Justia Constitutional Law Opinion Summaries

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

The issue before the Supreme Court in this case concerned the district court’s holding that Ashton Urban Renewal Agency (AURA) had standing to challenge a property tax exemption granted to Ashton Memorial, Inc., a corporation with real and personal property located within AURA’s revenue allocation area. Specifically, the issue was whether AURA was a “person aggrieved” under I.C. 63-511, and therefore, could appeal the grant of the exemption to the Idaho Board of Tax Appeals (BTA). The Supreme Concluded that AURA was an "person aggrieved" under the statute, therefore it affirmed the district court's decision. View "Ashton Urban Renewal v. Ashton Memorial" on Justia Law

Defendant-Respondent-Appellant Stephen Adams appealed a district court judgment that upheld a magistrate judge's order that dismissed his motions to modify child custody and child support. Defendant's had been held in contempt for failing to make one child support payment. He was unable to purge the contempt by paying all delinquent child support payments for reasons he said were beyond his control. A court can impose a criminal contempt sanction in nonsummary contempt proceedings only if the contemnor has been afforded the federal constitutional rights applicable to criminal contempt proceedings. The magistrate held that it could refuse to hear the Father's motions because he was unable to purge the contempt and could not prove that his inability was due to circumstances beyond his control. The district court held that refusal to hear the Father's motions was a permissible criminal contempt sanction. Idaho Code section 7-610 does not authorize denial of access to the courts as a criminal contempt sanction. Therefore, the district court erred in affirming the magistrate's order on the ground that it was a permissible criminal contempt sanction. The Supreme Court held that the district court erred in affirming the magistrate court's order. In addition, the Supreme Court held that refusal to hear a motion and dismissal of a motion that the contemnor did not purge the contempt violates Article I, Section 18 of the state constitution. The district court was reversed and the case remanded. View "Slane v. Adams" on Justia Law

This appeal stemmed from Native Wholesale Supply Company's (NWS) cigarette sales to Warpath, Inc. NWS is an Indian retailer organized under the tribal laws of the Sac and Fox Nation. It operates on the Seneca reservation in New York. Warpath is an Idaho corporation that operates on the Coeur d'Alene reservation. The State of Idaho brought suit against NWS for acting as a cigarette wholesaler without a permit and for selling cigarettes that are unlawful for sale in Idaho. The district court enjoined NWS from selling wholesale cigarettes in Idaho without a wholesale permit and assessed civil penalties in the amount of $214,200. NWS appealed that decision, arguing the State did not have subject matter jurisdiction or personal jurisdiction. Upon review, the Supreme Court affirmed in part, reversed in part, and remanded to the district court for further proceedings. The Court found that NWS's sales to Warpath were exempt from Idaho taxation, and NWS was not required to obtain a wholesale permit. Furthermore, the State had subject matter over NWS's importation of non-compliant cigarettes into the State of Idaho, and that the State could validly exercise personal jurisdiction over NWS. View "Idaho Tax Commission v. Native Wholesale Supply" on Justia Law