Nampa Education Association v. Nampa School District No. 131, 343 P.3d 1094

Nampa School District No. 131 and the Nampa Education Association failed to reach a master contract for 2012–13; teachers signed state-approved standard contracts reflecting the district’s last offer.
Facing a budget shortfall, the district offered unilateral addenda allowing teachers to voluntarily donate 1–4 specified furlough days (no pay for donated days; teachers could optionally work).
Approximately 500 teachers signed addenda; ~24 later modified the number of donated days.
The Association sued for a declaratory judgment that the addenda were unlawful and unenforceable because they were not approved by the State Superintendent as required by statute and regulation.
The district court granted summary judgment to the Association, concluding the addenda modified contract terms in violation of Idaho Code § 33-513 and IDAPA 08.02.01.150; the School District appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to sue	Association has a concrete interest as exclusive representative and alleged statutory violation	District said Association suffered no injury and lacked standing	Association had standing; court may vindicate its interest in statutory compliance
Mootness	Challenge not moot because declaration can prevent future similar conduct; conduct likely to evade review	District said issue moot because furloughs completed by hearing	Not moot — capable of repetition and likely to evade review; live controversy for declaratory relief
Whether addenda required Superintendent approval under I.C. § 33-513	Addenda are contract modifications/deviations from approved form and thus require approval	Addenda are post‑formation amendments outside § 33-513’s scope (applies only to initial contract)	§ 33-513’s requirement covers employment contracts and deviations; addenda were part of employment contracts and void without approval
Whether teachers’ voluntary donations are otherwise regulated by § 33-513	Association sought to enforce statutory form‑approval requirement	District argued ruling would chill voluntary donations or donations for supplies	Court limited holding to employment contract form requirement; personal donations not governed by § 33-513

Miles v. Idaho Power Co., 116 Idaho 635, 778 P.2d 757 (standing doctrine guidance) (discusses focus on party seeking relief)
Knox v. State ex rel. Otter, 148 Idaho 324, 223 P.3d 266 (standing elements: injury in fact, causation, redressability)
Koch v. Canyon County, 145 Idaho 158, 177 P.3d 372 (Idaho courts look to U.S. Supreme Court for standing guidance)
Bear Lake Educ. Ass’n v. Board of Trustees of Bear Lake School Dist. No. 33, 116 Idaho 443, 776 P.2d 452 (associations may have standing to vindicate their own rights)
Warth v. Seldin, 422 U.S. 490 (associational standing principles)
Ameritel Inns, Inc. v. Greater Boise Auditorium Dist., 141 Idaho 849, 119 P.3d 624 (mootness doctrine and exceptions: collateral consequences, repetition-evading review, public interest)
Morrison v. Northwest Nazarene Univ., 152 Idaho 660, 273 P.3d 1253 (appellate rule: failure to brief attorney‑fees argument waives review)