Justia Idaho Supreme Court Opinion Summaries

In this case, the plaintiffs, BABE VOTE and the League of Women Voters of Idaho, challenged two amendments to Idaho's election laws, House Bills 124 and 340, which modified the forms of identification voters can use to prove their identity when registering to vote and voting at the polls. The plaintiffs argued that the bills violated the Idaho Constitution's guarantee of equal protection and unduly burdened the right of suffrage. The Idaho Secretary of State, Phil McGrane, counterclaimed, seeking a judgment declaring that the bills did not violate these rights under either the Idaho or the United States Constitutions. The district court granted the Secretary’s motions and entered judgment in favor of the Secretary.The Supreme Court of the State of Idaho affirmed the decisions of the district court. The court held that the bills were a valid exercise of the legislature’s power to enact conditions on the right of suffrage under Article VI, section 4 of the Idaho Constitution. The court applied the rational basis test and found that the new laws were rationally related to their stated purpose to clarify and create uniformity by requiring only generally accepted, authentic, and reliable forms of identification as a reasonable condition to exercise the right of suffrage. The court also found that the bills did not violate the Equal Protection Clause of the Idaho Constitution. View "BABE VOTE v. McGrane" on Justia Law

Petitioners Idahoans for Open Primaries and Reclaim Idaho filed an original action to the Idaho Supreme Court, claiming that the Idaho Attorney General’s short and general ballot titles for “The Idaho Open Primaries Act” failed to comply with Idaho Code section 34-1809(2)(d) and (e). Petitioners asked the Supreme Court to declare the ballot titles deficient, certify Petitioners’ proposed short and general ballot titles to the Idaho Secretary of State, or in the alternative, retain jurisdiction of this matter and order the Attorney General to immediately prepare ballot titles consistent with Petitioners’ proposed titles and submit them to this Court for review. Petitioners also requested a writ of mandamus compelling the Secretary of State to extend the deadline for Petitioners to obtain signatures to qualify the initiative for placement on the 2024 general election ballot. After review, the Supreme Court granted certiorari review, holding that the short and general titles failed to substantially comply with Idaho Code section 34-1809. The Attorney General was ordered to provide revised, substantially compliant short and general ballot titles. The request for mandamus relief was denied. View "Idahoans for Open Primaries v. Labrador" on Justia Law

This case arose from a petition asserting the Idaho Commission for Reapportionment (“the Commission”) violated Idaho Code section 72-1506 when it adopted Plan C03, the congressional reapportionment plan, following the 2020 federal census. Petitioner Christopher Pentico argued the Commission failed to timely submit its plan and final report, and that Plan C03 violated Idaho Code section 72-1506 by splitting local precinct boundary lines. Pentico requested the Idaho Supreme Court issue a writ of prohibition to restrain the Secretary of State from transmitting a copy of the Commission’s Final Report and Plan C03 to the President Pro Tempore of the Idaho Senate and the Speaker of the Idaho House of Representatives. The Supreme Court declined, finding the Commission filed its Final Report within the ninety-day deadline, and pursuant to Idaho Code section 72-1506(7), a commission need not retain local precinct boundary lines with respect to its congressional plan if it determines it cannot complete its duties for a legislative district while retaining precincts. View "Pentico v. Idaho Commission for Reapportionment" on Justia Law

This case arose out of multiple petitions challenging the constitutionality of Plan L03, the legislative redistricting plan adopted by the Idaho Commission for Reapportionment (“the Commission”) following the 2020 federal census. Petitioners generally argued that Plan L03 split more counties than was required to comport with federal constitutional requirements, rendering Plan L03 unconstitutional under the Idaho Constitution. The petitions were filed in the Idaho Supreme Court's original jurisdiction. Petitioners requested the Court issue a writ of prohibition to restrain the Secretary of State from transmitting a copy of the Commission’s Final Report and Plan L03 to the President Pro Tempore of the Idaho Senate and the Speaker of the Idaho House of Representatives. Finding there was no constitutional violation, the Supreme Court declined to issue the writ. View "Durst et al v. ID Comm. for Reapportionment" on Justia Law

Two petitions reached the Idaho Supreme Court, both seeking to declare two statutes unconstitutional and to issue extraordinary writs: a writ of mandamus and a writ of prohibition. First, Michael Gilmore sought a declaration that Idaho Code section 34-1805(2), as amended by SB 1110, violated the people’s constitutional initiative and referendum rights. SB 1110 requires that, for an initiative or referendum to appear on the ballot, organizers must obtain a threshold number of signatures from “each of the thirty-five (35) legislative districts” in the state. Gilmore argued this violated the equal protection clause of the Idaho Constitution and unconstitutionally divides the people’s legislative power. Gilmore also petitioned for a writ of mandamus ordering the Idaho Secretary of State “not to implement” the statute as amended. In the second petition, Reclaim Idaho (“Reclaim”) and the Committee to Protect and Preserve the Idaho Constitution, Inc. (“the Committee”), sought a declaration that the new signature threshold mandated by SB 1110, requiring signatures from every legislative district, was unconstitutional. They also challenged the constitutionality of another statute, Idaho Code section 34-1813(2)(a), amended in 2020, stating that an initiative may not become effective earlier than July 1 of the year following the vote in which it was passed. Reclaim and the Committee contended both amended statutes nullify the people’s fundamental constitutional right to legislate directly. They also sought a writ of prohibition to prevent the Secretary of State from enforcing these statutory provisions. After review, the Supreme Court: (1) dismissed Gilmore's petition because he lacked standing; (2) granted Reclaim and the Committee's petition in part by declaring that section 34-1805(2) violated Article III, Section 1 of the Idaho Constitution, and the SOS and Legislature failed to present a compelling state interest for limiting that right. Furthermore, the Court declared section 34-1813(2)(a), violated Article III, Section 1 of the Idaho Constitution because it infringed on the people’s reserved power to enact legislation independent of the legislature. Accordingly, the Court granted Reclaim and the Committee’s petition for a writ of prohibition preventing the Secretary of State from enforcing this provision. View "Reclaim Idaho/Gilmore v. Denney" on Justia Law

Defendant-appellant Tom Katsilometes challenged the Idaho Senate’s order granting over $18,000 in attorney fees to Senator W. Marcus Nye, awarded after Nye prevailed against Katsilometes in a contest over the results of the 2016 general election. The Senate confirmed Nye’s election and awarded him costs and attorney fees. Because Katsilometes refused to pay the attorney fees, Nye brought an action in district court seeking a declaratory judgment ordering Katsilometes to pay him the amount ordered by the Senate. The district court granted the declaratory judgment and further awarded Nye costs, attorney fees, and prejudgment interest. The Idaho Supreme Court determined the Senate did not have the authority to award attorney fees to Nye at the time of the election contest. Nye was not entitled to recover his litigation costs, attorney fees, and prejudgment interest in the district court action. Therefore, the Idaho Supreme Court reversed the district court’s order enforcing the award of attorney fees to Nye pursuant to the order of the Idaho Senate, and vacated all costs, attorney fees, and prejudgment interest awarded to Nye by the district court. Neither side was entitled to attorney fees on appeal; however, as the prevailing party, Katsilometes was entitled to his costs on appeal. View "Nye v. Katsilometes" on Justia Law

Phil Hart appealed a district court’s grant of summary judgment dismissing his action contesting the results of a primary election for a State legislative seat. The district court ruled Hart had failed to demonstrate that any irregularities in the election were “sufficient to change the result” - an essential component of an election challenge under the Elections Contests Act, Idaho Code sections 34-2101–34-3128. Hart appealed, but finding no reversible error, the Idaho Supreme Court affirmed. View "Hart v. Idaho Secretary of State" on Justia Law

On May 15, 2012, Karl H. Lewies won the primary election for the position of Fremont County Prosecuting Attorney. Because he had no opponent in the general election, he knew he would be elected as the prosecuting attorney, and he was. He was scheduled to be sworn into office on January 14, 2013. On November 23, 2012, he filed two petitions for review against the county commissioners of Fremont County. One petition for review was on behalf of Flying "A"Ranch, Inc., and others, and the other petition was on behalf of E. C. Gwaltney, III. The petitions sought to overturn the designation by the county commissioners of certain roads as being public roads rather than private roads. In early 2013, the county commissioners, represented by Blake Hall, the deputy prosecutor hired by the prosecutor that Lewies had defeated in the primary, filed motions in both cases seeking to have Lewies disqualified from representing the petitioners in those cases. Lewies filed motions in both cases to withdraw as counsel for the petitioners. In each of the cases, Lewies had named two of the commissioners in both their official and individual capacities. The commissioners filed motions in both cases to dismiss the actions against them in their individual capacities. Substitution counsel entered appearances for the county commissioners in both cases. The court made preliminary rulings that Lewies could not represent any parties in the two cases; that the county would be awarded attorney fees against him personally for having to file the motion to disqualify; that an action against the two commissioners in their individual capacities could not be joined with a petition for judicial review; and that attorney fees would not be awarded against Lewies for having named them in their individual capacities. During the hearing, Lewies contended that substitution counsel should have been disqualified from representing the commissioners and that a deputy prosecutor should represent them. Ultimately the trial court entered a written order affirming its preliminary rulings. After several hearings, the court entered its memorandum decision in both cases awarding the county attorney fees in the sum of $1,185.00 against Mr. Lewies personally pursuant to Rule 11(a)(1), and Lewies appealed. Because there was no legal basis for the award, the Supreme Court reversed. View "Lewies v. Fremont County" on Justia Law

The issue before the Supreme Court in this case related to the service of four members of the Board of Directors for the Southern Valley County Recreation District. The State brought usurpation actions against Donald Keithly, Yvette Davis, Patrick Cowles, and Michael Smith (the Directors), alleging they usurped their offices as directors of the Recreation District. The State requested they be removed from office and sought a fine against each of them. Upon the parties' cross-motions for summary judgment, the district court ruled that this action was an election contest, rather than a usurpation action, which could be brought by the State. The district court also ruled that the Directors' actions while in office were protected by the de facto officer doctrine. The State appealed, arguing this was a proper usurpation action and the de facto officer doctrine did not apply. The Directors cross-appealed, arguing they are entitled to attorney fees. The Supreme Court concluded the matter was moot and affirmed the district court's order denying attorney fees. View "Idaho v. Keithly" on Justia Law

This case appealed a district court's denial of Petitioner Jim Brannon's election contest of the Coeur d'Alene city council election in 2009. In the official vote total, Brannon lost the election for seat 2 of the city council to Mike Kennedy by five votes. Brannon then filed an election contest that alleged numerous irregularities and sought to set aside, void, or annul the election. After a bench trial, the district court issued a memorandum decision that affirmed the election result, finding insufficient illegal votes or irregularities to change the outcome of the election. On appeal, Brannon argued that the City delegated its election duties to Kootenai County in contravention of Idaho law, that the district court made numerous factual and legal errors at trial, and that the district court erred in denying Brannon's motion to disqualify and motion for new trial. Upon review and finding no error, the Supreme Court affirmed the decision of the district court. View "Brannon v. City of Coeur D'Alene" on Justia Law