Coalition for Agricultures's Future v. Canyon County and Canyon Co Bd of Commissioners, 160 Idaho 142

Coalition for Agriculture’s Future (an unincorporated nonprofit whose members include Canyon County seed growers and landowners) sued Canyon County seeking declaratory relief that the county’s 2020 Comprehensive Plan (adopted May 31, 2011, and amended Aug. 3, 2011) was invalid under Idaho’s Local Land Use Planning Act (LLUPA).
The Coalition alleged the 2020 Plan lacked an officially adopted future land use map, that the county used an unofficial map and made spot zoning and rezoning decisions harming agricultural interests (loss of isolation for seed crops, nuisance exposure, and loss of farmland).
The Coalition did not challenge any specific zoning decisions in the complaint; it sought to void the plan and all land-use decisions made under it or enjoin future rezoning of agricultural areas.
Canyon County moved to dismiss for lack of standing under I.R.C.P. 12(b)(6). The district court dismissed, finding the Coalition failed to allege a concrete, particularized injury fairly traceable to the challenged adoption of the plan.
On appeal, the Idaho Supreme Court reviewed the dismissal de novo and affirmed, holding the Coalition’s alleged injuries were either generalized grievances or traceable to specific zoning decisions (not the plan) and therefore insufficient to confer standing.
The Court awarded costs to Canyon County but denied attorney fees, finding the Coalition’s claim was not frivolous or without foundation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to seek declaratory relief to invalidate the Comprehensive Plan	Coalition: county’s failure to properly adopt a plan and omission of an official future land use map caused particular harm to agricultural members (loss of isolation, increased nuisance risk, loss of farmland).	County: Coalition alleges only generalized injury or injuries traceable to specific spot zoning decisions; Coalition failed to show a particularized, traceable injury from the plan adoption.	Held: No standing. Injuries alleged were either generalized grievances (affecting all citizens) or tied to individual zoning decisions, not fairly traceable to the challenged plan adoption.
Entitlement to attorney fees on appeal	Coalition: sought costs, not fees.	County: prevailing party; requests fees under Idaho Code §§12-117 and 12-121 because the claim lacked legal basis.	Held: Costs awarded to County; attorney fees denied because Coalition’s claim was not frivolous or unreasonable.

Miles v. Idaho Power Co., 116 Idaho 635 (Idaho 1989) (standing requires injury in fact and likelihood relief will redress injury)
State v. Philip Morris, Inc., 158 Idaho 874 (Idaho 2015) (standing requires distinct palpable injury and causal connection)
Troutner v. Kempthorne, 142 Idaho 389 (Idaho 2006) (generalized grievances shared by all citizens do not confer standing)
McCuskey v. Canyon Cnty., 123 Idaho 657 (Idaho 1993) (party may challenge validity of zoning ordinance by declaratory judgment where no zoning decision was appealable)
Ciszek v. Kootenai Cnty. Bd. of Comm’rs, 151 Idaho 123 (Idaho 2011) (particularized allegations of interference with use and decreased property value can confer standing)
Bone v. City of Lewiston, 107 Idaho 844 (Idaho 1984) (a party who could have appealed an adverse zoning decision may not later use declaratory relief to challenge it)