City of Sparks v. Sparks Mun. Court
Annotate this CaseThe City of Sparks traditionally made most personnel and budget decisions for the Sparks Municipal Court. The City and Municipal Court later entered into a dispute over the City's exercise of this authority. The district court subsequently enjoined the City from making such decisions in the future based on the Municipal Court's broad authority to manage its own affairs. The City appealed. The Supreme Court (1) affirmed the portion of the district court's order enjoining the City from interfering with the Municipal Court's ability to make personnel decisions, holding that the separation of powers doctrine and the Municipal Court's inherent authority barred the City from interfering with the Municipal Court's control over such decisions; and (2) reversed the district court's order as to the parties' budgetary dispute, holding (i) the Municipal Court's inherent power over its budget must be weighed against the City's authority over government finances, but (ii) the parties failed to develop the record sufficiently for the Court to determine whether the Municipal Court properly invoked its inherent powers on this point. Remanded.
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