Idaho Supreme Court Reinstates Class Action Against the State Alleging Inadequate Public Defense System
by Mark Wilson
On April 28, 2017, the Idaho Supreme Court reversed the dismissal of a class action lawsuit alleging that Idaho’s public defense system violates federal and state constitutional standards. The Court held that claims against the State and the Idaho Public Defense Commission (“PDC”) were improperly dismissed but upheld the dismissal against the Governor.
On June 17, 2015, four Idaho criminal defendants brought a class action lawsuit against the State of Idaho, Governor C.L. “Butch” Otter, and seven members of the PDC. The Idaho Supreme Court noted that the plaintiffs are not seeking any relief in their own cases; instead, “they seek to effect systemic reform.”
Plaintiffs alleged systemic inadequacies in the public defense system that resulted in actual or constructive denials of counsel at critical stages of the prosecution in violation of the U.S. Constitution and Idaho Constitution. They sought various forms of equitable relief, “including a declaration that Idaho’s public defense system is unconstitutional and an injunction requiring Respondents to bring Idaho’s public defense system into constitutional compliance.” The district court granted defendants’ motion to dismiss, holding that dismissal was required on standing, ripeness, and separation of powers grounds.
The Idaho Supreme Court reversed the district court’s dismissal of the claims against the State and PDC but affirmed the dismissal of the claims against Governor Otter. The Supreme Court first held that “sovereign immunity is inapplicable when constitutional violations are alleged.” Next, the Court concluded that plaintiffs adequately alleged standing against the State and PDC. In doing so, the Court determined that in holding that plaintiffs failed to show “injury in fact,” the lower court improperly applied Strickland v. Washington, 466 U.S. 668 (1984), and engaged in an erroneous case-by-case injury inquiry. The Idaho Supreme Court held that Strickland “is inapplicable when systemic deficiencies in the provision of public defense are at issue.” Rather, Gideon v. Wainwright, 372 U.S. 335 (1963), and State v. Montroy, 37 Idaho 684 (1923), control. Ultimately the high court concluded that plaintiffs “satisfy the injury in fact standard because the complaint alleged actual and constructive denials of counsel at critical stages of the prosecution.”
Turning to the issue of ripeness, the Supreme Court found that the district court applied the same erroneous analysis it applied when it incorrectly concluded that plaintiffs failed to sufficiently allege “injury in fact.” Applying the correct analysis, the Court ruled that the claims against the State and PDC were ripe.
Finally, the high court determined that the district court improperly held that it lacked jurisdiction over the case under the separation of powers doctrine. The “requested relief does not implicate the separation of powers doctrine. The right to counsel, which Appellants seek to vindicate, is not entrusted to a particular branch of government.”
The Idaho Supreme Court remanded the “case for further proceedings consistent with” its opinion. Plaintiffs were represented by Richard Alan Eppink and Jason D. Williamson of the American Civil Liberties Union of Idaho Foundation. See: Tucker v. State, 394 P.3d 54 (Idaho 2017).
Related legal case
Tucker v. State
|Cite||394 P.3d 54 (Idaho 2017)|