Sanders v. Board of Trustees of the Mountain Home School District No. 193
322 P.3d 1002
Idaho2014Background
- Sanders, a Mountain Home School District employee, applied for a consulting teacher position but was passed over for another candidate.
- A Master Contract with the Mountain Home Education Association provided a grievance process culminating in non-binding arbitration.
- Arbitrator ruled Sanders breach occurred due to the appointee's minimum qualifications; Board rejected the arbitrator's report.
- Sanders sued for breach of contract; district court denied attorney fees to the Board under I.C. §12-117, and awarded arbitration costs as discretionary costs.
- Syringa Networks held that I.C. §12-117 is not exclusive, allowing fees under I.C. §12-120(3); arbitration costs were later challenged on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is §12-117 exclusive when §12-120(3) may apply? | Sanders argues Syringa allows §12-120(3) alongside §12-117. | Board contends §12-117 is the exclusive basis when applicable. | Not exclusive; §12-120(3) may apply. |
| Whether §12-120(3) applies to this employment-contract breach case? | Board sought §12-120(3) fees; Sanders argues contract-related case fits commercial transaction. | Employee breach of employment contract falls within §12-120(3) as a commercial transaction. | Yes; §12-120(3) applies. |
| Whether the district court properly awarded arbitration costs as discretionary costs? | Costs were pre-litigation arbitration costs governed by the contract and should be treated differently. | Costs arose from arbitration connected to litigation and are recoverable as discretionary costs. | Arbitration costs were not recoverable as discretionary costs. |
| Should attorney fees be awarded on appeal? | Cross-appeal/appeal on fees; Sanders seeks no fee on appeal. | Board seeks fees on appeal under §12-120(3) and §12-117. | Neither party awarded attorney fees on appeal. |
Key Cases Cited
- Hagerman Water Right Owners, Inc. v. State, 130 Idaho 718 (1997) (I.C. §12-117 exclusive basis subject to statutes expressly providing otherwise)
- Syringa Networks, LLC v. Idaho Dep’t of Admin., 155 Idaho 55 (2013) (I.C. §12-117 not exclusive; fees may be awarded under other statutes such as §12-120(3))
- Potlatch Educ. Ass’n v. Potlatch School Dist. No. 285, 148 Idaho 630 (2010) (I.C. §12-117 exclusive when applicable prior to Syringa)
- Hayden Lake Fire Prot. Dist. v. Alcorn, 141 Idaho 307 (2005) (statutory interpretation; free review of interpretation of statutes)
- Printcraft Press, Inc. v. Sunnyside Park Utils., Inc., 153 Idaho 440 (2012) (I.C. §12-120(3) applies to commercial transactions; appellate fees discussed)