United States v. State of Idaho
1:22-cv-00236
| D. Idaho | Dec 13, 2024Background
- The United States challenged five Idaho statutes related to water rights allocation, particularly as applied to federal lands and stockwater rights.
- The case emerged after Idaho amended its statutory regime following the landmark Joyce Livestock Co. v. United States decision regarding water rights on federal land.
- Related litigation included the Snake River Basin Adjudication, culminating in a 2014 decree recognizing federal stockwater rights.
- Cross-motions for summary judgment were filed by the United States, the State (and agency), the Idaho Legislature, and various ranching entities.
- In August 2024, the court issued a Memorandum Decision finding some statutes constitutional (in part) and others invalid under the Supremacy Clause.
- The present decision addresses both parties’ requests to amend the judgment for clarity under Federal Rule 60(a).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of Idaho § 42-222(2) and § 42-224 | Both violate Supremacy Clause and other constitutional provisions | Both sections constitutional; do not unlawfully burden US | Both upheld as constitutional; summary judgment for Defendants |
| Constitutionality of §§ 42-113(2)(b), 42-502, and 42-504 | Violate Supremacy Clause as applied to US | Statutes valid, do not violate federal rights | Unconstitutional as applied to US; summary judgment for US |
| Application of Property Clause and Contracts Clause | State laws conflict with federal property and contractual rights | No conflict or impairment; laws valid | No facial violation of Property or Contracts Clauses |
| Retroactivity and Sovereign Immunity claims | Statutes retroactively impair rights; immunity applies | No retroactive impairment; sovereign immunity not at issue | No facial retroactivity violation; sovereign immunity not reached |
Key Cases Cited
- Miller v. Transamerican Press, Inc., 709 F.2d 524 (9th Cir. 1983) (clarifies Rule 60(a) cannot be used for substantive changes)
- Garamendi v. Henin, 683 F.3d 1069 (9th Cir. 2012) (Rule 60(a) allows clarification for judgment reflecting intent)
- Blanton v. Anzalone, 813 F.2d 1574 (9th Cir. 1987) (judgment must reflect original intent, not after-the-fact rationale)