Martin v. Camas County ex rel. Board of Commissioners
150 Idaho 508
| Idaho | 2011Background
- Martin challenged Camas County's 2008 zoning amendments via declaratory judgment; district court granted summary judgment for Camas County on standing grounds.
- CV-2007-24 involved earlier zoning amendments with related orders; district court entered injunctions and findings that were later remanded; proceedings affected by federal removal and jurisdiction issues.
- Martin owned a 40-acre Agricultural parcel, a 29-acre parcel changed to Residential, and an AT parcel previously zoned Agricultural Transitional; he also held development contracts and a right of first refusal on other parcels; post-2008 amendments these properties were variably rezoned or redesignated.
- Court treated standing as a jurisdictional matter and not an adjudicative fact subject to collateral estoppel from CV-2007-24; analysis focused on whether Martin suffered a distinct palpable injury.
- Court concluded Martin did not suffer a distinct palpable injury and did not establish Koch-type standing, upholding summary judgment for Camas County.
- Attorney fees were not considered as Camas County did not raise them properly in the Argument section.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court should have judicially noticed CV-2007-24 orders. | Martin sought notice of adjudicative facts from CV-2007-24. | Court could rely on independent record; standing is jurisdictional. | No reversible error; standing is jurisdictional. |
| Whether Martin had standing to challenge the 2008 zoning amendments. | Martin claimed distinct palpable injury from upzoning and nearby rezones. | No specific, personal injury; general or speculative harms insufficient. | Martin lacked standing. |
| Whether upzoning constitutes a cognizable injury under standing rules. | Upzoning and nearby changes decrease development value. | Upzoning alone insufficient without particularized injury. | Not cognizable absent particularized injury. |
| Whether Koch exception or other standing theories apply. | Taxpayer/ratepayer status could confer standing. | Exception limited; no applicable particularized injury here. | Koch exception not applicable; no standing. |
| Whether the Comprehensive Plan designation creates vested rights to develop. | Density designations confer enforceable rights. | Comprehensive plan designations are non-vested expectations. | No vested right to develop as designated. |
Key Cases Cited
- Ameritel Inns., Inc. v. Greater Boise Auditorium District, 141 Idaho 849 (Idaho 2005) (taxpayer standing when challenged actions threaten specific fiscal impact)
- Miles v. Idaho Power Co., 116 Idaho 635 (Idaho 1989) (specialized injury among a large class may confer standing)
- Butters v. Hauser, 131 Idaho 498 (Idaho 1998) (peculiarized harm from a permit can establish standing)
- Koch v. Canyon County, 145 Idaho 158 (Idaho 2008) (taxpayer standing exceptions limited to constitutional challenges)
- Bone v. City of Lewiston, 107 Idaho 844 (Idaho 1984) (comprehensive plan designations do not create present rights)