Tucker v. Idaho
Annotate this CaseThe plaintiffs were indigent defendants represented in criminal actions by attorneys provided through Idaho’s public defense system. They alleged that numerous inadequacies in Idaho’s public defense system, as administered by the State and the Idaho Public Defense Commission (“PDC” or together “Respondents”), violated the rights of the named plaintiffs, as well as those of similarly situated criminal defendants across Idaho, under the Sixth and Fourteenth Amendments to the U.S. Constitution and Article I, Section 13 of the Idaho Constitution. In 2019, the district court denied cross motions for summary judgment, citing a lack of precedent as to the controlling legal standard to be applied, and requested this appeal. The Idaho Supreme Court granted the district court’s request for permissive appeal to determine the standard of review. The central issue presented for the Supreme Court's review centered on how to properly evaluate the deficiencies in Idaho’s public defense systems alleged by Appellants. In sum, Appellants insisted that a broader view was sufficient, while Respondents demanded the district court examine this issue closely. The Supreme Court held that both views were necessary: "a close up view, which allows for greater specificity, must be applied to the individual claims of at least one of the named plaintiffs whose allegations formed the basis of standing; however, a more distant view, which allows for greater overall perspective, is permissible for the examination of the systemic constitutional shortcomings alleged by Appellants."
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