Todd Rich v. State of Idaho
159 Idaho 553
Idaho2015Background
- In 1992 Todd Rich pleaded guilty to felony rape in Idaho, was sentenced, placed on probation, and completed probation in 2004.
- On April 12, 2004 the Idaho district court reduced his conviction to a misdemeanor under Idaho Code § 19-2604(2) and stated his civil rights were restored.
- Rich later moved to Pennsylvania; a PA administrative law judge denied his request to possess a firearm, citing Idaho law (I.C. § 18-310(2)) as not restoring firearm rights for certain felonies.
- In 2013 Rich sued in Idaho state court seeking a declaratory judgment that his Idaho firearm rights were restored.
- The Idaho district court dismissed the action with prejudice on two alternative grounds: (1) lack of standing/justiciability because Rich lived outside Idaho and faced no present threat of prosecution; and (2) restoration of firearm rights must be sought from the Idaho Commission of Pardons and Parole under I.C. § 18-310(3).
- On appeal Rich contested only the standing ruling; the Idaho Supreme Court affirmed because the district court’s alternative unchallenged ground (Commission authority) was dispositive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rich had standing to seek an Idaho declaratory judgment about firearm rights | Rich argued a declaration that Idaho restored his firearm rights could affect his federal firearm status and therefore is justiciable | State argued no concrete controversy: Rich lives in PA, faces no Idaho prosecution risk, and PA independently denied his firearm request | Court affirmed dismissal—alternative uncontested ground (exclusive restoration process via Pardons & Parole) dispositive |
| Whether a district court can restore firearm rights for felonies enumerated in I.C. § 18-310 | Rich asserted his § 19-2604(2) misdemeanor reclassification restored civil/firearm rights | State pointed to I.C. § 18-310(3) making restoration for specified felonies subject to application to the Commission of Pardons and Parole | Court affirmed district court’s ruling that restoration mechanism is through the Pardons & Parole Commission, not the district court |
Key Cases Cited
- Knox v. State ex rel. Otter, 148 Idaho 324, 223 P.3d 266 (2009) (standing requires injury in fact, traceability, and redressability)
- State v. Grazian, 144 Idaho 510, 164 P.3d 790 (2007) (appellate court will affirm on an uncontested alternative ground)