The Idaho Supreme Court affirmed the district court's ruling regarding the City of Meridian's zoning regulations that prohibit the use of mobile tiny homes as secondary dwelling units. This decision affects property owners in Meridian, particularly those interested in using tiny homes for residential purposes.
The case, Chasidy Decker and Robert Calacal v. City of Meridian and Mayor Robert Simison, was filed under docket number 52335 and addressed the enforcement of local zoning laws. The court ruled on November 9, 2026, confirming the lower court's dismissal of the plaintiffs' claims.
Background
Chasidy Decker and Robert Calacal are the plaintiffs in this case. Calacal purchased a single-family residential property in Meridian in 2022, intending to rent out hookups for a tiny home owned by Decker. The tiny home, measuring 252 square feet, was moved onto Calacal's property on May 18, 2022. However, the day after its installation, a neighbor complained to the City about the tiny home, prompting an investigation by the City’s code enforcement officer.
City code enforcement officer Anthony Negrete determined that Decker's tiny home violated Meridian's zoning regulations, which prohibit mobile tiny homes from being used as residences unless they are located in an approved recreational vehicle park. Following this determination, the City issued notices of violation to both Calacal and Decker, demanding compliance with the zoning regulations.
The Ruling
The Idaho Supreme Court upheld the district court's decision, which dismissed the plaintiffs' substantive due process claims as nonjusticiable and rejected their equal protection claims based on selective enforcement. The court stated, "The judgment of the district court is affirmed," indicating that the lower court's findings were supported by the evidence presented during the trial.
The district court found that the plaintiffs did not demonstrate that they were treated differently from other property owners in a way that violated their equal protection rights. The court noted that the code enforcement officer's actions were based on a formal complaint and not on any discriminatory practices against the plaintiffs. The court concluded that the plaintiffs' claims were moot because even if they succeeded in their challenges to the zoning regulations, their application for a secondary dwelling unit permit would still be denied due to other zoning requirements.
Impact
This ruling has significant implications for property owners in Meridian and potentially other areas with similar zoning regulations. The court's decision reinforces the authority of local governments to enforce zoning laws and restrict the use of mobile tiny homes as secondary dwelling units. This case may deter other property owners from attempting to use tiny homes in violation of local codes, as the court has upheld the city's right to regulate land use.
Additionally, the ruling sets a precedent regarding the justiciability of zoning disputes, particularly in cases where plaintiffs have not pursued all available administrative remedies before seeking judicial intervention. The court's emphasis on the need for a formal application process before challenging zoning regulations may influence future cases involving land use and zoning disputes.
What's Next
Following the ruling, it is unclear if the plaintiffs will seek further legal recourse or if they will attempt to comply with the city’s zoning regulations in the future. The court's decision may also prompt other property owners to reconsider their plans for tiny homes, given the legal challenges highlighted in this case.
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