Friends of Minidoka v. Jerome County, 281 P.3d 1076

Big Sky Farms sought an LCO/CAFO permit for an 8,000 Animal Unit facility in A-1 zone near Eden, Idaho, about 1.25 miles from Minidoka National Historic Site.
Jerome County Board denied the permit on grounds including the Comprehensive Plan when reviewing on the initial proceedings.
District Court remanded, finding the Board had relied on the Comprehensive Plan and could consider other valid bases for denial.
On remand, the Board approved the permit with conditions after reconsideration.
Petitioners sought judicial review; the district court affirmed, determining standing for some petitioners and denying others; the appellate court reviews independently the agency record.
Court held that Friends of Minidoka lacked standing, while Idaho Rural Council, Inc. and ICARE had standing; Board’s due process and zoning applications were upheld; Jerome County was not awarded attorney fees on appeal or on judicial review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing of appellant-organizations	Idaho Rural Council and ICARE had members within one mile.	Only some associations had identifiable harmed members.	RCC and ICARE have standing; Friends of Minidoka lacks standing.
Procedural due process at hearing	Record shows limited opportunity to present/rebut evidence and notice issues.	Due process satisfied given hearing procedures and time; ample opportunity to be heard.	Board's process did not violate procedural due process.
Constitutionality of one-mile rule	I.C. § 67-6529(2) arbitrarily restricts participation.	Rational basis; reasonable relation to governmental interest; board may extend radius.	One-mile rule constitutional.
Board's application of zoning ordinances	Board failed to follow JCZO requirements; comprehensive plan relied on improperly.	Board properly applied zoning ordinances and recognized relevant standards.	Board complied with applicable ordinances.
Attorney fees on appeal/judicial review	Fees should be awarded under I.C. § 12-117; district court erred.	Post-2010 amendments restrict/alter fee awards; no fees awarded to prevailing party.	No party entitled to attorney fees on appeal or judicial review.

Castaneda v. Brighton Corp., 130 Idaho 923 (1998) (quasi-judicial notice/hearings require meaningful opportunity to be heard)
Cowan v. Bd. of Comm’rs of Fremont Cnty., 143 Idaho 501 (2006) (due process at planning/zoning hearings; limited public comment not per se fatal)
Neighbors for a Healthy Gold Fork v. Valley Cnty., 145 Idaho 121 (2007) (deference to board findings; substantial evidence standard)
Chisholm v. Twin Falls Cnty., 139 Idaho 131 (2003) (deference to board’s interpretation of its ordinances; substantial evidence)
Evans v. Teton Cnty., 139 Idaho 71 (2003) (LLUPA review; standard of review; agency findings reasonable)