280 P.3d 693
Idaho2012Background
- Consolidated actions involving cottage-site residential leases on Idaho endowment lands (Priest Lake and Payette Lake).
- Attorney General challenged I.C. § 58-310A as unconstitutional under Article IX, § 8; district court upheld statute.
- Payette Lake Lessees alleged Board breached renewal terms; district court granted summary judgment for Board for failure to exhaust remedies.
- Court held § 58-310A unconstitutional as to disposition of endowment lands, including leases, and not severable.
- Payette Lake contract claim remanded for declaratory judgment handling; AG’s constitutionality ruling reversed.
- Court remanded Payette Lake proceedings for further district court consideration of contract interpretation in light of invalid statute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the Attorney General’s challenge authorized by standing? | Wasden has standing as guardian of endowment beneficiaries. | Priest Lake Lessees argue lack of standing. | Yes; AG has standing to challenge the statute on behalf of endowment beneficiaries. |
| Is I.C. § 58-310A unconstitutional under Article IX, § 8? | Statute exempts cottage sites from public auctions, violating disposal requirement. | Board's duty is to maximize long-term returns; auctions not required in every case. | Unconstitutional; disposal includes leases, triggering public auctions. |
| Is the statute’s invalidity severable from the remainder? | If unconstitutional, portions could survive. | Auction exemption is indispensable; statute non-severable. | Not severable; entire § 58-310A declared unconstitutional. |
| Did Payette Lake Lessees need to exhaust administrative remedies for contract claim? | Contract interpretation claim belongs in civil declaratory judgment. | Action should be administrative review. | District court erred; contract claim remanded for declaratory judgment handling. |
| Should the district court address the contract claim on remand given § 58-310A invalidation? | Remand appropriate; terms may be inconsistent with invalid statute. | Board’s obligations to maximize returns control lease terms. | Remand appropriate for contract interpretation consistent with invalid statute. |
Key Cases Cited
- Idaho Watersheds Project v. State Bd. of Land Comm’rs, 128 Idaho 761 (1996) (auction requirement tied to disposition of endowment lands; decision linked to leases and sales)
- Idaho Watersheds Project v. Bd. of Land Comm’rs, 133 Idaho 55 (1999) (IWP 2; disposal includes leases; amendment on sale vs. disposal)
- East Side Blaine Cnty. Livestock Ass’n v. State Bd. of Land Comm’rs, 34 Idaho 807 (1921) (mandatory competitive bidding to maximize return; auctions for leases)
- Wasden v. State Bd. of Land Comm’rs, 150 Idaho 547 (2010) (dissent cited regarding § 58-310A and market rent)
- Miles v. Idaho Power Co., 116 Idaho 635 (1989) (standing analysis framework and concrete adversariness)
- Van Valkenburgh v. Citizens for Term Limits, 135 Idaho 121 (2000) (standing requirements for state interests)
- Summers v. Earth Island Inst., 555 U.S. 488 (2009) (special solicitude for state actors in standing)