Woodworth v. State Ex Rel. Idaho Transportation Board
298 P.3d 1066
Idaho2013Background
- Woodworth was struck while crossing 11th Avenue South at 3rd Street in Nampa, Idaho, a segment of U.S. Highway 30, and sustained injuries.
- The intersection is a T-shaped junction with no marked pedestrian crosswalk at the time of the accident.
- Plaintiff sued the State of Idaho and the City of Nampa; the City was later dismissed; the State moved for and obtained summary judgment.
- The district court granted summary judgment on immunity under I.C. § 6-904(7) and on the merits, finding no genuine issue of material fact of negligence.
- Woodworth’s pleadings and briefing framed the claim as common law negligence and argued for an engineering study; HAL program was discussed as a potential fulfillment of statutory duties.
- On appeal, the majority affirmed the district court’s judgment; the dissent would reject perpetual design immunity and allow further proceedings on warning duties.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the State immune under I.C. § 6-904(7)? | Woodworth contends immunity does not apply because the claim arises from failure to warn or non-design-related duties. | State argues Woodworth’s claim arises from the plan or design of the intersection and is barred by immunity. | Yes; immunity applied; district court decision affirmed. |
| Does Woodworth present a viable negligence claim despite plan/design immunity? | Woodworth argues there are statutory/common-law duties and failure to warn claims not precluded by design immunity. | State contends the complaint lacks a viable negligence theory outside plan/design immunity. | No viable claim; affirmed on immunity grounds. |
| Did HAL program compliance fulfill the State's statutory duties under 40-201? | HAL participation does not cure deficiencies or create a duty to warn or improve safety. | HAL program satisfied statutory duties and supported the summary judgment. | Discussion unnecessary to decision; not reaching HAL analysis. |
Key Cases Cited
- Lawton v. City of Pocatello, 126 Idaho 454 (Idaho 1994) (abrogates sovereign immunity but preserves limited plan/design immunity under 6-904(7))
- Leliefeld v. Johnson, 104 Idaho 357 (Idaho 1983) (design immunity is perpetual (majority view); later questioned in dissent)
- Esterbrook v. State, 124 Idaho 680 (Idaho 1993) (MUTCD compliance can create negligence per se)
- County of Boise v. Idaho Counties Risk Mgmt. Program, Underwriters, 151 Idaho 901 (Idaho 2011) (summary judgment standard and review; duty and immunity contexts)