Idaho Power Company v. Idaho State Tax Commission
Annotate this CaseIdaho Power Company and Avista Corporation (collectively the “Companies”) contested the the Idaho State Tax Commission (the “Commission”), in its capacity as the State Board of Equalization, assessments of their operating property during 2019 and 2020, asserting that those assessments violated the proportionality and uniformity requirements set out in Article VII, sections 2 and 5 of the Idaho Constitution. The Commission rejected the Companies’ challenges and upheld its assessments. The Companies then sought judicial review of the Commission’s decision in district court, arguing that the Commission had erred in two significant ways: (1) because the Commission reduced the assessed values of certain railroads’ operating property in compliance with federal law, the assessed values of the Companies’ operating property were unconstitutionally assessed at a higher percentage of their actual cash value than were the railroads’ operating properties (the "4-R" claim); and (2) that commercial property had been assessed (and therefore taxed) at a lower percentage of its actual cash value than the Companies’ operating property, rendering the Companies’ operating property unconstitutionally disproportionally over-taxed (the "alternative claim"). The district court granted summary judgment to the Commission as to the Companies’ first argument. However, the district court concluded genuine issues of material fact existed as to the Companies’ second argument and declined to grant the Commission’s request for summary judgment. Both parties appealed. The Idaho Supreme Court concluded the district court erred in dismissing the 4-R claim, but did not err as to the alternative claim. Judgment was reversed in part, affirmed in part, and remanded for further proceedings.
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