James v. City of Boise

PETITIONER: Melene James
RESPONDENT: City of Boise, Idaho
LOCATION: Supreme Court of Idaho

DOCKET NO.: 15-493
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: Idaho Supreme Court

CITATION: 577 US (2016)
GRANTED: Jan 25, 2016
DECIDED: Jan 25, 2016

Facts of the case

Melene James filed a complaint against City of Boise police officers after she was bitten by a police dog as the officers were responding to a call about a burglary in progress. The officers mistakenly thought James was a burglar. James brought claims of assault, battery, false arrest, wrongful imprisonment, and intentional infliction of emotional distress against the officers. The Idaho Tort Claims Act provides that a governmental entity is liable for negligent or wrongful acts of its employees if the acts were committed in the course and scope of their employment, but is not liable for intentional torts. The District Court of the Fourth Judicial District dismissed the claim because the officers had immunity for their intentional torts and James failed to show that they acted negligently. On appeal, the Idaho Supreme Court affirmed and awarded the defendants appellate attorney fees under the civil rights attorney fee statute. The court awarded these fees without determining that “the plaintiff’s action was frivolous, unreasonable, or without foundation” as required under the U.S. Supreme Court’s decision in Hughes v. Rowe. The Idaho Supreme Court decided that Hughes did not apply because the U.S. Supreme Court did not have the authority to limit the discretion of state courts without a limit in the relevant statute.


Does the Supreme Court’s decision in Hughes v. Rowe bind state courts, or does the U.S. Supreme Court lack the authority to limit the discretion of state courts where such limitation is not contained in the statute?