Barry Lynn Winmill

In this case, plaintiff Autumn Pauls, a former inmate at Adams County Jail, sued the county, Sheriff Rich Green, and Officer Butch Gibson under 42 U.S.C. § 1983, alleging that Gibson coerced her into sexual acts in violation of her Fourth, Fifth, Eighth, and Fourteenth Amendment rights, along with related state-law claims. The defendants moved to dismiss for failure to exhaust administrative remedies under the Prison Litigation Reform Act, for summary judgment on the merits, and related discovery motions. The court denied the motion to dismiss, holding that the PLRA's exhaustion requirement did not apply because the grievance procedures were not available to Pauls after her prompt transfer to another facility. It granted in part and denied in part the summary judgment motions, granted in part the motion to strike and the request for evidentiary sanctions, and addressed various discovery issues.

civil rightsprocedure

This case involves Elven Joe Swisher's motions under 28 U.S.C. § 2255 to vacate, set aside, or correct his federal sentence, in which he alleged ineffective assistance of counsel primarily due to an actual conflict of interest arising from his attorneys' prior representation of David Hinkson in a separate prosecution, as well as other unrelated deficiencies in their performance. The court dismissed both the original and renewed § 2255 motions after reviewing the filings, the government's response, and the underlying criminal record. The record included details of Swisher's disputed claims of military service and combat experience, his testimony as a government witness in the Hinkson trial, and questions raised about the authenticity of his military documents. The court concluded that the claims did not warrant relief.

criminal lawprocedure

The case concerned a motion by ranchers to modify a prior court injunction that had banned grazing on 28 allotments in the Jarbidge Resource Area due to failures to meet rangeland health standards and impacts on sage grouse habitat. After a settlement allowed limited grazing under interim plans, a major wildfire, expiration of those plans, and subsequent BLM actions prompted the ranchers to seek relief under Rule 60(b)(5). The court granted the motion in part, finding significant changes in factual circumstances that made the total ban no longer equitable. It modified the injunction to permit grazing subject to specific conditions, including limits on timing and intensity in key habitat areas, compliance with stubble height standards, burned-area closures, and annual reporting to the court. The decision emphasized that modifications should be narrowly tailored to address the changed conditions while the BLM completes its environmental reviews and permit renewals.

environmentfederal power

This case involved plaintiff Wanda Collier, who sued her employer Turner Industries, supervisor David Eastridge, and related parties at Agrium for gender discrimination and harassment under Title VII, Section 1983, and Idaho state laws, claiming she faced hostile treatment and was ultimately fired because she was a woman. The court granted the defendants' summary judgment motions in part, dismissing claims for intentional infliction of emotional distress, violation of the Idaho Human Rights Act, breach of contract, breach of implied duty of good faith, promissory estoppel, and punitive damages on state claims, while narrowing the Title VII hostile work environment claim to a single incident of pushing on September 10, 2008. The court denied the motions as to the remaining claims. The reasoning centered on the lack of sufficient evidence to support the dismissed claims under applicable legal standards, while finding genuine issues of material fact regarding gender bias in the surviving claims based on incidents involving Daniell and statements by Eastridge.

labor & employmentcivil rights

In Nu-West Mining Inc. v. United States, the plaintiffs sought to hold the federal government liable under CERCLA for costs to clean up selenium contamination at four phosphate mine sites in the Caribou-Targhee National Forest. The court granted the motion for partial summary judgment, finding the United States liable as an owner, operator, and arranger under 42 U.S.C. § 9607(a) with respect to the cleanup costs. This conclusion followed from the government's ownership of the land and middle waste shale containing selenium, its issuance of leases and permits that authorized mining and waste disposal, and its requirements for specific reclamation and waste-dump designs that caused the contamination to leach into the environment.

environmentbusiness & regulatoryfederal power

The case involved the Idaho Republican Party challenging the state's open primary election system, which allows any voter to participate in selecting a party's nominees without declaring affiliation. The court ruled that this system violates the Republican Party's First Amendment right to freedom of association. The reasoning centered on the fact that the open primary enables significant crossover voting by independents and members of other parties, thereby interfering with the party's ability to control its own nomination process. The decision was based on evidence from a bench trial showing the extent and impact of such voting.

electionsfree speech

In this case, an Idaho inmate brought a civil rights action under 42 U.S.C. § 1983 against a parole hearing officer, alleging that she included false statements about uncharged sexual abuse counts in a report to the parole commission, which caused his parole to be denied, and seeking damages plus expungement of the records. The court dismissed the complaint in its entirety. The claims were barred by Heck v. Humphrey because success would necessarily imply the invalidity of the parole denial and thus the duration of confinement. Additionally, the inmate had no protected liberty interest in accurate parole records, as Idaho law does not create a right to parole under its sentencing and parole statutes, precluding any due process claim.

criminal lawcivil rights

The case arose when plaintiff Mickey Cockerham, who had purchased riverfront property to develop a hunting club, posted nearby islands as private land to deter errant shots from hunters; this led to a confrontation with hunters and a subsequent investigation by Idaho Fish and Game officers who cited Cockerham and briefly detained him for questioning after one officer fired a warning shot on an island. Cockerham sued the officers under 42 U.S.C. § 1983 for an unreasonable seizure involving excessive force and under § 1985 for conspiracy to interfere with his civil rights. The court granted the defendants' motion for summary judgment, holding that any seizure occurred during a later verbal interrogation without brandishing of weapons or significant physical force, that the limited force used was objectively reasonable under the circumstances, and that the § 1985 claim failed for lack of any alleged racial or class-based discriminatory animus.

civil rights

This case involves former Deputy Fire Chief Douglas Brown suing the City of Caldwell and three city employees after his 2009 termination, asserting claims under the Idaho Whistleblower Act, breach of contract and good faith covenant, and First Amendment retaliation. Defendants moved to dismiss the state law damages claims for failure to comply with the notice-of-claim requirement in Idaho Code § 50-219, which incorporates the Idaho Tort Claims Act's 180-day filing deadline. The court granted the motion in part and denied it in part, dismissing the contract claims because the notice rule applies to them and was not satisfied, but allowing the whistleblower claim to proceed because the statute does not cover that statutory cause of action; claims against the individual defendants were also dismissed. The core reasoning examined the text of § 50-219, Idaho Supreme Court precedent such as Beckstead, and the distinct nature of statutory whistleblower protections versus contract theories.

labor & employmentcivil rightsprocedure

The case concerns a challenge by the Western Watershed Project to supplemental environmental reports issued by the U.S. Forest Service for grazing on four North Sheep allotments in the Sawtooth National Forest and Recreation Area, after an earlier ruling found the original North Sheep Environmental Impact Statement violated NFMA, NEPA, and the Sawtooth National Recreation Act. The Forest Service prepared a Forest Plan supplement with capability analysis for sage-grouse and pileated woodpecker habitat plus a SEIS addressing grazing levels, adaptive management, and land capability. The court granted summary judgment to the Forest Service and denied the plaintiff's motion, holding that the supplements satisfied the statutes by including capability maps and data, site-specific studies, and an aggressive monitoring program with enforcement consequences that showed a rational connection between facts and grazing authorizations.

environment

The case involved environmental groups challenging the U.S. Forest Service's adoption of the Idaho Roadless Rule, which replaced the nationwide 2001 Roadless Rule with state-specific management categories for over 9 million acres of inventoried roadless areas in Idaho's national forests, allowing more road construction and timber harvesting in certain backcountry zones to address wildfire risks while imposing stricter protections in others. The plaintiffs alleged violations of the Endangered Species Act (ESA) by the Fish and Wildlife Service in its Biological Opinion and of the National Environmental Policy Act (NEPA) by the Forest Service in its environmental impact statement and record of decision. The court granted summary judgment to the federal defendants and denied the plaintiffs' motion, holding that the agencies had complied with the ESA and NEPA based on the administrative record, including public input, coordination with states, and reasoned explanations for categorizing specific areas like Winegar Hole.

environmentfederal power

This case involves two plaintiffs who developed compulsive gambling addictions after playing slot machines at the Fort Hall Casino on the Shoshone Bannock Tribes' reservation and sued the Idaho Governor and U.S. Secretary of the Interior, claiming the machines were installed in violation of the Indian Gaming Regulatory Act and Johnson Act. The court granted the Governor's motion to dismiss for lack of jurisdiction, denied the Secretary's motion to dismiss, and denied the plaintiffs' motion to amend, allowing the action to proceed solely as an Administrative Procedure Act challenge to the Secretary's approval of tribal-state compacts authorizing video gaming. The core reasoning was that the claims against the Governor raised only state-law issues without implicating the Supremacy Clause or other federal causes of action, while the Secretary's compact approvals constituted final agency action subject to APA review.

federal powerbusiness & regulatoryprocedure

In United States v. Barnes, the defendant moved to suppress evidence seized during a search of his residence pursuant to a state-issued warrant, as well as a later statement he made to an ATF agent. The court granted the motion after finding that the warrant lacked the particularity required by the Fourth Amendment because it broadly authorized a search for unspecified firearms, ammunition, and other items without limiting the search to the specific weapons and evidence described in the supporting affidavit. The court further held that the good-faith exception to the exclusionary rule did not apply because the warrant was so facially deficient that officers could not reasonably have believed it was valid, and it suppressed the defendant's subsequent statement as fruit of the unlawful search.

criminal lawprocedure

In this case, AMX International sued Battelle Energy Alliance for tortious interference with contract, alleging that Battelle hired away AMX's subcontracted IT employees despite knowing they were bound by non-competition agreements that barred them from working directly for AMX clients for 12 months after leaving AMX. The court granted Battelle's motion for summary judgment and dismissed the claim. The core reasoning was that the non-compete provisions were unenforceable under Idaho law because they were overbroad in scope—lacking reasonable geographic or client limitations and prohibiting work for any entity invoiced by AMX in the prior 24 months—without the need for factual findings on reasonableness. The court distinguished prior precedent and concluded that patently invalid contracts could not form the basis for a tortious interference action.

torts & liabilitylabor & employmentbusiness & regulatory

The case involved plaintiff Kerry Winn's claims against escrow agent Amerititle for releasing a $100,000 earnest money deposit in a failed Idaho land purchase solely to one seller's account rather than jointly to all sellers named in the purchase agreement. Winn asserted breach of the escrow agreement, breach of fiduciary duty, and negligence after he obtained assignment of the buyer's rights and could not recover the funds from the sellers despite a prior state court judgment. The court granted Amerititle's motion for summary judgment on all claims and denied Winn's cross-motion. It reasoned that the escrow instructions did not clearly impose a duty to distribute jointly, that any breach was not shown to have caused harm, and that Winn failed to demonstrate damages because the money reached the intended recipient and he stood in the same position as if joint release had occurred.

propertybusiness & regulatorytorts & liabilityprocedure

The case involves Western Watersheds Project challenging the Bureau of Land Management's (BLM) re-issuance of a grazing permit on an allotment within the Burnt Creek Wilderness Study Area (WSA) after an earlier permit was invalidated for inadequate environmental analysis. The court granted summary judgment to the plaintiff and set aside the permit decision. The core reasoning is that the BLM's environmental assessment failed to evaluate whether the grazing would impair the wilderness values from the 1980 inventory or consider cumulative effects across the entire WSA, violating requirements under the Federal Land Policy and Management Act (FLPMA) for managing WSAs.

environmentfederal power

Ronald Reece, a teacher employed by the Pocatello/Chubbuck School District since 1994, sued the district after he was reprimanded and involuntarily reassigned from teaching keyboarding to geography and study skills. Reece alleged the actions were in retaliation for his role in reporting written student statements alleging sexual harassment by the school principal, which he and a colleague delivered to legal counsel, the Idaho Department of Health and Welfare, and district officials. The district maintained the discipline resulted from Reece's misconduct in soliciting and sharing the statements and failing to follow proper reporting procedures. On the district's motion for summary judgment, the court granted the motion as to the third and fourth claims for relief but denied it as to the remaining claims, determining that the record contained sufficient evidence for a fact-finder to conclude the district lacked an honest belief in its stated reasons.

civil rightslabor & employment

The case involves SI03, Inc. and its principal suing over a dozen defendants for online forum postings on bodybuilding.com that allegedly criticized SI03's products and principals, asserting claims under the Lanham Act as well as state tort claims for defamation, injurious falsehood, and tortious interference. After removal and transfer from the Eastern District of Missouri to the District of Idaho under 28 U.S.C. § 1406(a), several defendants moved to dismiss on grounds including insufficient service of process and lack of personal jurisdiction. The court held that re-service of a summons and complaint issued by the Idaho court is required after a § 1406(a) transfer when no merits decision has occurred, that defendants had not waived the service objection, and that SI03 must complete service by May 24, 2010 while also being granted leave to amend to address personal jurisdiction under Idaho's long-arm statute and due process limits.

proceduretorts & liabilitybusiness & regulatory

The case involved a challenge by plaintiffs seeking to block the U.S. Forest Service from issuing a special use permit allowing the Idaho Department of Fish and Game to use helicopters in the Frank Church Wilderness to dart and collar wolves for population monitoring after the species was delisted from the Endangered Species Act. The plaintiffs argued that the helicopter operations violated the Wilderness Act's restrictions on aircraft landings and NEPA's requirements for environmental review. The court denied the motion for a preliminary injunction, finding that the plaintiffs were unlikely to succeed on the merits because the activity qualified for two categorical exclusions under NEPA and was justified under the Wilderness Act as necessary for the minimum administration of the area to support wolf recovery and data collection. The decision emphasized that the helicopter use was limited in scope, timed with existing surveys, and aimed at restoring wilderness character disrupted by prior human activity.

environment

In Dunham v. Kootenai County, plaintiff Blair Dunham sued county animal control officers and the municipality under 42 U.S.C. § 1983 after officers entered a rural property without a warrant, examined horses reported for possible neglect, and removed three horses they determined were not receiving adequate care under Idaho animal cruelty statutes. The court granted the defendants' motion for summary judgment on all claims, including allegations of unlawful search and seizure as well as failure to train and supervise officers. The core reasoning was that the officers' actions did not violate the plaintiff's constitutional rights, the plaintiff failed to identify any municipal policy or custom as the moving force behind any alleged violation, and no evidence supported the training or supervision claims.

criminal lawcivil rightspropertyprocedure