Russell Joki v. State Bd of Education, 162 Idaho 5

Plaintiffs (led by Russell Joki) sued the State of Idaho, state education officials, 114 school districts and one charter school claiming fees charged students and the statewide school-funding system violated Article IX, §1 (duty to provide a general, uniform, thorough, and free public school system).
Plaintiffs sought reimbursement for fees and a declaratory judgment that Idaho’s education funding system is unconstitutional; they also sought to proceed as a class action.
The State Defendants moved to dismiss under the Constitutionally Based Educational Claims Act (CBECA), I.C. §§ 6-2201–2216, which requires patrons to sue local districts first and obtain court authorization before adding state defendants.
The district court dismissed the State Defendants: (1) because plaintiffs had not complied with CBECA’s procedural requirements to add state parties; and (2) because the complaint did not allege facts falling within the narrow remedy in ISEEO V concerning school facilities funding.
The district court later entered a small judgment ($85) against Meridian Joint District #2; plaintiffs appealed only the dismissal of the State Defendants and their request for attorney’s fees.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred in dismissing State Defendants under the CBECA	Joki: State officials are proper defendants because of their general responsibilities; CBECA is inapplicable or unconstitutional as applied and improperly limits class actions	State: CBECA governs; plaintiffs failed to first sue local districts and obtain district-court authorization to add state parties; CBECA upheld as constitutional	Affirmed — dismissal proper because plaintiffs did not follow CBECA’s procedural requirement to sue the local district first and obtain court authorization before adding state defendants
Whether plaintiffs are entitled to attorney’s fees under the private-attorney-general doctrine	Joki: Prevailing on public-interest claims entitles him to fees	State: Only a prevailing party may recover under I.C. § 12-121; Joki did not prevail against State Defendants	Denied — Joki was not a prevailing party as to the State Defendants, so no fees awarded

Osmunson v. State, 135 Idaho 292, 17 P.3d 236 (Idaho 2000) (upholding CBECA’s requirement that patrons sue local districts first before adding state defendants)
ISEEO v. State, 140 Idaho 586, 97 P.3d 453 (Idaho 2004) (holding HB 403 unconstitutional as a special law and separation-of-powers violation; addressed amendments aimed at undermining ISEEO litigation)
ISEEO v. State, 142 Idaho 450, 129 P.3d 1199 (Idaho 2005) (affirming that the state’s method of funding school facilities was unconstitutional in the narrow facilities context)
Hellar v. Censarrusa, 106 Idaho 571, 682 P.2d 524 (Idaho 1984) (discussing private-attorney-general basis for attorney’s fees under I.C. § 12-121)
Coalition for Agriculture’s Future v. Canyon County, 160 Idaho 142, 369 P.3d 920 (Idaho 2016) (standard of review for dismissals under I.R.C.P. 12(b)(6) and summary-judgment review)