The Idaho Supreme Court reversed and remanded a district court decision that denied a petition for review in *Crookham v. County of Canyon*, a case challenging Canyon County's approval of a controversial farmland rezoning application.
The case centers on a dispute over the Judith A. Gross Trust and Douglas Gross's application to rezone 145 acres of farmland for light industrial use. Canyon County's Development Services Department and Planning and Zoning Commission both recommended approval of the rezoning request, which the Canyon County Board of Commissioners ultimately granted.
George Crookham, Crookham Company, John Hoadley, and Ron Amarel filed a petition for review challenging the county's decision. However, the U.S. District Court for the Third Judicial District of Idaho denied their petition, concluding that the petitioners lacked standing to bring the challenge.
In its January 16, 2026 opinion authored by Justice Brody, the Idaho Supreme Court addressed a critical legal question about which standing test applies to petitions for review brought under Idaho's Local Land Use Planning Act. The court needed to determine whether courts should apply the traditional three-part standing test derived from federal law, or LLUPA's specific "affected person" standard.
The distinction between these two standards could significantly impact who can challenge local land use decisions in Idaho. The traditional federal three-part test typically requires plaintiffs to show they suffered an injury in fact that is fairly traceable to the defendant's conduct and likely to be redressed by a favorable decision. LLUPA's "affected person" standard may provide a different framework for determining who has sufficient interest to challenge local zoning and planning decisions.
The case highlights ongoing tensions between property development and community concerns about land use changes. The proposed rezoning would convert agricultural land to light industrial use, a change that could affect traffic patterns, environmental conditions, and the character of the surrounding area. Such rezonings often generate opposition from neighboring property owners and community members who may be impacted by increased commercial or industrial activity.
Canyon County, located in southwestern Idaho near Boise, has experienced significant growth and development pressure in recent years. The county's planning and zoning decisions frequently involve balancing economic development opportunities with preservation of agricultural land and quality of life concerns for existing residents.
The petitioners were represented by Sawtooth Law Offices, with attorney David P. Claiborne arguing their case before the high court. Canyon County was represented by Canyon County Prosecuting Attorney Chris Boyd, with Laura K. Keys presenting oral arguments for the respondents.
The supreme court's reversal means the case will return to the district court for further proceedings. The district court will need to reconsider the standing question under whatever framework the supreme court established in its full opinion. If the petitioners are found to have standing, the district court would then proceed to review the merits of their challenge to the county's rezoning approval.
This decision could have broader implications for land use litigation throughout Idaho. By clarifying the appropriate standing test for LLUPA challenges, the court's ruling may make it easier or more difficult for community members to challenge local zoning decisions, depending on how the court resolved the legal question.
The case also reflects the complex procedural landscape surrounding land use appeals in Idaho. Property owners, developers, and community members must navigate both state procedural requirements and local government processes when challenging or defending zoning decisions. The standing requirements determine the threshold question of who can participate in judicial review of these administrative decisions.
For Canyon County, the reversal means the rezoning approval remains subject to ongoing litigation. The county will need to defend its decision-making process and the merits of approving the Gross Trust's rezoning application when the case returns to the district court.
The Crookham Company, one of the petitioners, is an Idaho corporation that may have business or property interests affected by the proposed industrial development. The involvement of both individual and corporate petitioners suggests the rezoning decision had multiple potential impacts on different types of stakeholders in the community.
Moving forward, the district court will need to apply the supreme court's guidance on standing requirements and determine whether the petitioners can proceed with their substantive challenge to Canyon County's rezoning approval. The ultimate resolution of this case will depend on both the standing determination and, if standing is established, the merits of the petitioners' arguments against the county's decision to approve the industrial rezoning of the agricultural property.