Tidwell, et al. v. Blaine County, et al.
Annotate this CasePlaintiffs Kiki Leslie Tidwell (“Tidwell”) and the Madison Jean Tidwell Trust opposed an affordable housing project on land dedicated to Blaine County, Idaho for public use. Plaintiffs contended the Final Plat contemplated the land be held for open space and recreational use, but Blaine County contracted with ARCH Community Housing Trust (“ARCH”) and Blaine County Housing Authority (“BCHA”) to donate a parcel ("Parcel C") to BCHA to construct community housing. Plaintiffs filed a complaint against the County, ARCH, and BCHA (collectively “the County”) seeking declaratory relief, injunctive relief, and damages to Tidwell under 42 U.S.C. 1983. The district court ultimately dismissed Tidwell’s section 1983 claim, but the district court allowed Plaintiffs to pursue the remaining claims, despite the County’s contention that Plaintiffs lacked standing to bring the complaint. Following a series of unsuccessful dispositive motions seeking summary and partial summary judgment on both sides, the case proceeded to court trial, where Plaintiffs prevailed on both claims for declaratory and injunctive relief. The district court denied Tidwell’s request for attorney fees. The County appealed, and Tidwell cross-appealed the dismissal of her section 1983 claim and both Plaintiffs appealed the district court’s denial of attorney fees. On appeal, the County again raised its standing argument, contending Plaintiffs had no particularized interest in the parcel and suffered no particularized injury. If Plaintiffs had standing, the County claimed the district court erred by concluding the Final Plat was ambiguous and by permitting extrinsic evidence, including testimony of what the parties intended to construct on the parcel when the land was transferred. The Plaintiffs cross-appealed, with Tidwell alleging the district court erred in dismissing her procedural and substantive due process claims brought under 42 U.S.C. 1983. Both Plaintiffs also contended the district court abused its discretion in denying their claim for attorney fees. The Idaho Supreme Court vacated the district court's judgment because Plaintiffs lacked standing to assert their claims. Costs, but not attorney fees, were awarded on appeal to the County.
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