Wilson v. Idaho State Board of Land Commissioners

CourtIdaho Supreme Court
DecidedSeptember 5, 2025
Docket51376
StatusPublished

This text of Wilson v. Idaho State Board of Land Commissioners (Wilson v. Idaho State Board of Land Commissioners) is published on Counsel Stack Legal Research, covering Idaho Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wilson v. Idaho State Board of Land Commissioners, (Idaho 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF IDAHO

Docket No. 51376

GREGORY M. WILSON, ) ) Petitioner-Appellant, ) Boise, May 2025 Term ) v. ) Opinion filed: September 5, 2025 ) IDAHO STATE BOARD OF ) Melanie Gagnepain, Clerk LAND COMMISSIONERS; IDAHO ) DEPARTMENT OF LANDS; and ) WILLIAM FALOON, ) ) Respondents. )

Appeal from the District Court of the First Judicial District of the State of Idaho, Bonner County. Susie Jensen, District Judge.

The decision of the district court is affirmed.

Gregory M. Wilson, Post Falls, Appellant pro se.

Raúl R. Labrador, Idaho Attorney General, Boise, for Respondents Idaho State Board of Land Commissioners and Idaho Department of Lands. Jennifer J. Winters argued.

Fulgham Law, PLLC, Spokane, WA, for Respondent Willaim Faloon. Mischelle R. Fulgham argued. _______________________________________________

MOELLER, Justice. This case concerns “littoral1 rights,” which are the rights of landowners to use their land bordering the shoreline of a still body of water, such as a lake. Gregory M. Wilson (“Wilson”) owns property along the shore of Priest Lake in Bonner County, Idaho. In 2021, he filed an application with the Idaho Department of Lands (“IDL”) seeking a permit for a submerged log structure located near the southern boundary of his lot. He alleges the structure has been there since the early 1960s.

1 “Of, relating to, or involving the coast or shore of an ocean, sea, or lake.” Littoral, Black’s Law Dictionary (12th ed. 2024)

1 IDL denied Wilson’s application pursuant to Idaho Code section 58-1312, 2 concluding that Wilson had failed to provide documentation showing the structure had not been modified since 1974. Wilson contested IDL’s decision. After a hearing, IDL Director Dustin Miller issued a Final Order, affirming the denial of Wilson’s permit. Wilson then filed a petition for judicial review in district court. The district court affirmed IDL’s Final Order and concluded that Wilson’s due process rights were not violated. Wilson now appeals to this Court. For the following reasons, we affirm the district court’s decision. I. FACTUAL AND PROCEDURAL BACKGROUND Wilson is a littoral landowner whose property borders the shoreline of Priest Lake in Bonner County, Idaho. The subject of this litigation is a wooden structure embedded in the lakebed near Wilson’s shoreline. It is described as a “submerged log and timber framed structure” and is “fastened with spikes” to the bottom of the lake. The structure, known as a “groyne” or a “jetty,” was constructed perpendicular to the shoreline to prevent erosion and allow for a sandy beach to accumulate. Wilson alleges that it has been there since the 1960s, which is prior to the enactment of the Lake Protection Act (“LPA”) in 1974. The parties refer to this structure as the “pre-LPA log crib.” In 2020, Wilson filed an application (the “1081B application”) with IDL for a non- navigational “riprap” encroachment permit. The encroachment “was comprised of a pre-existing log crib structure situated in the lakebed,” along with cobblestones and sandbags that Wilson added on top of the structure. This was done to facilitate the accumulation of sand on his property and create a beach along the shoreline. Wilson’s neighbor to the south, William Faloon (“Faloon”), filed an objection to the 1081B application. Faloon complained that the encroachment, which was near their common boundary line, caused erosion on Faloon’s property. The record on appeal includes several photographs showing the structure and this erosion, which was alleged to provide Wilson’s property with several additional feet of beachfront at Faloon’s expense. IDL denied Wilson’s application pursuant to IDAPA 20.03.04.030.02 (2020). The Preliminary Order concluded that Wilson had “enhanced the pre-existing encroachment, in part, by adding rocks on top of the crib and the lakebed, resulting in the existing jetty.” Furthermore, it found that there was “no evidence in the record that the proposed nonnavigational encroachment

2 All references to Idaho Code section 58-1312 in this opinion are to the version that was enacted in 2006, which was in effect at all times relevant to this proceeding until it was amended during the 2024 legislative session.

2 would involve major environmental, economic, or social benefit to the general public”; therefore, the proposed encroachment did not satisfy IDAPA 20.03.04.030.02. Despite denying his 1081B application, IDL encouraged Wilson to submit a permit application for the underlying pre-existing log crib pursuant to Idaho Code section 58-1312. On June 15, 2021, Wilson filed a second application (the “1081C application”), seeking an existing encroachment permit pursuant to Idaho Code section 58-1312. It is this application that gives rise to this litigation. Idaho Code section 58-1312 authorizes permits for existing encroachments that were “constructed prior to January 1, 1975” if the applicant provides “the board with substantive documentation of the age of the encroachment and documentation that the encroachment has not been modified since 1974.” I.C. § 58-1312(1). In support of his permit application, Wilson submitted two supplemental letters, both of which indicated that the log crib structure had been embedded in the lakebed prior to 1974. On July 8, 2022, IDL sent Wilson a letter denying his 1081C application because it found that he had not satisfied the two key requirements of Idaho Code section 58-1312: “[1] substantive documentation of the age of the encroachment and [2] documentation that the encroachment has not been modified since 1974.” The letter informed Wilson that if he were dissatisfied with IDL’s determination, he could appeal, in which case a hearing officer would be appointed and a hearing scheduled. Otherwise, Wilson was ordered to “remove the portions of the log structure that are below the [ordinary high-water mark]” within 30 days of receipt of the letter. Wilson appealed. After a public hearing on the matter, the hearing coordinator issued a Preliminary Order. The Preliminary Order denied Wilson’s 1081C application, concluding that Wilson had not satisfied either of the requirements of Idaho Code section 58-1312. The Preliminary Order found that the letters submitted to support the date of the encroachment did not satisfy section 58-1312’s requirement of “substantive documentation” establishing the age of the encroachment. Similarly, the Preliminary Order found that the application did not establish that the encroachment has not been modified since 1974; in fact, there was ample evidence in the record to support its finding that the log crib structure had been modified since 1974. Thereafter, IDL Director Miller issued a Final Order denying Wilson’s 1081C application. Unlike the Preliminary Order, the Final Order determined that Wilson had provided substantive documentation that the log crib encroachment existed prior to 1974, thereby satisfying the first requirement of section 58-1312. However, the Final Order agreed with the hearing coordinator’s

3 Preliminary Order, which concluded that Wilson had failed to demonstrate that the encroachment had not been modified since 1974. IDL noted that Wilson had “state[d] in his own words that he removed stones and pieces of concrete that were around the pre-existing log crib.” Thus, the Final Order denied Wilson’s 1081C application and ordered Wilson to “remove the portion of the logs below [2,437.64 feet] prior to June 1, 2023.” This portion of the Final Order is referred to as the abatement order. On February 15, 2023, Wilson filed a Petition for Judicial Review of IDL’s Final Order in district court. Wilson argued that IDL’s failure to comply with the procedure set forth in Idaho Code section 58-1306(b) violated his Fourteenth Amendment due process rights.

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Wilson v. Idaho State Board of Land Commissioners, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wilson-v-idaho-state-board-of-land-commissioners-idaho-2025.