Rita Hoagland v. Ada County, 303 P.3d 587

Hoagland appeals and cross-appeals from summary judgment in a 42 U.S.C. § 1983 case arising from Munroe’s suicide in Ada County Jail.
Munroe had prior incarcerations; in 2008 he was booked after armed robbery, evaluated for suicide, then died in custody.
District court granted summary judgment in favor of most defendants; Johnson denied due to qualified immunity.
Munroe’s estate was held not to be a valid § 1983 plaintiff; standing issues were unresolved for Hoagland.
Questions were raised about awards of costs and discretionary costs, and whether attorney fees were appropriate.
Court remanded to reconsider discretionary costs and enter a consistent judgment; costs on appeal awarded to respondents.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Burden on § 1983 summary judgment	Hoagland argues plaintiff bears burden.	Defendants argue plaintiff must show deprivation.	Plaintiff bears burden to show constitutional deprivation.
Estate standing under § 1983	Estate has standing via survivorship/wrongful death claims.	§ 1983 is a personal action; estate cannot sue.	Munroe’s estate not a valid § 1983 plaintiff.
Parent’s standing for loss of familial relationship	Hoagland claims constitutional right to familial relationship with Munroe.	No established right; interference must be directed at relationship.	No § 1983 claim for loss of familial relationship.
Costs awarded as matter of right vs discretionary	Certain costs were improper, and discretionary costs were inadequately justified.	Costs awarded as matter of right; discretionary costs justified.	$918 removed; discretionary costs vacated and remanded with express findings.
Attorney fees on appeal	N/A	Entitled to fees under 42 U.S.C. § 1988(b) or I.C. § 12-121.	No fees on appeal; district court did not abuse discretion.

Evans v. Twin Falls Cnty., 118 Idaho 210 (1990) (§ 1983 personal action; right to sue in own name)
Robertson v. Wegmann, 436 U.S. 584 (1991) (Abatement not inconsistent with § 1983 policies)
Minix v. Canarecci, 597 F.3d 824 (2010) (Estate claims under § 1983 not applicable in Idaho)
Trujillo v. Bd. of Cnty. Comm’rs of Santa Fe Cnty., 768 F.2d 1186 (1985) (Intent to interfere with intimate association supports § 1983 claim)
Russ v. Watts, 414 F.3d 783 (2005) (Reluctance to constitutionalize unintended family losses)
Troxel v. Granville, 530 U.S. 57 (2000) (Fundamental liberty interest in parental rights; limits on state action)
McCurdy v. Dodd, 352 F.3d 820 (2003) (Requires deliberate action directed at parent-child relationship)