Reid v. Teton County

── Reid v. Teton County ── Court: Idaho Court of Appeals Date: April 29, 2026 Category: General IN THE COURT OF APPEALS OF THE STATE OF IDAHO Docket No. 53207 MICHAEL L. REID, ) ) Filed: April 29, 2026 Petitioner-Appellant, ) ) Melanie Gagnepain, Clerk v. ) ) THIS IS AN UNPUBLISHED TETON COUNTY, IDAHO, ) OPINION AND SHALL NOT ) BE CITED AS AUTHORITY Defendant-Appellant. ) ) Appeal from the District Court of the Seventh Judicial District, State of Idaho, Teton County. Hon. Steven W. Boyce, District Judge. Appeal from order dismissing petition for judicial review of a zoning ordinance, dismissed. Michael L. Reid, Victor, pro se appellant. Richard Stout, Teton County Prosecuting Attorney; Burkley M. Rudd, Deputy Prosecuting Attorney, Driggs, and Hopkins Roden Crockett Hansen & Hoopes, P.L.L.C.; D. Andrew Rawlings, Idaho Falls, for respondent. ________________________________________________ MELANSON, Judge Pro Tem Michael L. Reid appeals from the district court’s order dismissing his petition for judicial review of Teton County, Idaho’s repeal of portions of its former zoning and subdivision code and its replacement with a land development code that included a new zoning ordinance. Because Reid’s petition for judicial review was not timely filed with the district court, we dismiss this appeal for lack of jurisdiction. I. FACTUAL AND PROCEDURAL BACKGROUND In July 2022, the Teton County Board of Commissioners adopted amendments to its land development regulations that repealed and reenacted portions of the county’s zoning code. The 1 ordinance took effect on August 3, 2022. Reid owns property in Teton County that was subject to the revised zoning regulations. On August 2, 2024, Reid filed a petition for judicial review in the district court pursuant to I.R.C.P. 84. Reid argued that Teton County violated I.C. § 67-6511 by failing to provide adequate notice of the zoning change. Teton County moved to dismiss the petition. The district court concluded the petition for judicial review was untimely under I.C. § 67-6521 because it was filed beyond the twenty-eight-day deadline for seeking judicial review of a land-use decision and determined Reid had not exhausted his administrative remedies. The district court dismissed the petition. Reid filed a motion for rehearing, which the district court granted to permit additional briefing. Following rehearing, the district court again dismissed the petition. Reid appeals. II. ANALYSIS Reid advances multiple arguments that the district court erred in dismissing his petition for judicial review. An appellate court has a duty to ensure that it has subject matter jurisdiction over an appeal, which includes raising the issue sua sponte. City of Eagle v. Idaho Dep’t of Water Res., 150 Idaho 449, 454, 247 P.3d 1037, 1042 (2011). A district court lacks jurisdiction over a petition for judicial review if the petitioner fails to file the petition within the applicable deadline. I.R.C.P. 84(n). If a district court lacks jurisdiction, so too does the reviewing appellate court. Erickson v. Idaho Bd. of Registration of Prof’l Eng’rs & Prof’l Land Surveyors, 146 Idaho 852, 854, 203 P.3d 1251, 1253 (2009) superseded by statute on other grounds as recognized by City of Eagle, 150 Idaho 449, 247 P.3d 1037. To seek judicial review of a final z