Tracy Tucker v. State of Idaho, 162 Idaho 11

Background

Four named plaintiffs filed a class action challenging Idaho’s public defense system as violating the Sixth and Fourteenth Amendments and Article I, §13 of the Idaho Constitution; they sought statewide declaratory and injunctive relief.
Defendants were the State of Idaho, Governor C.L. "Butch" Otter (official capacity), and the Idaho Public Defense Commission (PDC) members; counties were not named.
The district court dismissed the complaint for lack of justiciability (standing, ripeness, separation of powers) and found the State immune from federal-law claims but not state-law claims.
Plaintiffs alleged systemic deficiencies: failure to provide counsel at critical stages, excessive caseloads, inadequate training, poor communication, and resulting pretrial detention and constructive/actual denials of counsel.
On appeal the Idaho Supreme Court addressed sovereign immunity for state-law constitutional claims, clarified that justiciability challenges are Rule 12(b)(1) jurisdictional issues, and analyzed standing, ripeness, and separation-of-powers as to each defendant.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sovereign immunity bars state-law constitutional claims against the State	State is responsible for ensuring constitutional public defense and can be sued for systemic violations	Sovereign immunity and I.R.C.P. 3(b) shield the State from such injunctive/state-law suits	Sovereign immunity does not bar suits alleging constitutional violations; State may be sued on state-law constitutional claims
Standing (injury, causation, redressability) to seek systemic injunctive relief	Systemic denials and constructive/actual failures to provide counsel create concrete injury traceable to State and PDC; relief would redress harms	Defendants (especially Governor) argued plaintiffs lack individualized injury, causation is to counties/Legislature, and relief is speculative	Plaintiffs have standing as to State and PDC (injury: actual/constructive denials; causation: State and PDC duties; redressability: State/PDC can remedy). No standing as to Governor Otter (causal link too attenuated)
Ripeness of systemic challenge	Injuries are concrete and ongoing; present need for adjudication over statewide deficiencies	Defendants argued the case was premature because individual cases were unresolved and PDC duties (later expanded) might address issues	Claims against State and PDC are ripe; district court erred to require exhaustion of individual remedies or conviction/post-conviction relief
Separation of powers — whether courts may order systemic remedies and retain oversight	Court can declare constitutional violations and order remedial plans; remedies may require coordination but do not commandeer Legislature	Defendants argued relief would improperly intrude on legislative/executive functions and require legislative action/funding	Separation-of-powers did not bar adjudication; requested relief challenges governmental inaction/failure to perform statutory duties rather than usurping a textually committed power

Key Cases Cited

Gideon v. Wainwright, 372 U.S. 335 (establishes state obligation to provide counsel to indigent defendants)
Strickland v. Washington, 466 U.S. 668 (framework for individualized ineffective-assistance claims; Court distinguished systemic claims from Strickland analysis)
United States v. Cronic, 466 U.S. 648 (constructive denial of counsel doctrine; presumption of prejudice in systemic-denial contexts)
Rothgery v. Gillespie County, Tex., 554 U.S. 191 (right to counsel attaches at initial critical stages)
Bennett v. Spear, 520 U.S. 154 (causation/traceability standard for standing)
Osmunson v. State, 135 Idaho 292 (state retains ultimate responsibility for constitutional duties delegated to subdivisions)
Idaho Sch. for Equal Educ. Opportunity v. State, 142 Idaho 450 (permitting declaratory relief and retained jurisdiction for systemic constitutional violations)