271 P.3d 703
Idaho2012Background
- Noak was medical director for Prison Health Services under IDOC contract; he treated inmate Norma Hernandez at SBWCC on Jan 30, 2004.
- Disputed hallway incident: Noak allegedly escorted Hernandez to her cell; accounts differ on coercion and threats.
- Hernandez complained; IDOC restricted Noak from SBWCC; director banned him from all IDOC facilities; Noak placed on leave.
- IDOC demanded replacement of Noak as medical director; PHS removed him from the contract on March 10, 2004.
- Noak sued PHS, IDOC, and Haas for various tort and contract-related claims; district court granted several summary judgments and awarded fees.
- Noak appeals the district court’s rulings, asserting breach of implied covenant, among other tort and defamation claims; ITCA issues arise on statute of limitations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether IDOC is entitled to summary judgment on breach of the implied covenant. | Noak asserts implied covenant attaches via IDOC-PHS contract. | No direct contract with IDOC; covenant not applicable. | Yes; no contract between Noak and IDOC, so no implied covenant claim. |
| Whether Noak’s ITCA claims against IDOC are time-barred. | Tolling under 28 U.S.C. § 1367(d) applies. | 1367(d) tolling does not apply to nonconsenting state defendants; claims untimely. | Yes; ITCA claims untimely; tolling does not apply. |
| Whether Haas is immune under I.C. § 54-1818 for the March 15, 2004 letter to IBOM. | Noak alleges defamation and distress from Haas’s letter. | Section 54-1818 provides immunity for communications to IBOM. | Yes; Haas immune under 54-1818 for communications to IBOM. |
| Whether IDOC is entitled to attorney fees under I.C. § 12-120(3). | Noak’s covenant claim sounds in contract; fees may be recoverable. | Prevailing party under contract-related claim may recover. | Yes; fee award affirmed for contract-related claim; fees on appeal awarded. |
Key Cases Cited
- Hoyle v. Utica Mut. Ins. Co., 137 Idaho 367 (Idaho 2002) (standard for summary judgment review remains consistent)
- Huyett v. Idaho State Univ., 140 Idaho 904 (Idaho 2004) (contract-based fee-shifting under I.C. 12-120(3) applies when contractual relation exists)
- Raygor v. Regents of the Univ. of Minnesota, 534 U.S. 533 (U.S. 2002) (1367(d) tolling not intended to breach state sovereign immunity)
- Walker v. Shoshone County, 112 Idaho 991 (Idaho 1987) (authority to consider arguments not cross-appealed when not changing district court result)