Hon. Lawrence G. Wasden v. Idaho State Board of Land Commissioners
150 Idaho 547
| Idaho | 2010Background
- Attorney General Wasden seeks a writ of prohibition to stop IDL Director Bacon from issuing cottage site leases at Priest and Payette Lakes.
- Wasden argues the cottage leases fail to secure maximum long-term financial return and do not generate market rent, violating the Idaho Constitution and I.C. § 58-310A.
- The Land Board argues it has discretion to set rents and that prohibitory relief is inappropriate because an adequate ordinary remedy exists.
- I.C. § 58-310A directs the Board to ensure market rent throughout the lease duration, eliminating conflict auctions for cottage sites.
- Historically, cottage rents used flat rates and a premium rent mechanism (leasehold transfer fee); premium rent persists despite sunset of the statutory basis.
- The Board adopted a rolling plan and a 4% rolling average proposal, facing opposition for not achieving true market rent; the petition challenges this framework.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an extraordinary writ is appropriate. | Wasden asserts no adequate plain remedy exists. | Board contends a plain, speedy remedy via declaratory/injunctive relief exists. | No; plain, speedy, adequate remedy exists; writ denied. |
| Whether the Land Board exceeded its jurisdiction. | Wasden maintains the Board failed to generate market rent as required. | Board claims broad constitutional discretion to maximize long-term returns within the law. | Board acted within jurisdiction; however, merits addressed via declaratory/injunctive path rather than prohibition. |
| Whether declaratory/injunctive relief is a sufficient alternative to prohibition. | Declaratory/injunctive relief would adequately address legal questions and preserve rights. | Relief should be limited to the writ only if no other adequate remedy exists. | Declaratory/injunctive relief provides a plain, speedy, adequate path; prohibition denied. |
Key Cases Cited
- Henry v. Ysursa, 148 Idaho 913 (2008) (plain, speedy, adequate remedy analysis for writs of prohibition)
- Agricultural Services, Inc. v. City of Gooding, 120 Idaho 627 (Ct.App.1991) (writs of prohibition traditional context; declaratory relief discussed)
- Balderston v. Brady, 17 Idaho 567 (1910) (Board acts outside jurisdiction; limits of board discretion)
- Pike v. State Board of Land Commissioners, 19 Idaho 268 (1911) (policy judgment vs. legal authority; courts defer to board on policy)
- Idaho Watersheds Project, Inc. v. State Board of Land Commissioners, 128 Idaho 761 (1996) (conflict auction and market rent requirements; follow constitutional view)
- Taylor v. Girard, 54 Idaho 787 (1934) (jurisdiction and remedies as basis for prohibition)
- Clark v. Ada Cnty. Bd. of Comm’rs, 98 Idaho 749 (1977) (prohibition requires effective remedy; avoid idle writs)
- Stein v. Morrison, 9 Idaho 426 (1904) (prohibition power limited to excess of jurisdiction)
- Crooks v. Maynard, 112 Idaho 312 (1987) (jurisdiction includes legal power to hear and determine causes)