20180531Appellant Reply Brief.pdf

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May 30, 2018
Clerk of the Court
Idaho Supreme Court
451 W. State St.
Boise,lD 83702
Via Federal Exorcss
SAMUEL L LINNET
Linnet Law Office, PLLC
l-15 Second Avenue South
Hailey, ld 83333
208.788.6688
Fax2OB.7 88.7901
[e-mail]
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Re: Idaho Power Company v. Tidwell and IPUC; Docket No. 45644-2018
Dear Clerk:
Enclosed please find an original and six (6) bound copies of the Appellant's Reply Brief, which
was been electronically filed today. Bound copies have also been sent to Idaho Power and the
ldaho Public Utilities Comrnission by Federal Express today.
Please do not hesitate to contact our office if you have any questions
Sincerely,
Strope
Assistant to Samuel L. Linnet
[e-mail]
Encl.
Edith Pacillo
Karl Klein
Idaho Public Utilities Commission
Donovan Walker
Idaho Power Company
cc
?0tB rf,iY 3 t fiH g: t2
IN THE SUPRBME COURT OF THE STATE OF IDAIIO "li --'r.i. , --i!il! lr-'
: :_.:; I ii, :,-CCiiii?i5StOru
IDAHO POWER COMPANY,
Appellant-Respondent,
v,
KIKI LESLIE A. TIDWELL,
Intervenor-Apil ellant,
and
IDAHO PUBLIC UTILITIES COMMISSION,
Respondent.
DOCKET NO. 45644-2018
APPELLANT'S REPLY BRIEF
Appeal from Idaho Public Utilities Commission
Commissioner Eric Anderson, presiding
Samuel L. Linnet (ISB #9788)
Linnet Law Office
115 Second Avenue South
Hailey, ID 83333
Attorney fgr Intervenor-Appellant Kiki
Leslie A. Tidwell
Donovan E. Walker (ISB #5921)
Idaho Power Company
1221 West Idaho (83702)
P.O. Box 70
Boise, ID 83707
Attorney for Respondent Idaho Power
Company
Lawrence G. Wasden
Attorney General
Edith Pacillo (ISB #5430)
Karl Klein (ISB #5156)
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
Attorneys for Respondent on Appeal
Idaho Public Utilities Commission
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Table of Contents
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ry.
STATEMENT OF THE CASE.......
ISSUES PRESENTED..............2
ARGUMENT.3
A. Ms. Tidwell Adequately Raised the Arguments in Her Appeal with the IPUC................ 3
B. The IPUC failed to properly notice the August 22,2017 deadline for intervenor funding
requests......5
C. The IPUC abused its discretion because the August 8,2017 evidentiary hearing was not
"the last evidentiary hearing in a proceeding or the deadline for submitting briefs,
proposed orders, or statements of position," as required under Rule 164.........................6
D. Rule 164 is unconstitutionally vague.7
8
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E. The Commission's Order denying Ms. Tidwell's Intervenor-Funding Rquest was also
Unreasonable, Unlawful, Erroneous or Not in Conformity with the law......
3. This forum is appropriate for awarding intervenor funding because the IPUC did not
otherwise object to Ms. Tidwell's petition under the statutory factors..................... l0
4. Ms. Tidwell is entitled to an award of attorney fees under Idaho Appellate Rule 40
and 41.ll
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F. Ms. Tidwell Is Entitled to Attorney Fees..........
l. Ms. Tidwell satisfies elernents of the ldaho's Private Attorney General Doctrine.....
2. Ms. Tidwell is entitled to attomey fees under Idaho Code l2-l 17. ............
I
Cases
Associates Northv'est, Ittc. r,. Beets, I 12 Idaho 603, 605, 733 P.2d824,826 (Ct.App.l987)........ 3
Building Contractors Assn. of Southwestem Idaho v. Idaho Public Utilities Commn., l5l Idaho
to,253 P.3d 684, (2ol l).......3
H & V Eng'& [nc. v. Idaho State Bd. of Profl Engineers & Land Surveyors, I 13 Idaho 646,649,
747 P.2d 55, 58 (1987)....... ...............7
Hellarv. Cenamrs4 106Idaho 571,682P.2d524 (1984) .......3
Idaho Fair Share v. Idaho Pub. Utils. Comm'n, I 13 Idatro 959,751P.2d 107 (1988)....... .......2,3
J.R. Simplot Co., lnc. v. Idaho State Tax Comm'n, 120 ldaho 849,862,820 P.2d 1206,1219(reer)....... .......................2
Owner-Operator Independent Drivers Ass'n v. Idaho PUC, 125 Idaho 401,407,871 P.2d 818,
824 (tee+) ....................... e
State v. Hedger, I l5 Idaho 598, 600, 768P.2d 1331,1333 (1989)3
llrestby v. Shaefer,l5T ldaho 616, 338 P.3d 1220 (2014)...........3
Statutes
Idaho Code $ l2-ll7 9, l0
Idaho Code $ 6l-617A..........
Idaho Code $ 67-5201(l)......
4,9,10,11
9
Rules
Idaho Appellate Rule 40......
Idaho Appellate Rule 4l ......
.......... I I
.......... I I
........5, 6
... passim
IDAPA 31.01.01.016
IDAPA 3 1.01.01. 164 ..........
IDAPA 31.01.01 .255 ..........7
ll
L STATEMENT OF THE CASE
This is an appeal of a final order from the Idaho Public Utilities Commission ("IPUC")
denying Kiki Leslie A. Tidwell ("Ms.Tidwell') reimburse'rnent for intervenor costs. R- vol. I.
pp. 180-182.
In her initial brief, Ms. Tidwell argued that the l) IPUC failed to provide notice of a
deadline affecting a substantial, legislatively enacted right to intervenor funding requests, 2) the
IPUC acted arbitrarily, capriciously, and abused its discretion in denying Ms. Tidwell's request
for intervenor funding, and 3) the administrative rule used to deny Ms. Tidwell's request for
intervenor funding is unconstitutionally vague.
It is crucial to remember that the IPUC published no less than twelve notices and orders
during the life-span of Case No. IPC-E-16-28. Those notices span almost ayeaL None of them
remotely mention Rule 164, any of the triggering events in Rule 164, or the August 22,2017
deadline for intervenor funding. AdditionallS the IPUC failed to provide intervenor's with notice
that the last evidentiary hearing had been schoduld. The IPUC further admits that notice of the
August 22,2017 deadline for intervenor funding roquests was not provided to intervenors.
Respondent Br. at 15. And finally, the IPUC failed to address whether the August 8,2017
evidentiary hearing was the "last evidentiary hearing in a proceeding or the deadline for
submitting briefs, proposed orders, or staternents of position " as stated under Rule 164. ,See
Appellant's Br. at 13.
Ms. Tidwell's arguments are fully explained in her initial brief. This reply brief clarifies
and expands those arguments below. Ms. Tidwell also attempts to respond to many of the
incorrect assumptions and arguments the IPUC puts forward in its brief. In its simplest form, this
Appellant's Reply Brief - I
case is a question of whether an agency can set a deadline without noticing it and whether the
agency misinterpretd its own vague statute.
IL ISSUES PRESENTEI)
Ms. Tidwell's first brief lays out the issues presented to this court. Those issues remain.
For the purposes of replying to the IPUC's arguments and in an attempt to not simply reiterate
Ms. Tidwell's arguments, the issues presented in this brief are as follows:
l. Whether Ms. Tidwell adequately raisd her arguments before this court in her petition for
reconsideration with the IPUC.
2. Whether adequate notice ofthe Rule 164 deadline was providod.
3. Whether the IPUC acted arbitrarily, capriciously, and in an abuse of discretion in denying
Ms. Tidwell's petition for intervenor funding.
4. Whether Rule 164 is unconstitutionallyvague.
5. Whether Ms. Tidwell is entitled to an award of attomey fees.
ilI. STANDARD OF REVIEW
The standard of review for an appeal challenging a statutory interpretation and the
application of an administrative rule is whether the adjudicatory body abused its discretion.
Idatro Fair Share v. Idatro Pub. Utils. Comm'n, 113 Idatro 959,751P. 2d 107 (1988), rev'd on
other grounds. J.R Simplot Co., Inc. v. Idaho State Tax Comm'n, 120 ldatro 849,862,82OP.2d
1206, l2l9 (1991). Furttrer clarification of what is required to prove an abuse of discretion
standard is straightforward. "When an exercise of discretion is reviewed on appeal, the appellate
court conducts a multi-tierd inquiry. The sequence of the inquiry is (l) whether the lower court
rightly perceived the issue as one of discretion; (2) whether the court actd within the outer
boundaries of such discretion and consistently with any legal standards applicable to specific
Appellant's Reply Brief - 2
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choices; and (3) whether the court reached its decision by an exercise of reason." State v.
Hedger, I 15 Idatro 598, 600, 768P.2d 1331,1333 (1989) (citinglssociates Nortltwest, Inc. v.
Beets, I 12 Idaho 603, 605, 733 P.2d824,826 (Ct.App.t987). Interestingly, the IPUC's brief
cites Westby v. Slruefer, t 57 Idaho 616, 338 P.3d, l22O (2014), Westby v. Shaeferuses the
standard of review as created in Hedger (abuse of discretion and the factors quoted above), but
when the IPUC cttes Westby v. Shaefer it cites a different standard of review. Respondent Br. at
8. From Ms. Tidwell's perspective, the IPUC is either misstating the appropriate standard of
review or asking this court to apply a brand new standard of review.
The case before this court requires an abuse of discretion of standard. This standard has
been upheld in numerous cases concerning questions of law from administrative bodies,
including cases involving the IPUC. Idaho Fair Share v. Idaho Public Utilities Comm'n,l2O
Idaho 849,820P.2d 1206 (19 88) ("The decision of the adjudicating body awarding fees will not
be overturned absent an abuse of discretion.") (citing Hellar v. Cenamrs4 106 Idaho 571,682
P.2d 524 (198a)); Building Contractors Assn. of Southwestern ldaho v. Idaho Public Utilities
Commn., l5l Idaho 10, 253 P.3d 684, (201 1) ("Building Contractors has not shown that the
Commission abused its discretion in denying the requestd intervenor expenses."). Clearly,
appeals to the Idaho Supreme Court for questions about petitioners for intervenor funding require
an abuse of discretion standard of review.
IV. ARGUMENT
A. Ms. Tidwell Adequately Raised the Arguments in Her Appeal with the IPUC.
The issues put forward by Ms. Tidwell in herpetition for intervenor funding and petition
for reconsideration are the same issues that Ms. Tidwell is arguing now. See R. vol. I at 178-179.
Ms. Tidwellwas pro se during the time she prepared and submitted both her petition for
Appellant's Reply Brief - 3
intervenor funding and petition for reconsideration. kgal counsel is far more adept at explaining
legal arguments and using the correct vemacular and legal maxims. However, the arguments
presented by Ms. Tidwell as apro se litigant in front of the IPUC were sufficient to put the IPUC
on notice of Ms. Tidwell's arguments, as contained in her initial briefing.
Ms. Tidwell's petition for intervenor funding and her petition for reconsideration allege
that proper notice of the Rule 164 deadline was not provided and that the IPUC faild to properly
interpret the Rule 164. R. Vol. I, p. 178-179. While subsequent briefing has broken those
allegations down into more specific arguments, the main thrust of those arguments remain the
same: the IPUC failed to provide notice of a deadline and it abused its discretion in denying Ms.
Tidwell's petition for intervenor funding. The current arguments that the IPUC acted
inconsistently and that Rule 164 is unconstitutionally vague are under the umbrella of Ms.
Tidwell's original argument regarding the correct interpretation of Rule 164 and its application
to her case.
It is clear that the IPUC would rather not address Ms. Tidwell's arguments directly and
instead find a way to ignore their legislativelymandated duties and the requirements of notice
and reasoned decision making required of agencies. The IPUC had a full and fair opportunity to
correct its mistakes when Ms. Tidwell lild her petition for intervenor funding and her petition
for reconsideration. Yet, even though the IPUC had the funds required under ldaho Code $ 6l-
617A to reimburse Ms. Tidwell her intenrenor expenses, the IPUC instead decided to double-
down on its erroneous and illegal actions.
Appellant's Reply Brief - 4
B. The IPUC failed to properly notice the August22,20l7 deadline for intervenor
funding requests.
The cnrx of Ms. Tidwell's argument is that the IPUC failed to notice the August 22,2017
deadline for intervenor funding request. The entire administrative record is devoid of a reference
to an August22,2017 intervenor funding request deadline. Tellingly, the IPUC admits that it did
not notice the August 22,2017 deadline. Respondent Br. at 15. Therq the IPUC argues that Rule
164 speaks for itself. As explained more in Ms. Tidwell's void for vagueness doctrine argument,
Rule 164 does a lot of things, but speak for itself is not one of them. Not only does Rule 164
have a clause allowing for an order to waive any requirements under Rule 164, the rule itself
contains two separate clauses with a contingency that must be interpreted to determine which
clause applies. Regardless of Rule 164's vagueness, this important fact remains: notice of the
August 22,2017 deadline was not gverU and the IPUC freely admits so.
The fact that the transcript contains a one-sentence proclamation by Commissioner
Anderson is similarly undisputed, but that announcement does not equate to adoquate notice of a
deadline. First, the idea that Ms. Tidwell had notice because the transcript was available upon
request is absurd. See Respondent Br. at4,n.2. Without knowing about Commissioner
Anderson's statement, Ms. Tidwell had no way to know where to look in the administrative
record for the August 22,2017 deadline or that she would need to request the transcript.
Additionally, the cost of requesting a transcript to search for a one sentence statement that you
do not know exists is prohibitive and similarly ludicrous; it is also one of the reasons this appeal
only contains a short section of transcript.
Finally, Rule l6 of IDAPA requires that all notices be served by U.S, Mail or
electronically. IDAPA 31.01.01.016. The IPUC admits that notice of the August 22,2017
Appellant's Reply Brief - 5
deadline was not provided. Respondent Br. at 15. Then, the IPUC tries to argue that notice was
not rquired because the IPUC did not issue an order pertaining to Rule 164. Id. at l4-15. The
IPUC misinterprets Rule 16, which onlyprovides that orders and notices be served bymail or
snail. IDAPA 3 I .01 .01 .01 6. Rule I 6 does not require an order to trigger the notice requirements,
as claimed by IPUC. Respondent Br. at 14.
For all of the foregoing reiasons, the record of this case unquivocally proves that Ms.
Tidwell and every other intervenor did not receive notice of the August 22,2017 deadline for
intervenor funding requests.
C. The IPUC abused its discretion because the August&r20l7 evidentiary hearing was
not 6the last evidentiary hearing in a proceeding or the deadline for submitting
briefs, proposed orders, or statements of positio&'as required under Rule 164.
The August 8,2017 evidentiary hearing should not have started the l4-day period for
petitions for intervenor funding because it was not the last event to occur under Rule 164. Rule
164 states:
Unless otherwise provided by order, an intervenor requesting intervenor
funding must apply no later than fourteen (14) days after the last evidentiary
hearing in a proceeding or the deadline for submitting briefs, proposed orders, or
statements of position, whichever is last.
IDAPA 3 1.01.01. 164 (emphasis added).
The IPUC admitted that there was no order setting a due date for petitions for
intervenor funding requests. Respondent Br. at l4-15. Thus, the two deadline options
contemplated by the rule apply. Either intervenor funding requests were due 14 days after
the last evidentiary hearing or 14 days after the deadline for submitting briefs, proposed
Appellant's Reply Brief - 6
orders, or statements of position. Because there was no order stating otherwise,
whichever event is last is the triggering event.
In Ms. Tidwell's case, the last applicable event was the deadline for submittingbriefs,
proposed orders, or statements of position because that deadline was November l6,20l7,which
is after August 8,2017. See Appellant's Br. at 13-14. Additionally, Rule 255 allows any party to
file briefs, proposed orders, or staternents of position. IDAPA 31.01.01.255.
Ms. Tidwell met the Rule 164 deadline even thouglr she did not receive proper notice and
the IPUC misinterpreted its own poorly written rule because her petition for intervenor funding
was received on September20,z0lT,before the last chance to file petitions for reconsideration
and before the case before the IPUC had formally ended. While the IPUC would like to ignore
the last three words of Rule 164 ('lvhichever is last."), it is not afforded such discretion unless it
drafts an order consistent with the rule. The IPUC did not draft an order, and so we are left with
language of Rule 164 which gave Ms. Tidwell until 14 days after November 2,2017 to submit
her request.
For the foregoing reasons, the deadline for intervenor funding requests was at least as late
as November 16,2017, and the IPUC's purportod August 22,2017 deadline was decidd
arbitrarily, capriciously, and in an abuse of discretion.
D. Rule 164 is unconstitutionally vague.
The vagueness of Rule 164 should be apparent in the context of the arguments put forth
by both sides. The void for vagueness doctrine applies to statutes that do not suffrciently warn a
person of common intelligence as to the proscribed conduct required. H & V Eng'g, Inc. v. Idatro
State Bd. of Profl Engineers & Land Surveyors, I l3 Idaho 646,649,747 P.2d 55, 58 (1987).
Appellant's Reply Brief - 7
While Ms. Tidwell contends and maintains that her interpretation of Rule 164 is the
correct interpretation, it was not one that was arrived at easily. And, it was not until after the
IPUC erronoously set the intervenor funding request deadline that Ms. Tidwell became aware of
such deadline. R. vol. 1,p.179. She was, exactly as the doctrine requires, unaware of the
proscribed conduct that was required of her based solely on reading the rule. Rule 164 simply
does not ale'rt an intervenor as to what is expected of them.
The IPUC argues that Rule 164 speaks for itself. Respondent Br. at 15. Rule 164 does a
lot of things, but speak for itself is not one of them. Not onlydoes Rule 164 have a clause
allowing for an order to waive any timing requirements under Rule 164, the rule itself contains
two separate clauses with a contingency that must be interpreted to determine which clause
applies. IDAPA 31.01.01.164. A lawyer, let alone a lalperson, would have a difficult time
properly interpreting Rule 164. For the above reasons, and those laid out in Ms. Tidwell's initial
brief, Rule 164 is void for vagueness.
E. The Commission's Order denying Ms. Tidwell's Intervenor-Funding Request was
also Unreasonable, Unlawful, Erroneous or Not in Conformity with the law.
Should this court decide to deviate from prior case law regarding the standard of review
in appeals from the IPUC, the IPUC still cannot make a valid argument that its orderwas not
unreasonable, unlawful, and erone,ous. While the standard of review may change, the lack of
notice and the requirements of Rule 164 do not. As a result, Ms- Tidwell's arguments, as laid out
above and in her initial briefing, remain the same and show that the IPUC acted unreasonably,
unlawfully, and erroneously in its application of Rule 164 as well as its interpretation of the rule.
Appellant's Reply Brief - 8
F. Ms. Tidwell Is Entitled to Attorney Fees.
l. Ms. Tidwell satisfies elements of the ldaho's Private Attomey General Doctrine.
Idaho's private attomey general doctrine applies to cases against the IPUC because courts
have previously applied the doctrine to cases against the IPUC. ln Ov'ner-Operator, even though
the court ultimately declined to award attorney fee.s to appellant, they did so because the
appellant's request failed to meet the required substantive elements ofthe doctrine, not because
the doctrine did not apply to the IPUC. Owner-Operator Independent Drivers Ass'n v. Idaho
PUC, 125 Idaho 401,407,871P.zd 818, 824 (1994).
As argued in Ms. Tidwell's opening briet her appeal satisfies the requirernents of Idaho's
private attorney general doctrine. Appellant's Br. at 17-18. Contrary to the IPUC's arguments,
the issues presentd by Ms. Tidwell do not only stand to benefit herpecuniary interest. Ms.
Tidwell is seeking to hold the IPUC accountable to all potential intervenors and require the IPUC
provide adequate notice of intervenor deadlines. Since every ldahoan has the opportunity to be
an intervenor, the ruling of this court will affect every single ldahoan.
2. Ms. Tidwell is entitled to fees under Idaho Code 12-117.
Agencies, as defined by Idaho Code $ 67-5201(l), does not exclude legislative agencies,
and therefore the statute forms a basis for an award of attorney fees. While the IPUC is a
legislatively created agency,Idaho Code $ 67-5201(l) excludes the "legislative branch," not
agencies created by the legislature. Additionally, Ms. Tidwell does not seek attorney fees from
the IPUC or legislative branch. She seeks approval by the IPUC to award attorney fees from
Idaho Power Company, as explained in Idaho Code $ 6l-617A. The budget for intervenor
funding comes from the ldaho Power Company, not the legislature. Accordingly, fees under
Appellant's Reply Brief - 9
otherwise obiect to Ms. Tidrrell's oetition under the statutory factors.
Attorney fees for intervenor's are allowed under ldaho Code $ 6l-617A. This provision
of ldaho code expressly allows for an award of attorney fees to intervenors. Ms. Tidwell
originally applied to the IPUC for an award of attorney fees under Idaho Code $ 6l-617A. R.
vol. I, pp. 164-165. That request was not denied for failure to satisff the requirements under the
statute, but rather because the IPUC erroneously decided that Ms. Tidwell did not apply in time.
R. vol. I, pp. 175-l77.The IPUC contends that this means they did not make a substantive
decision on Ms. Tidwell's application. Respondent Br. at 24. However, this argument is actually
a thinly veiled attempt at getting a second chance to deny Ms. Tidwell her funding request.
Ms. Tidwell applied for intervenor funding in accordance with the statute, and the IPUC
was given a chance to approve or de,ny it basd on the factors in Idaho Code $ 6l-617 A.In fact
the IPUC was required to make its decision on those factors alone, not Rule 164. Idaho Code $
6l-617A ("The determination of the commission with regard to the payment of these expenses
shall be based on the following considerations..."). The IPUC did not object to any of the
substance of Ms. Tidwell's application, nor did any other intervenors object to Ms. Tidwell's
petition for intervenor funding. The IPUC does not need, nor are they allowed, to take a second
opportunity to deny Ms. Tidwell's application. As a result, Ms. Tidwell believes that if this court
agrees that her intervenor funding request was timely or if the IPUC's decision to deny her
request based on timing only was an abuse of discretion, then this court may award Ms. Tidwell
attorney fees in accordance with the ldatro Code $ 6l-617A.
Appellant's Reply Brief - l0
Idaho Code $ l2-ll7 are appropriate because the award of fees is actually an award of fees from
the Idatro Power Company.
3. This forum is appropriate for awarding fundins because the IPUC did not
In the event Ms. Tidwell prevails on her arguments in this appeal, Ms. Tidwell
respectfully ask that this court award attorney fees accordingly, including the cost of this appeal.
4. Ms. Tidwell is entitled to an award of attorney fees und€r Idaho Appellate Rule 40
and 41.
Idaho Appellate Rule 40 and Rule 4l are a basis for an award of costs and attorney fees.
Idaho Code $ 6l-617A is a statutoryprovision authorizing an award of attorney fees, which also
provides the basis for this appeal. As a result, an award of attorney fes and costs under Idaho
Appellate Rule 40 and 4l is appropriate.
V. CONCLUSION
The IPUC abused its discretion in denying Ms. Tidwell's petition for intervenor funding
and setting an unnoticed and erronmus deadline under Rule 164. Additionally, Rule 164 is void
for vagueness. Ms. Tidwell respectfully asks for an award of attorney fe,es and costs as allowed
by Idaho Code $ 6l-617A. Ms. Tidwell also respectfully requests reasonable attorney fees and
costs on appeal.
DATED this 2? day of May,2Ol8.
Samuel L. Linnet
Attorney for Appellant/Intervenor
Appellant's Reply Brief - I I
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on May 30, 2018, I caused to be served a true copy of the
foregoing document by the method indicated below, and addrcssed to each of the following:
Sanlue Linnet
Attorney for Ms. Tidwell
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E-Mail
Fedex
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E-Mail
Fedex
Donovan E. Walker
Idaho Power Company
PO Box 70
Boise, Idaho 83707 -0070
dwalker@idahopower. com
[e-mail]
Edith Pacillo
Karl Klein
Idaho Public Utilities Commission
472 W. Washington Street
Boise,Idaho 83702
edith.pacillo@puc. idaho. gov
karl.klein@puc. idaho. gov
Appellant's Reply Brief - 12
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