Idaho Anti-Trafficking Coalition v. Idaho Council on Domestic Violence and Victim Assistance, 1:24-cv-00526

Idaho Anti-Trafficking Coalition (IATC), an Idaho non-profit, provided services to human trafficking victims and received federal grant funding via the Idaho Council on Domestic Violence and Victim Assistance (ICDVVA) since 2019.
IATC persistently lodged complaints against a competitor, COBS, alleging unethical practices and fraud; these concerns were shared with a news organization, InvestigateWest, in early 2024.
Following publication of critical articles, ICDVVA board members met with IATC, allegedly urging its executive director to stop criticizing ICDVVA publicly.
IATC was initially awarded the FY25 grant, but after further articles and public records requests, ICDVVA reconsidered and revoked IATC’s funding in September 2024, citing collaboration issues and management concerns.
IATC brought suit alleging First Amendment retaliation and procedural due process violations; defendants moved to dismiss on grounds including qualified immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
First Amendment Retaliation	Funding was revoked in retaliation for protected speech about matters of public concern.	Government funding was withdrawn for business reasons; qualified immunity protects against liability.	Plaintiff states a plausible First Amendment claim; not dismissed.
Qualified Immunity	Rights were clearly established; no qualified immunity.	Not clearly established that these facts violate the First Amendment.	Not entitled to qualified immunity at dismissal stage.
Pickering Balancing	Relationship is not analogous to an employee; strict balancing test should not apply.	IATC is like a contractor; Pickering balances government vs. speech interests.	Pickering applies; balancing cannot be resolved at this stage.
Procedural Due Process	IATC had a property interest in grant funding.	No protected property interest in prospective grants.	No property interest; due process claim dismissed with prejudice.

Ashcroft v. Iqbal, 556 U.S. 662 (pleading requirements for motions to dismiss)
Bd. of County Comm’rs v. Umbehr, 518 U.S. 668 (Pickering analysis applies to government contractors)
CarePartners, LLC v. Lashway, 545 F.3d 867 (distinguishes regulated entities from contractors)
Soranno’s Gasco v. Morgan, 874 F.2d 1310 (First Amendment retaliation in permit suspensions)
Hyland v. Wonder, 117 F.3d 405 (Pickering applies to government volunteers)
Jones v. Williams, 297 F.3d 930 (damages require personal participation by defendants)