Summary
The Idaho Supreme Court considered a constitutional challenge to House Bill 403, which altered procedures for litigation concerning the State’s obligation to provide a general, uniform, and thorough system of public schools. The court held that the legislation was special legislation directed at a particular pending lawsuit and improperly interfered with judicial procedural authority. The court also addressed whether the legislation’s educational necessity levy improperly delegated taxing power to the judiciary.
Topics
Practice areas
Questions Presented
- Whether the plaintiffs, including the school districts, retained standing to pursue the pending constitutional school-funding action after enactment of HB 403.
- Whether HB 403's provisions restructuring and effectively dismissing the pending ISEEO litigation constituted a special law regulating the practice of the courts in violation of Article III, section 19 of the Idaho Constitution.
- Whether HB 403 impermissibly altered Idaho judicial procedural rules and invaded the judiciary's rulemaking authority under Article V, section 13 of the Idaho Constitution.
- Whether HB 403's authorization for district courts to impose educational necessity levies delegated legislative taxing power to the judiciary in violation of the separation-of-powers provision of Article II, section 1 of the Idaho Constitution.
- Whether the trial judge was disqualified from continuing to hear the case because she responded to the State's petition for a writ of prohibition.
Holdings
- The plaintiffs, including the school districts, retained standing to pursue the action; the Legislature could not withdraw their statutory and constitutional right to seek relief by revoking standing during the pending litigation.
- HB 403's amendments to Idaho Code section 6-2215 were unconstitutional special legislation because they were directed specifically at the pending ISEEO lawsuit, its parties, and their cause of action, and regulated the practice of the courts.
- HB 403 unconstitutionally attempted to rewrite judicial procedures governing the pending case, including dismissal and stays, without the constitutionally required necessity and in conflict with the Idaho Supreme Court's authority over judicial procedure.
- The HB 403 amendments to Idaho Code section 6-2214 were unconstitutional because they delegated the power to tax to the judiciary in violation of Article II, section 1 of the Idaho Constitution.
- The trial judge was not disqualified merely because she filed a response to the State's petition for a writ of prohibition and obtained legal assistance in responding to it.
Key quotations
“This is a special enactment designed only to affect one particular lawsuit and is clearly a special law in violation of Article III, § 19.” (at 593)
“Because I.C. § 6-2214 as amended by HB 403 assigns the power to tax to the judiciary, it violates the Idaho Constitution.” (at 597)
“Just as Article II of the Idaho Constitution prohibits the Legislature from usurping powers properly belonging to the judicial department, so does that provision prohibit the judiciary from improperly invading the province of the Legislature.” (at 597)
Factual background
ISEEO, an association of Idaho public-school superintendents together with school districts and parents, challenged the adequacy of Idaho's school-funding system under Article IX, section 1 of the Idaho Constitution. After trial, the district court determined that reliance on local property taxes alone was inadequate to fund major repairs or replacement of unsafe school buildings, particularly in districts with low property-tax bases or low per-capita income. The Legislature enacted HB 403, which sought to restructure the pending litigation, dismiss or alter parties, change venue, and authorize district courts to impose educational necessity levies to address unsafe or unhealthy school facilities.
Procedural history
ISEEO brought a long-running action alleging that the Idaho Legislature failed to fulfill its constitutional duty to establish and maintain a general, uniform, and thorough system of public, free common schools. In prior appeals, the Idaho Supreme Court recognized standing, rejected mootness, and held that the State had a duty to provide a means for school districts to fund safe school facilities. After the district court found the existing funding system inadequate and the Legislature enacted HB 403, the district court declared HB 403 unconstitutional; the State appealed.
Remand instructions
The matter was to proceed in the district court to briefing, oral argument, and decision on the underlying issues raised by the appeal. Respondents were awarded costs on appeal.