Justia Civil Rights Opinion Summaries

Canyon County employed William Hartman as a heavy equipment operator at the Pickles Butte landfill in Nampa, Idaho, from 2012 until 2017. In February 2017, Hartman reported to Canyon County’s Human Resources Office that a female co-worker was being sexually harassed. The next month, Hartman, who was an army veteran, told both the director of the landfill, David Loper, and his immediate supervisor that he was taking narcotics prescribed to him for chronic pain. Canyon County requested Hartman provide, by a set deadline, medical documentation confirming his prescription and verifying that his use of narcotics would not adversely impact his ability to safely operate equipment. Hartman stated he was attempting to obtain the documentation, but he failed to provide it within the requested timeframe. On April 28, 2017, Loper sent Hartman a “Notice of Intent to Terminate,” informing him that his employment with Canyon County would be terminated effective May 2, 2017. The notice stated that pursuant to Rule 11.04 of the Canyon County Personnel Manual and “I.C. § 72-1701 et. seq. [sic],” Hartman could request a good faith hearing concerning the termination within two days of receiving the letter. Prior to Hartman’s receipt of the notice, Canyon County paid Hartman the balance of his accrued leave. Hartman did not request a good faith hearing. Hartman filed a notice of tort claim with Canyon County on July 27, 2017, alleging he had been unlawfully terminated. He filed a charge of discrimination with the Idaho Human Rights Commission on August 3, 2017. On November 28, 2018, Hartman filed a complaint against Canyon County, alleging: (1) disability-based discrimination in violation of the Idaho Human Rights Act (“IHRA”) and Americans with Disabilities Act (“ADA”); (2) unlawful retaliation in violation of Title VII of the Civil Rights Act (“Title VII”); and (3) unlawful termination in violation of the Uniformed Services Employment and Reemployment Rights Act (“USERRA”). Hartman later voluntarily dismissed his USERRA claim. After considering the parties’ supplemental briefing the district court issued a written decision, granting Canyon County’s motion for summary judgment. Finding that the district court erred in its grant of summary judgment, the Idaho Supreme Court reversed and remanded for further proceedings. View "Hartman v. Canyon County" on Justia Law

The United States District Court for the District of Idaho certified a question of law to the Idaho Supreme Court. Plaintiff was a prisoner in the custody of the Idaho Department of Correction (IDOC), currently incarcerated at the Idaho State Correctional Institution (ISCI). He asserts that he, and all IDOC prisoners, have a state-created liberty interest in being employed, arising from Idaho Code [section] 20-209. Plaintiff asserted the statute contained a "very specific, clear, and unambiguous" mandate that the Board of Correction must provide all inmates with employment during incarceration. The federal court asked the Idaho Supreme Court for guidance on plaintiff's contention: whether Idaho Code section 20-209 required the state board of correction to provide employment for all prisoners, and, if so, what was the minimum the board must do to implement the statute’s mandate? The Supreme Court responded, finding 20-209 required the Board to make employment available for all prisoners in the form of: (1) labor assignments as prescribed by the Board’s rules and regulations; and/or (2) implementation of statutory work programs managed by the Board in accordance with its rules and regulations. The Board retained discretion to manage these prisoner employment opportunities pursuant to its broad control over the correctional system. Section 20-209 did not create a right to paid or unpaid work during a prisoner’s period of incarceration or establish an employer-employee relationship between the Board and the prisoner. At a minimum, the Board must comply with legislation controlling its responsibilities managing prisoner employment and with its own rules and regulations. View "Goodrick - Certified Question of Law" on Justia Law

Natalie Shubert sued her former public defender, Michael Lojek, former Ada County chief public defender Alan Trimming, and Ada County (collectively the “Ada County Defendants”). In 2008, Shubert was charged with two felonies and pleaded guilty to both charges. Her sentences were suspended in each case, and she was placed on probation. After a probation violation in 2011, the Ada County district court entered an order extending Shubert’s probation beyond the time period allowed by law. The mistake was not caught. After Shubert’s probation should have ended in both cases, she was charged and incarcerated for a subsequent probation violation in 2014. Thereafter, in 2016, Shubert was charged with a new probation violation. Shubert was assigned a new public defender, who discovered the error that unlawfully kept Shubert on probation. Shubert’s new public defender filed a motion to correct the illegal sentence, raising the error that had improperly extended her probation. The district court granted Shubert’s motion to correct the illegal sentence and released Shubert from custody. Shubert then sued the Ada County Defendants, alleging false imprisonment, intentional infliction of emotional distress, negligence per se, negligence, and state and federal constitutional violations. The district court dismissed all of Shubert’s claims except for negligence. In denying the Ada County Defendants’ motion for summary judgment, the district court held that public defenders were not entitled to common law quasi judicial immunity from civil malpractice liability, and two provisions of the Idaho Tort Claims Act (ITCA) did not exempt public defenders from civil malpractice liability. The Ada County Defendants petitioned the Idaho Supreme Court pursuant to Idaho Appellate Rule 12. Finding no reversible error in the district court's judgment, the Supreme Court affirmed the district court’s order granting summary judgment, and remanded for further proceedings. View "Shubert v. Ada County" on Justia Law

On the evening of June 17, 2018, Appellants Shane Dodge and his wife Christine (“the Dodges”) were returning home with their son after having dinner together, when they turned onto District Two Road and saw a police car partially blocking their lane of travel. At that time, two Bonners Ferry police officers, Sergeant William Cowell and Officer Brandon Blackmore, were conducting a traffic stop of another vehicle. To avoid hitting them, Shane drove slowly by the two cars, and then pulled over about four car-lengths away. He exited his car and approached the police officers. He informed them that the location “was a pretty stupid place to pull people over.” Sergeant Cowell instructed Shane that he could be arrested for obstruction or interfering with the traffic stop, whereupon Shane said, “go to hell.” Shane was then arrested and placed in the back of the patrol car. When she saw her husband being arrested, Christine exited her car and attempted to approach and question the officers. When she asked the officers why they were arresting her husband, Sergeant Cowell told Officer Blackmore to arrest her too, but Officer Blackmore ordered her to leave the scene. Shane was taken to the county jail and booked. Thereafter, he posted bond and was released. The Dodges appealed after a district court dismissed their tort claim against the Bonners Ferry Police Department, Sergeant Cowell and Officer Blackmore. The grounds for dismissal was failing to file a notice of tort claim pursuant to Idaho Code sections 6-610 et seq., and for failing to post a bond prior to commencing their cause of action. Finding no reversible error in the district court's judgment, the Idaho Supreme Court affirmed. View "Dodge v. Bonners Ferry Police Department" on Justia Law

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

This appeal arose from the 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 July 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.” The factual background from that point was heavily disputed. Picatti alleged 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 and aggravated battery on law enforcement. At the end of his preliminary hearing, Picatti was bound over. Prior to trial, Picatti accepted a plea agreement in which he pleaded guilty to disturbing the peace for “failing to obey a traffic sign and driving into a restricted pedestrian area.” The court entered a judgment of conviction, which was not appealed, overturned, or expunged. Two years later, Picatti brought a 42 U.S.C. section 1983 suit against his arresting deputies, claiming deprivations of his protected 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 defending deputies holding that collateral estoppel barred Picatti from relitigating probable cause once it was determined at the preliminary hearing. Picatti timely appealed. The Idaho Supreme Court affirmed the order granting summary judgment to the deputies as to Picatti’s claims of false arrest and unreasonable seizure; however, the Court vacated the 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

This appeal arose out of a retaliation action under the Idaho Protection of Public Employees Act (the “Whistleblower Act”) and a negligent infliction of emotional distress claim against the Idaho State Police. Plaintiff Brandon Eller alleged the Idaho State Police (ISP) retaliated against him in two ways: (1) after he testified against another officer in a preliminary hearing; and (2) when he voiced objections to a new ISP policy requiring members of the Crash Reconstruction Unit to destroy draft and peer review reports. A jury awarded Eller $30,528.97 in economic damages under the Whistleblower Act and $1.5 million in non-economic damages for his negligent infliction of emotional distress claim. The district court then entered a memorandum decision and order reducing the award for Eller’s negligent infliction of emotional distress claim to $1,000,000 because Idaho Code section 6-926 capped the State’s liability for actions brought under the Idaho Tort Claims Act (ITCA) at $500,000 per occurrence. Both Eller and ISP timely appealed on several grounds, and their appeals were consolidated. After its review, the Idaho Supreme Court held the district court incorrectly applied the ITCA to Eller’s claim because the Whistleblower Act supplanted it. The district court’s rulings that the Whistleblower Act bars non-economic damage awards and that the ITCA caps Eller’s damages were vacated, and the matter remanded for a partial new trial regarding non-economic damages solely under the Whistleblower Act. View "Eller v. Idaho State Police" on Justia Law

An employee brought claims under provisions of the Idaho Human Rights Act, claiming: (1) the employer unlawfully discriminated against him based on race. He also alleged (2) breach of employment contract and the implied covenant of good faith. Furthermore, the employee (3) sought to disqualify the trial judge for cause based upon perceived bias. The district court denied the employee’s disqualification motion and granted summary judgment for the employer on all of the employee’s claims. Finding no reversible error, the Idaho Supreme Court affirmed judgment entered in favor of the employer. View "Mendez v. University Health Svcs BSU" on Justia Law

In 1992, Todd Rich was indicted for felony rape, allegedly committed between November 1991 and January 1992; he pled guilty on August 19, 1992; and on October 23, 1992, the district court sentenced him to six years in the custody of the Idaho Board of Correction. The district court retained jurisdiction for 120 days, and ultimately suspended the remainder of Rich’s sentence and placed him on probation. Rich successfully completed his probation on or about March 2, 2004. The following day, Rich filed a motion asking the district court in his criminal case for relief pursuant to Idaho Code section 19-2604(2), which was granted. The district court reduced Rich’s charge to a misdemeanor. The order reducing the charge stated that “the Judgment is hereby deemed a misdemeanor conviction, thereby restoring [Rich] to his civil rights.” At some point, Rich moved to Pennsylvania. He apparently applied for permission to possess a firearm in Pennsylvania. His request was denied by an administrative law judge who ordered: “It appearing that under Idaho law, I.C. 18-310(2), final discharge for a conviction of rape does not restore the right to ship, transport, possess or receive a firearm, the determination of the Pennsylvania State Police that Todd Rich is prohibited under the Uniform Firearms Act, 18 Pa. C.S. 6101 et seq., is upheld.” Rich filed this action seeking a declaratory judgment that he “may lawfully purchase, own, possess or have under his custody or control a firearm under the laws of the State of Idaho.” The State responded by contending that Rich had no standing to seek such relief. The district court dismissed the case on two alternative grounds: (1) Rich did not have standing because no real, substantial, and concrete controversy then existed; and (2) “Idaho Code 18-310(3) provides the mechanism for the restoration of civil rights is through application to the commission of pardons and parole, not through the District Court.” The district court entered a judgment dismissing this action with prejudice. Finding no reversible error, the Idaho Supreme Court affirmed. View "Rich v. Idaho" 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