Arnold v. City of Stanley
Annotate this CaseThomas and Rebecca Arnold appealed the grant of summary judgment in favor of the City of Stanley. In 2012, the City provided notice to the Arnolds (and other interested parties) of the date and time for three public hearings and a regular city council meeting, all scheduled to take place on August 9, 2012. The first of the three public hearings was noticed to begin at 5:00 p.m. and was for the purpose of receiving public comment on proposed Ordinance 189, the ordinance that the Arnolds alleged affected their property rights. The second and third hearings were noticed to begin at 5:15 p.m. and 5:30 p.m., respectively (and were for the purpose of public comment on matters not at issue here). The regular city council meeting was noticed to begin at 6:00 p.m. The first two meetings were held at their scheduled times. The third meeting began five minutes early, at 5:25 p.m., and concluded at 5:29 p.m. The regular city council meeting, scheduled to begin at 6:00 p.m., commenced at 5:31 p.m. and adjourned at 6:55 p.m. Prior to the start of the 6:00 p.m. meeting, the City did not amend the notices it had provided or otherwise notify the public that the meetings would begin earlier than scheduled. The early start time of the 6:00 p.m. meeting and the City's failure to provide amended notice of the earlier start time were the issues presented in this appeal to the Supreme Court: it was at the 6:00 p.m. meeting that the mayor and city council deliberated toward a decision on Ordinance 189, eventually voting to adopt the ordinance. Although the Arnolds were fully aware of the agenda items to be discussed at the various meetings, at no time from the outset of the first meeting at 5:03 p.m. until the final meeting adjourned at 6:55 p.m. did they attend the meeting; the Arnolds conceded at oral argument that they had no intention of attending the meeting. Following adoption of Ordinance 189, the Arnolds filed an action against the City under Idaho Code section 67-2347(6), seeking to have the ordinance declared null and void because the City held the 6:00 p.m. meeting in violation of Idaho's open meeting law by starting the meeting early and failing to provide notice of the earlier start time. The district court held the Arnolds lacked standing to bring an enforcement action because the plain language of Section 67-2347(6) allows standing for such an action only to one who is actually affected by a violation of the open meeting law, instead of being affected only by a substantive action taken at the meeting. The court granted the City's motion for summary judgment on this basis. The Arnolds appealed. The Supreme Court affirmed the district court: because a plain reading of the statute contradicted the Arnolds' argument, and because they did not even claim to have been actually harmed by the 6:00 p.m. meeting's early start time, the Court found that their appeal was brought without a reasonable basis in fact or law.
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