equal protection clause in Idaho

2010Viking can bring an equal protection claim as a “class of one” if it alleges that it “has been intentionally treated *199 differently from others similarly situated and that there is no rational basis 5 for the difference in treatment.” Village of Willowbrook v. Olech, 528 U.S. 562, 564 , 120 S.Ct. 1073, 1074 , 145 L.Ed.2d 1060, 1063 (2000).

2010Viking can bring an equal protection claim as a “class of one” if it alleges that it “has been intentionally treated *199 differently from others similarly situated and that there is no rational basis 5 for the difference in treatment.” Village of Willowbrook v. Olech, 528 U.S. 562, 564 , 120 S.Ct. 1073, 1074 , 145 L.Ed.2d 1060, 1063 (2000).

2013Anderson v. Spalding, 137 Idaho 509, 514 , 50 P.3d 1004, 1009 (2002); Henson v. Dep’t of Law Enforcement, 107 Idaho 19, 23 , 684 P.2d 996, 1000 (1984); State v. Hayes, 108 Idaho 556, 560 , 700 P.2d 959, 963 (Ct. App. 1985).

2013Anderson v. Spalding, 137 Idaho 509, 514 , 50 P.3d 1004, 1009 (2002); Henson v. Dep’t of Law Enforcement, 107 Idaho 19, 23 , 684 P.2d 996, 1000 (1984); State v. Hayes, 108 Idaho 556, 560 , 700 P.2d 959, 963 (Ct. App. 1985).

2019However, the basic tenet underlying equal protection is that it is only "similarly situated people" that are entitled to "receive the same benefits and burdens under the law." State v. Hansen, 125 Idaho 927 , 933, 877 P.2d 898 , 904 (1994) (recognizing that "[t]he disparity in sentences between one defendant and another defendant convicted of the same crime does not, in itself, establish an equal protection violation"); see also State v. Rawlings, 159 Idaho 498 , 501, 363 P.3d 339 , 342 (2015) (finding no violation of the Equal Protection Clause because "[t]he persons in these two classificati

2019However, the basic tenet underlying equal protection is that it is only "similarly situated people" that are entitled to "receive the same benefits and burdens under the law." State v. Hansen, 125 Idaho 927 , 933, 877 P.2d 898 , 904 (1994) (recognizing that "[t]he disparity in sentences between one defendant and another defendant convicted of the same crime does not, in itself, establish an equal protection violation"); see also State v. Rawlings, 159 Idaho 498 , 501, 363 P.3d 339 , 342 (2015) (finding no violation of the Equal Protection Clause because "[t]he persons in these two classificati

2017For that reason, the district court rejected Kelley’s equal protection argument and noted that Kelley “has not identified a discriminatory classification at issue.” Cf. McLean v. Maverik Country Stores, Inc., 142 Idaho 810, 813 , 135 P.3d 756, 759 (2006) (“The first step in an equal protection analysis is to identify the classification at issue.”).

2017For that reason, the district court rejected Kelley’s equal protection argument and noted that Kelley “has not identified a discriminatory classification at issue.” Cf. McLean v. Maverik Country Stores, Inc., 142 Idaho 810, 813 , 135 P.3d 756, 759 (2006) (“The first step in an equal protection analysis is to identify the classification at issue.”).

2006“Under the ‘rational basis test,’ a classification will withstand an equal protection challenge if there is any conceivable state of facts which will support it.” Bint v. Creative Forest Prods., 108 Idaho 116, 120 , 697 P.2d 818, 822 (1985).

2006“Under the ‘rational basis test,’ a classification will withstand an equal protection challenge if there is any conceivable state of facts which will support it.” Bint v. Creative Forest Prods., 108 Idaho 116, 120 , 697 P.2d 818, 822 (1985).

2021“Under the rational basis test, a classification will withstand an equal protection challenge if there is any conceivable state of facts which will support it.” Id. at 396–97, 987 P.2d at 308–09 (internal quotation omitted).

2021“Under the rational basis test, a classification will withstand an equal protection challenge if there is any conceivable state of facts which will support it.” Id. at 396–97, 987 P.2d at 308–09 (internal quotation omitted).

2013Anderson v. Spalding, 137 Idaho 509, 514 , 50 P.3d 1004, 1009 (2002); Henson v. Dep’t of Law Enforcement, 107 Idaho 19, 23 , 684 P.2d 996, 1000 (1984); State v. Hayes, 108 Idaho 556, 560 , 700 P.2d 959, 963 (Ct. App. 1985).

2013Anderson v. Spalding, 137 Idaho 509, 514 , 50 P.3d 1004, 1009 (2002); Henson v. Dep’t of Law Enforcement, 107 Idaho 19, 23 , 684 P.2d 996, 1000 (1984); State v. Hayes, 108 Idaho 556, 560 , 700 P.2d 959, 963 (Ct. App. 1985).

2010See Idaho Water Resources Board v. Kramer, 97 Idaho 535 , 548 P.2d 35 (1976).

2010See Idaho Water Resources Board v. Kramer, 97 Idaho 535 , 548 P.2d 35 (1976).

2005See Tiffany v. City of Payette, 121 Idaho 396, 401 , 825 P.2d 493, 498 (1992); Langmeyer v. State, 104 Idaho 53, 55 , 656 P.2d 114, 116 (1982); Saenz v. Roe, 526 U.S. 489, 503 , 119 S.Ct. 1518, 1526 , 143 L.Ed.2d 689, 704 (1999); Sosna v. Iowa, 419 U.S. 393, 406 , 95 S.Ct. 553, 560-61 , 42 L.Ed.2d 532, 544 (1974).

2005See Tiffany v. City of Payette, 121 Idaho 396, 401 , 825 P.2d 493, 498 (1992); Langmeyer v. State, 104 Idaho 53, 55 , 656 P.2d 114, 116 (1982); Saenz v. Roe, 526 U.S. 489, 503 , 119 S.Ct. 1518, 1526 , 143 L.Ed.2d 689, 704 (1999); Sosna v. Iowa, 419 U.S. 393, 406 , 95 S.Ct. 553, 560-61 , 42 L.Ed.2d 532, 544 (1974).

2013Anderson v. Spalding, 137 Idaho 509, 514 , 50 P.3d 1004, 1009 (2002); Henson v. Dep’t of Law Enforcement, 107 Idaho 19, 23 , 684 P.2d 996, 1000 (1984); State v. Hayes, 108 Idaho 556, 560 , 700 P.2d 959, 963 (Ct. App. 1985).

2012“In other words, the equal protection clause of the fourteenth amendment is designed to assure that those persons similarly situated with respect to a governmental action should be treated similarly.” Id. (internal quotations omitted) (emphasis in original); see Primary Health Network, Inc. v. State, 137 Idaho 663, 670 , 52 P.3d 307, 314 (2002) (“Equal protection issues focus upon classifications within a statutory scheme that allocate benefits or burdens differently among categories of persons affected.”).

2021“Under the rational basis test, a classification will withstand an equal protection challenge if there is any conceivable state of facts which will support it.” Id. at 396–97, 987 P.2d at 308–09 (internal quotation omitted).

2021“Under the rational basis test, a classification will withstand an equal protection challenge if there is any conceivable state of facts which will support it.” Id. at 396–97, 987 P.2d at 308–09 (internal quotation omitted).

2006As to the former, the Court generally applied strict scrutiny, see, e.g., Soto-Lopez, 476 U.S. at 904 , 106 S.Ct. at 2322-23 , 90 L.Ed.2d at 906 ; Shapiro, 394 U.S. at 631 , 89 S.Ct. at 1329-30 , 22 L.Ed.2d at 613 ; as to the latter, it declined to say whether strict scrutiny should apply, instead holding that the statutes at issue were not even rationally related to a legitimate state interest.

2006As to the former, the Court generally applied strict scrutiny, see, e.g., Soto-Lopez, 476 U.S. at 904 , 106 S.Ct. at 2322-23 , 90 L.Ed.2d at 906 ; Shapiro, 394 U.S. at 631 , 89 S.Ct. at 1329-30 , 22 L.Ed.2d at 613 ; as to the latter, it declined to say whether strict scrutiny should apply, instead holding that the statutes at issue were not even rationally related to a legitimate state interest.

1999Under the “rational basis” or “rational relationship” test, the regulation or statute in question should be upheld as long as its objectives “can reasonably be said to promote the health, safety and welfare of the public.” Jones v. State Board of Medicine, 97 Idaho 859, 871 , 555 P.2d 399, 411 (1976).

1999Under the “rational basis” or “rational relationship” test, the regulation or statute in question should be upheld as long as its objectives “can reasonably be said to promote the health, safety and welfare of the public.” Jones v. State Board of Medicine, 97 Idaho 859, 871 , 555 P.2d 399, 411 (1976).

1993However, in State v. Beam, 115 Idaho 208 , 766 P.2d 678 (1988), this Court upheld I.C. § 19-2719 under an equal protection analysis.

1993However, in State v. Beam, 115 Idaho 208 , 766 P.2d 678 (1988), this Court upheld I.C. § 19-2719 under an equal protection analysis.

1988The correct equal protection analysis was set out by Justice Brennan of the United States Supreme Court in Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456 , 101 S.Ct. 715 , 66 L.Ed.2d 659 (1981), which this Court has approved and quoted from as follows: “ ‘But States are not required to convince the courts of the correctness of their legislative judgment.

1988The correct equal protection analysis was set out by Justice Brennan of the United States Supreme Court in Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456 , 101 S.Ct. 715 , 66 L.Ed.2d 659 (1981), which this Court has approved and quoted from as follows: “ ‘But States are not required to convince the courts of the correctness of their legislative judgment.

2012“In other words, the equal protection clause of the fourteenth amendment is designed to assure that those persons similarly situated with respect to a governmental action should be treated similarly.” Id. (internal quotations omitted) (emphasis in original); see Primary Health Network, Inc. v. State, 137 Idaho 663, 670 , 52 P.3d 307, 314 (2002) (“Equal protection issues focus upon classifications within a statutory scheme that allocate benefits or burdens differently among categories of persons affected.”).

2012“In other words, the equal protection clause of the fourteenth amendment is designed to assure that those persons similarly situated with respect to a governmental action should be treated similarly.” Id. (internal quotations omitted) (emphasis in original); see Primary Health Network, Inc. v. State, 137 Idaho 663, 670 , 52 P.3d 307, 314 (2002) (“Equal protection issues focus upon classifications within a statutory scheme that allocate benefits or burdens differently among categories of persons affected.”).

2009Since indigency in this context is a relative term rather than a classification, fitting “the problem of this case into an equal protection framework is a task too Procrustean to be rationally accomplished,” North Carolina v. Pearce, 395 U.S. 711, 723 , 89 S.Ct. 2072, 2079 , 23 L.Ed.2d 656, 668 (1969).

2009Since indigency in this context is a relative term rather than a classification, fitting “the problem of this case into an equal protection framework is a task too Procrustean to be rationally accomplished,” North Carolina v. Pearce, 395 U.S. 711, 723 , 89 S.Ct. 2072, 2079 , 23 L.Ed.2d 656, 668 (1969).

1996The Court held the following: (1) pursuant to Thompson v. Engelking, 96 Idaho 793 , 537 P.2d 635 (1975), the system of school funding did not violate the “uniformity” requirement of the education clause of art. 9, § 1 of the Idaho Constitution; (2) that the equal protection clause was not violated by the current school funding system; (3) that the citizen/taxpayer plaintiffs did not have standing to sue; and (4) that Thompson did not decide whether *280 the “thoroughness” requirement of the education clause was violated in that case and therefore did not foreclose the ISEEO’s suit.

1996The Court held the following: (1) pursuant to Thompson v. Engelking, 96 Idaho 793 , 537 P.2d 635 (1975), the system of school funding did not violate the “uniformity” requirement of the education clause of art. 9, § 1 of the Idaho Constitution; (2) that the equal protection clause was not violated by the current school funding system; (3) that the citizen/taxpayer plaintiffs did not have standing to sue; and (4) that Thompson did not decide whether *280 the “thoroughness” requirement of the education clause was violated in that case and therefore did not foreclose the ISEEO’s suit.

1992Freeman Co., 117 Idaho 706, 711 , 791 P.2d 1285, 1290 (1990) (“[T]he appropriate test to review a statute which impacts social or economic areas is the rational basis test which requires only that the statute ‘advances legitimate legislative goals in a rational fashion.’ ”) (Citing Leliefeld v. Johnson, 104 Idaho 357, 374 , 659 P.2d 111, 128 (1983).) The Act’s distinction between commercial and non-commercial outfitting does not violate the equal protection clause of the United States Constitution.

1992Freeman Co., 117 Idaho 706, 711 , 791 P.2d 1285, 1290 (1990) (“[T]he appropriate test to review a statute which impacts social or economic areas is the rational basis test which requires only that the statute ‘advances legitimate legislative goals in a rational fashion.’ ”) (Citing Leliefeld v. Johnson, 104 Idaho 357, 374 , 659 P.2d 111, 128 (1983).) The Act’s distinction between commercial and non-commercial outfitting does not violate the equal protection clause of the United States Constitution.