Idaho Watersheds Project v. State Board of Land Commissioners

When Idaho was admitted to the Union in 1890, the federal government granted the state certain lands (school lands) and provided that proceeds from their lease or sale were to be used “for school purposes only.” Article IX, § 8 of the Idaho Constitution subsequently acknowledged that state school lands must be leased to secure the “maximum long term financial return” to the state school system. More than 100 years later, an environmental organization called the Idaho Watersheds Project (IWP) (plaintiff) placed public bids on grazing leases for certain school lands. Even though the IWP placed the highest bids, the Idaho Land Board (board) (defendant), which oversaw the leasing, disqualified the IWP and instead granted the leases to several local ranchers. In doing so, the board relied on a state statute, I.C. § 58-310B, which required the board to consider not only bid prices, but also the effect the leases would have on the livestock industry and on the state economy. Because the IWP did not intend to use the land for livestock grazing, the board concluded that I.C. § 58-310B compelled disqualification of the IWP. The IWP sued the board in state district court, arguing that I.C. § 58-310B violated Article IX, § 8 of the Idaho Constitution by considering factors other than revenue to state schools. The trial court upheld the constitutionality of the statute, and the IWP appealed.