Jeffry Black v. Idaho State Police, 314 P.3d 625

Black was appointed Executive Director of POST (a division of ISP) in 2006; Russell became ISP director in 2007 and supervised Black; POST faced budgetary shortfalls in 2008-2009 prompting audits and directives; Black resisted certain directives regarding POST operations and finances; a Personnel Management Audit was completed in 2009; Black was terminated on November 5, 2009, after disputes over directives and reporting structure; district court granted summary judgment for ISP, and the Idaho Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Black engaged in protected activity under the Whistleblower Act.	Black engaged in protected activity by reporting or objecting to violations.	No protected activity occurred; actions were insubordination or routine management within authority.	No protected activity; summary judgment for ISP affirmed.
Whether Black is entitled to attorney fees on appeal under I.C. § 6-2106(5).	Black will be prevailing party on remand and should recover fees.	Black is not the prevailing party; fees not warranted.	No attorney fees awarded on appeal.

Van v. Portneuf Med. Ctr., 147 Idaho 552, 212 P.3d 982 (2009) (establishes framework for retaliation and protected activity under the Whistleblower Act)
Patterson v. State, Dep’t of Health and Welfare, 151 Idaho 310, 256 P.3d 718 (2011) (reasonable belief standard with subjective and objective components)
Curlee v. Kootenai Cnty. Fire & Rescue, 148 Idaho 391, 224 P.3d 458 (2008) (examples of protected activity under the Act; factual-like standard for reasonableness)
Smith v. Mitton, 140 Idaho 893, 104 P.3d 367 (2004) (context for whistleblower protections and statutory interpretation)
Steele v. Spokesman-Review, 138 Idaho 249, 61 P.3d 606 (2002) (standards for reviewing summary judgment decisions)