service of four members of the Board of Directors for the Southern Valley County Recreation District. The State brought usurpation actions against Donald Keithly, Yvette Davis, Patrick Cowles, and Michael Smith (the Directors), alleging they usurped their offices as directors of the Recreation District. The State requested they be removed from office and sought a fine against each of them. Upon the parties' cross-motions for summary judgment, the district court ruled that this action was an election contest, rather than a usurpation action, which could be brought by the State. The district court also ruled that the Directors' actions while in office were protected by the de facto officer doctrine. The State appealed, arguing this was a proper usurpation action and the de facto officer doctrine did not apply. The Directors cross-appealed, arguing they are entitled to attorney fees. The Supreme Court concluded the matter was moot and affirmed the district court's order denying attorney fees. View "Idaho v. Keithly" on Justia Law