Guardians of minor student, in their individual capacities, as guardians of student, and as class representatives, brought proposed class action against school district for inverse condemnation under state constitution and violation of Fifth Amendment’s Takings Clause, under § 1983, alleging fees charged for second half of full-day kindergarten violated Idaho Constitution’s free common schools provision and constituted a taking without due process.
The Fourth Judicial District Court granted district’s motion to dismiss. Guardians appealed.
The Supreme Court held that:
- Student did not suffer particularized injury-in-fact necessary to have standing, and
- Statute providing that time for the commencement of the action would exclude period while plaintiff was still a minor did not apply to toll limitations period.
Minor student did not suffer a deprivation of property due to tuition charged for second half of full-day kindergarten, and thus did not suffer particularized injury-in-fact necessary to have standing to bring proposed class action against school district for violation of Takings Clause, under § 1983, alleging tuition violated Idaho Constitution’s free common schools provision and constituted a taking without due process, where tuition payments were made solely by minor’s guardians, using their funds and not any property belonging to minor.
Statute, providing that time for the commencement of the action would exclude the period during which plaintiff was still a minor, did not apply to toll limitations period for proposed class action brought by guardians of minor student against school district for violation of Takings Clause, under § 1983, alleging tuition charged for second half of full-day kindergarten violated Idaho Constitution’s free common schools provision and constituted a taking without due process, where it was guardians, not student, who had standing to bring the takings claim.