Hauser Lake Rod & Gun Club, Inc. v. City of Hauser, 162 Idaho 260

Hauser Lake Rod and Gun Club (the Club), located in the City of Hauser’s area of impact but outside city limits, applied for a Class II building permit; the City issued a code-violation notice claiming the Club operated outside historical hours.
The Club appealed the violation to a Joint Planning and Zoning Commission (Joint Commission) composed of City and County members; the Joint Commission upheld the violation. The Club then appealed to the Kootenai County Joint Board of Commissioners (Joint Board).
The Joint Board, composed of county commissioners with city officials in an advisory, non-voting role, reversed the Joint Commission for lack of City jurisdiction. The Club requested attorney fees under Idaho Code § 12-117; the Joint Board declined and provided no findings.
The Club sought judicial review in district court; the district court remanded for findings but ultimately held § 12-117 did not apply because the Joint Board was not a “political subdivision” since it was staffed by both City and County officials, and denied fees.
On appeal to the Idaho Supreme Court the central legal questions were whether the Joint Board qualified as a “political subdivision” under § 12-117 and whether the City acted without a reasonable basis in fact or law (entitling the Club to fees). The Supreme Court reversed, awarding fees at administrative, district court levels and on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Joint Board is a “political subdivision” under I.C. § 12‑117	Joint Board’s decision was the act of the County (a political subdivision), so § 12‑117 applies	Joint Board staffed by City and County officials is not a political subdivision for § 12‑117 purposes	Joint Board decision was the act of the County; County is a political subdivision, so § 12‑117 applies
Whether the City acted without a reasonable basis in fact or law in enforcing its code on a non-resident outside city limits	City lacked authority to enforce code outside its limits; action was without reasonable basis, so fees are warranted	City reasonably (in good faith) relied on Ordinance No. 289 and its interpretation was not unreasonable	City acted without a reasonable basis; enforcement outside city limits conflicts with constitutional and precedential limits on municipal authority, so fees are warranted
Whether the district court may be affirmed on alternative grounds that the Joint Board did not abuse discretion	N/A (Club prevailed on abuse of discretion)	City asks affirmance because Board reasonably concluded City had basis to act	Court rejected alternative, found Board abused discretion and prejudiced Club’s rights
Entitlement to appellate attorney fees under § 12‑117	Club is prevailing party on appeal and eligible for fees	City also sought fees but did not prevail	Club awarded appellate attorney fees under § 12‑117

Hayes v. City of Plummer, 159 Idaho 168, 357 P.3d 1276 (discussing statutory interpretation standard)
Peckham v. Idaho State Bd. of Dentistry, 154 Idaho 846, 303 P.3d 205 (reviewing agency records in judicial review)
Clear Springs Foods, Inc. v. Spackman, 150 Idaho 790, 252 P.3d 71 (abuse of discretion review framework)
Blaha v. Bd. of Ada Cnty. Comm’rs, 134 Idaho 770, 9 P.3d 1236 (city/county powers limited to jurisdictional boundaries)
Hobbs v. Abrams, 104 Idaho 205, 657 P.2d 1073 (municipal power confined to limits)
Boise City v. Blaser, 98 Idaho 789, 572 P.2d 892 (limits on city regulatory authority)
Reardon v. City of Burley, 140 Idaho 115, 90 P.3d 340 (agency acts without reasonable basis when acting beyond authority)
City of Osburn v. Randel, 152 Idaho 906, 277 P.3d 353 (interpretation of statutes by agencies may be reasonable if not previously construed)
Syringa Networks, LLC v. Idaho Dep’t of Admin., 159 Idaho 813, 367 P.3d 208 (if any alternative legal basis supports decision, it may be upheld)
Daleiden v. Jefferson Cnty. Joint Sch. Dist. No. 251, 139 Idaho 466, 80 P.3d 1067 (trial-court decision may be upheld on alternative legal bases)