Justia Constitutional Law Opinion Summaries

The issue before the Supreme Court in this case centered on a district court's judgment to condemn an easement across the appellants' real property for an irrigation pipeline. The Supreme Court found no error in the district court's holding that there was a reasonable necessity required for condemnation of the easement in question. The Court vacated a portion of the judgment as it pertained to Defendants-Appellants Donald and Carolyn Cain's counterclaim and the award of a perpetual easement across their property, but the Court affirmed in all other respects. The case was remanded for further proceedings. View "Telford Lands v. Cain" on Justia Law

Appellant Alpine Village appealed a district court's grant of summary judgment in favor of the City of McCall. Alpine sued the City to enforce Ordinance 819 (found to be unconstitutional in a separate proceeding), and argued that the City unlawfully took its property in violation of the federal and state constitutions. Finding that the district court did not err in its finding that Alpine's state law claims were barred for failing to bring them according to the notice requirements of the Idaho Tort Claims Act, and that the federal claims were not ripe for adjudication, the Supreme Court affirmed the district court's decision. View "Alpine Village v. City of McCall" on Justia Law

Alva Garrett owned an 80-acre parcel of property in Middleton. He sold most of the property to pay off debt. Alva owned the property in his name, but in 1990, executed a quitclaim deed to himself and his wife Thelma. In 2006, Alva executed a second quitclaim deed to his son, Plaintiff Jack Garrett. Alva gave the 2006 deed to Jack's brother John with instructions not to record it until Alva died. Alva died in 2008, and the deed was recorded. Jack then sued his stepmother Thelma to partition the property. After a bench trial, the court ruled that the 1990 deed re-characterized the property from separate to community property, invalidating the 2006 deed. Jack appealed, but the Supreme Court agreed with the trial court's conclusion. Therefore, the Supreme Court affirmed. View "Garrett v. Garrett" on Justia Law

This appeal arose from an action filed against the City of Lewiston by Tim Thompson, Janet Thompson, and Thompson's Auto Sales (collectively, Thompson). Thompson filed a claim under the Idaho Tort Claims Act (ITCA), alleging the City negligently designed and installed a storm water drain system on a city street adjacent to Thompson's property, which caused storm water runoff to flow onto Thompson's property and damage it. After suit was filed, Thompson entered bankruptcy proceedings and the bankruptcy trustee, C. Barry Zimmerman, was substituted as Plaintiff in the action. The City moved for summary judgment on the grounds of discretionary immunity and design immunity. The district court denied the motion as to design immunity, but granted the motion on the ground of discretionary immunity. Zimmerman appealed, arguing that the discretionary immunity exception to liability under the ITCA does not grant immunity from liability for damage caused by negligent design and, alternatively, that even if discretionary immunity was considered, it was inapplicable in this case because the City's actions were not discretionary within the meaning of the exception. Upon review, the Supreme Court reversed, finding that the City was not entitled to immunity from liability under any exception to the ITCA. View "Zimmerman v. City of Lewiston" on Justia Law

Plaintiff Thomas R. Taylor filed this action seeking to recover damages for alleged medical malpractice. Pursuant to Idaho Code section 6-1001, he then filed a request for a prelitigation screening panel four days later. The panel appointed regarding the alleged malpractice in this case conducted its proceedings and then issued its report on April 19, 2011. Although Plaintiff filed this action on January 20, 2011, he did not attempt to serve the summons and complaint upon any of the Defendants within six months after filing the complaint as mandated by Rule 4(a)(2) of the Idaho Rules of Civil Procedure. On August 16, 2011, defendant Eastern Idaho Health Services, Inc. filed a motion to dismiss this action as to it for the failure of Plaintiff to serve the summons and complaint upon it within the six-month period. Plaintiff filed a motion asking the district court to stay this lawsuit "nunc pro tunc from January 24, 2011, to April 19, 2011, or, alternatively, to extend [Plaintiff's] deadline for serving all Defendants to this lawsuit from July 19, 2011, to October 12, 2011." The district court entered an order denying Plaintiff's motions and granting the motions to dismiss filed by defendants. Plaintiff filed a notice of appeal. Because the partial judgment was not yet final due to the fact that there was no judgment resolving the claims against the remaining defendants, the Supreme Court then issued a notice that the appeal would be dismissed. Plaintiff then filed an amended notice of appeal timely appealing both the initial judgment and the amended judgment. The Supreme Court affirmed the district court: if there is not good cause for the failure to serve a defendant with the summons and complaint within six months after the complaint was filed, Rule 4(a)(2) states that "the action shall be dismissed as to the defendant without prejudice." Had Plaintiff served the Defendants before the prelitigation screening panel had completed its work, the worst that could have happened is that the district court would have stayed the court proceedings until after the panel had completed its work and for thirty days thereafter. Even if Plaintiff had thought he should wait until thirty days after the panel issued its report before serving the Defendants with a summons and complaint, he had from May 19, 2011, until July 20, 2011 to do so, but did not even attempt service during that time. View "Taylor v. Chamberlain" on Justia Law

At issue before the Supreme Court in this case was appeal and cross-appeal of summary judgments dismissing claims against Defendants Ada County, Deputy Jeremy Wroblewski, Kate Pape, and James Johnson in a 42 U.S.C. 1983 civil rights action brought by Rita Hoagland on behalf of herself and the estate of her deceased son, Bradley Munroe ("Munroe"), claiming a violation of a Fourteenth Amendment right to medical care and safety while Munroe was detained at Ada County Jail where he committed suicide. Munroe had a history of incarceration at Ada County Jail ("ACJ"). During the evening of September 28, 2008, Munroe was arrested and charged with the armed robbery of a convenience store. Munroe was intoxicated and uncooperative. During booking, Munroe was screaming and being rowdy. Munroe took a string and wrapped it around his neck. Because of his bizarre behavior throughout the night, Munroe was placed in a holding cell for observation until he was sober. The next morning booking continued. At that time, Munroe requested protective custody. Munroe was placed in a cell by himself and a well-being check was scheduled to occur every thirty minutes. Later that evening during a well-being check, the performing deputy found Munroe hanging from his top bunk by a bed sheet. Munroe was pronounced dead later that evening. Among the issues on appeal were: whether the decedent's estate could assert a 42 U.S.C 1983 action for alleged violations of the decedent's constitutional rights; whether the parent had standing to assert a 42 U.S.C. 1983 action for the death of her adult child while incarcerated; and whether the district court erred in awarding costs to Defendants. Upon review, the Supreme Court concluded that the district court: (1) was affirmed in dismissing Hoagland's 1983 claim on behalf of Munroe's estate; (2) was reversed in finding that Hoagland had a 1983 cause of action for violations of her own constitutional rights; (3) was partially affirmed in its award of costs as a matter of right; (4) was reversed in its award of discretionary costs; and (5) was affirmed in denying attorney fees. The case was remanded for the reconsideration and entry of express findings regarding the district court's award of discretionary costs. View "Hoagland v. Ada County" on Justia Law

In 2011, Gordon Ravenscroft filed a Petition for Judicial Review against Boise County, its Board of Commissioners, and other individual defendants. The petition sought review of the Board's final decision terminating Ravenscroft's employment. The petition claimed Ravenscroft was denied his constitutional right to due process, the board acted outside the bounds of its authority, and his firing was arbitrary, capricious, and an abuse of discretion. In response, the Board filed a motion to dismiss arguing that the district court was without jurisdiction to hear an appeal of a county personnel determination. The district court determined that it had jurisdiction over the Board's decision to terminate Ravenscroft because the decision was an "action" under I.C. 31-1506. The Board then sought permission to appeal this decision, which the district court granted. The question in this case is whether the Board's decision to terminate Ravenscroft is subject to the judicial review provisions of the Idaho Administrative Procedure Act [IAPA]. The IAPA and its judicial review provisions do not apply to the actions of local governing bodies, unless expressly authorized by statute. The Supreme Court concluded that the Board's decision to terminate Ravenscroft was an "Act" under I.C. 31-1506, and that his at-will status did not change the scope of Ravenscroft's claim. "If the employment is at will, judicial review will not enable the court to change it to employment terminable only for cause." The Court affirmed the district court's determination that the Board's decision to terminate Ravenscroft was an action under 31-1506. View "Ravenscroft v. Boise County" on Justia Law

Petitioner Peter Kaseburg was a littoral owner on Lake Pend Oreille who held an encroachment permit for a series of decaying wooden pilings that were driven into the lakebed in the 1930s. With the exception of a single piling that a neighboring marina uses to anchor one of its docks, the pilings never had any known navigational purpose. Petitioner applied to the Idaho Department of Lands (IDL) for a permit to replace ten of the wooden pilings with steel pilings, but failed to specify any navigational purpose for this proposal. The IDL considered the application a request for a nonnavigational encroachment permit and denied it after receiving several objections. While a final decision was still pending on the first permit application, Petitioner filed a second application for a permit to install a mobile dock system and mooring buoy. The IDL considered the second application a request for a permit for a navigational encroachment extending beyond the line of navigability. Again, the IDL received many objections and denied the application. Petitioner then sought judicial review, which reversed the IDL. The court held that all pilings were navigational encroachments as a matter of law, regardless of whether they have ever been used to aid navigation. The district court set aside both denials. The IDL appealed to the Supreme Court. Upon review, the Supreme Court reversed the district court with respect to the first application, but affirmed the district court with respect to the second. View "Idaho Bd of Land Comm v. Kaseburg" on Justia Law

This was an action brought by the grantor of a deed of trust to stop nonjudicial foreclosure proceedings based upon the contention that MERS, the Mortgage Electronic Registration Systems, which was the named beneficiary as nominee for the lender, could not legally act as the beneficiary. The defendants moved to dismiss this action on the ground that the complaint did not state a claim upon which relief could be granted. The district court agreed and entered judgment in favor of the defendants. Upon review, the Supreme Court affirmed the district court's judgment. View "Edwards v. MERS" on Justia Law

In 2011, Administrative District Judge Nye issued an Administrative Order Declaring Petitioner Holli Telford a Vexatious Litigant. At the time the pre-filing order was issued, there were no proceedings before Judge Nye to which Telford was a party. Judge Nye issued the pre-filing order after receiving requests from several district court and magistrate judges. The pre-filing order declared Telford a vexatious litigant on the basis that she "has previously been declared to be a vexatious litigant by any federal court of record in any action or proceeding." Telford had been declared vexatious by Utah, Texas, the Federal Ninth Circuit Court of Appeals, the Federal District Court of Idaho, the Federal District Court of Montana, and the United States Supreme Court. The pre-filing order also found Telford to be a vexatious litigant on the additional basis that she has commenced in Idaho three or more pro se litigations that were determined adversely to her in the past seven years. Telford was then served the pre-filing order. On appeal, Telford challenged the order deeming her a vexatious litigant, including attacking the merits of cases underlying the declarations of the other jurisdictions. Upon review, the Idaho Supreme Court found no abuse of discretion, and affirmed Judge Nye's pre-filing order. View "Telford v. Nye" on Justia Law