Justia Idaho Supreme Court Opinion Summaries
Articles Posted in Election Law
Idaho v. Keithly
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.
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Brannon v. City of Coeur D’Alene
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.
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Twin Falls County v. Idaho Commission on Redistricting
The constitutionality of "Plan L 87," a legislative redistricting plan adopted by the Commission on Redistricting for reapportionment, was challenged and brought before the Supreme Court. Upon review, the Court found that the Plan complied with the strictures of the Fourteenth Amendment's Equal Protection Clause of the federal constitution. However, the Plan did not comply with Article III, section 5 of the Idaho Constitution in that it did not "divide counties only to the extent that [they] must be divided to comply with the Federal Constitution." Furthermore, the Plan did not "avoid dividing counties whenever possible in violation of Idaho Code section 72-1506(5)." The Court did not order the Commission to adopt any one redistricting plan: "The commission certainly has the discretion to reject plans that have been submitted and draw boundaries in another manner that complies with both Constitutions." The Court directed the commission to reconvene and adopt a revised plan.
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