Insight The Well-Reasoned Decision: Lessons from the Interfaith Sanctuary Case

In the realm of public decision-making, Idaho government entities must ensure that their decisions are well-reasoned, transparent, and legally sound. A well-reasoned decision not only demonstrates compliance with statutory requirements (I.C. § 67-6535) but also upholds public trust by clearly explaining the rationale behind a decision. The Idaho Supreme Court’s recent decision in the Veterans Park Neighborhood Association, Inc. v. City of Boise, 2025 WL 259177, *11, __ Idaho __, __ (2025) case (“Interfaith Sanctuary Case”) underscores the importance of drafting a well-reasoned decision and provides guidance on the framework and structure of a well-reasoned decision. All interested parties to a land use decision, including government entities, applicants, and affected persons, should know and understand the requirements of a well-reasoned decision in order to best advance their respective positions.

Interfaith Sanctuary Case Procedure

On April 27, 2021, Interfaith Sanctuary Housing Services, Inc. (“IFS”) submitted a controversial conditional use permit application (“CUP”) to Boise’s Planning and Development Services. The CUP requested approval to operate a large congregate shelter home in northwest Boise. A neighborhood association near the proposed location, the Veteran’s Park Neighborhood Association, Inc. (“VPNA”), actively opposed the CUP. Following multiple public hearings, the Planning and Zoning Commission (“PZC”) denied the application, finding that the proposed use did not meet the approval criteria contained in the Boise City Code. IFS appealed the denial to the Boise City Council. After additional public hearings, the Boise City Council reversed the decision of the PZC and approved the CUP. VPNA filed a petition for judicial review, and the district court affirmed the Council’s decision to approve the CUP. VPNA then appealed to the Idaho Supreme Court.

On appeal, the Idaho Supreme Court reversed the Council’s approval of the CUP, finding that: (i) the Council’s decision to grant the CUP was arbitrary and capricious and based on unlawful procedure; (ii) the Council’s reasoned statement was inadequate under Idaho’s Local Land Use Planning Act (“LLUPA”); and (iii) VPNA suffered prejudice to its substantial rights.

This article focuses on the Court’s finding that the Council’s reasoned decision was inadequate under LLUPA and provides guidance on the criteria for complying with LLUPA’s statutory requirement of a well-reasoned decision.

The Framework of a Well-Reasoned Decision

[S]hall be in writing and accompanied by a reasoned statement that explains the criteria and standards considered relevant, states the relevant contested facts relied upon, and explains the rationale for the decision based on the applicable provisions of the comprehensive plan, relevant ordinance and statutory provisions, pertinent constitutional principles and factual information contained in the record.

I.C. § 67-6535(2). The Idaho Supreme Court has interpreted this statute to require a reasoned statement to:

1. Identify relevant contested facts;
2. Plainly state the resolution of the contested factual disputes;
3. Identify the evidence supporting that factual determination;
4. Explain the rationale for the legal conclusions; and
5. Identify the pertinent laws and regulations upon which the legal conclusions rest.

Veterans Park Neighborhood Association, Inc. v. City of Boise, 2025 WL 259177, *11, __ Idaho __, __ (2025) (citing Jasso v. Camas County, 151 Idaho 790, 793 (2011)).

Applying this framework, a land use decision is inadequate if the decision only contains conclusory statements, fails to resolve factual disputes, or fails to explain how the application complies with relevant criteria identified in the local ordinance. Importantly, under Idaho Code § 67-6535, a decision’s failure to comply with the well-reasoned framework constitutes grounds for invalidation of the decision on appeal.

Boise City Council’s Decision

In the Interfaith Sanctuary Case, the Idaho Supreme Court found that Boise City Council’s decision failed to meet the well-reasoned decision criteria. Id. at *11-15. Notably, the Council’s decision was only one and one-half pages and only contained five conclusory paragraphs explaining the Council’s decision. Id. at *11. The Court discussed in detail three of the five paragraphs and provided an explanation for why those paragraphs failed to meet the relevant criteria. Id. at *12-15.

In one of the five paragraphs, the Council analyzed one of the criteria necessary to approve a CUP—whether the proposed use would “adversely impact” other properties. The Council found that the shelter would meet this criteria. Specifically, the Council stated:

Conditions of approval will ensure that the shelter does not adversely impact other property in the vicinity. This includes requirements associated with the operation of the facility, limits on occupancy, property maintenance and upkeep, design elements, and improvements to the site and the adjacent right-of-way. In many ways, the conditions restrict the intensity of the use and integrate it more predictably with the neighborhood and with public facilities so that externalities can be minimized, such as potential nuisances on the site and calls for service from public safety agencies. Ongoing compliance with these conditions of approval will be subject to review at six months after occupancy, and on an annual basis moving forward.

Id. at *12. In reviewing this paragraph, the Court noted that there was “intense dispute over the anticipated impacts of the proposed use.” Id. However, the Council’s paragraph on adverse impacts failed to identify the relevant contested facts related to that dispute. For example, what facts did VPNA rely on to claim potential adverse impacts? What facts did IFS rely on to claim no adverse impacts? What facts did government agencies provide that are relevant to potential adverse impacts? This paragraph is simply devoid of any facts in the record relating to the decision criteria of whether or not the shelter would adversely impact other properties. And, since the paragraph does not identify the contested facts, it likewise fails to articulate how those contested facts were resolved by the Council, and which facts the Council relied on to reach that resolution.

Further, the Council’s paragraph did not explain the rationale for its legal conclusion. Id. Although the Council stated that conditions of approval would ensure that no adverse impacts exist, the Council did not explain how the conditions of approval would do so. The Council vaguely identified some conditions of approval, such as limits on occupancy, and conditions for property maintenance and upkeep, but the Council did not explain how those conditions would mitigate adverse impacts. Id. The rationale is missing.

For these reasons, the Court found that the Council’s decision did not “wrestle with any of the controversy and instead summarily concludes that its new conditions will resolve any problems,” and contained “conclusions without sufficient explanation,” and “does not adequately endeavor to resolve the intense dispute.” Id.

The Court found similar problems with two other paragraphs contained in the decision. Id. at *13-15. The paragraphs did not identify the contested facts, did not identify the facts relied upon by the Council, did not explain how the Council resolved the disputes, and did not provide a rationale for the legal conclusions. In short, the paragraphs were conclusory and did not adequately explain the factual findings and legal conclusions. Id. at *15.

As a result, the Court determinded that Council’s decision did not meet the well-reasoned decision framework, and therefore, the Court invalidated the Council’s decision.

Lessons from Interfaith Sanctuary

Applicants and affected persons can learn from the Interfaith Sanctuary Case in order to avoid the pitfalls of a decision lacking reason. The following tips can help to avoid an invalidated decision:

1. Engage in Due Diligence and Comprehensive Research

As an applicant or affected person, it is important to understand the legal criteria that will guide the government entity’s final decision. Applicants should consult the applicable zoning ordinance to identify the standards and criteria for approval of the land use application. Once those standards are identified, the applicant should identify the evidence it will need to support its application. If a governing standard requires no adverse impacts to neighboring properties, then the applicant will need to ensure that is provides evidence in the record showing that the proposed use will not cause a nuisance to neighboring properties, will not create pollution, excessive noise, traffic dangers, or fire risks to neighboring properties, and will not reduce neighboring property values. Conversely, affected persons opposing the application will likewise need to understand the evidence needed in the record to support their opposition.

To ensure sufficient evidence is included in the record, the applicant should consult with experts and legal counsel early to determine whether any reports, studies, permits, or impact assessments are necessary to place supporting evidence in the record. Even if a specific report is not required in the application, the report could be helpful to resolve a potential factual dispute.

If an applicant is unaware of potential factual disputes, the applicant can consider holding a neighborhood meeting (sometimes required by local ordinance) or simply engaging in transparent communications with neighbors in the community. Often, these meetings and communications will inform the applicant of the factual disputes and challenges to the application, and will provide guidance on the type of evidence needed to mitigation such concerns.

An applicant should also contact relevant government agencies prior to submitting the application to determine if the agency has any initial concerns with the proposed use. For example, the applicant can contact the relevant highway district, fire district, police department, school district, or health district. These agencies may identify concerns or propose conditions that the applicant can address in the application.

2. Identify factual disputes and provide evidence to support your position

A well-reasoned decision must identify contested facts, resolve those factual disputes, and identify the evidence supporting the resolution of the factual dispute.

As an applicant or affected person, it is critical to provide the government entity with evidence to support factual disputes. For example, if a land use application is opposed on the grounds that it would increase fire risks, the applicant should provide evidence of its fire protection plan, whether it will install fire breaks, whether it will use Firewise or similar materials, whether it has a source of water, and whether it can comply with any recommendations from the applicable fire agency. This evidence can be presented in the application, a rebuttal report (if allowed), or during the public hearing. It is critical for the applicant to ensure that the record contains all evidence to support a proper resolution of a factual dispute. In some instances, the factual dispute might not be raised until the public hearing, when it is often too late to submit additional documentary evidence. In such case, it may be beneficial to request a continuance in order to submit rebuttal documentation that will allow the government entity to resolve the factual dispute. Although delays are not favored, it may end up being more efficient if the alternative is a potential invalidation of the decision by the court.

Based on the facts and evidence in the record, the government entity should then draft a decision identifying this factual dispute, identifying how the government entity is resolving the dispute, and the evidence to support the resolution. If the record is inadequate to resolve the factual dispute, the government entity may continue the public hearing and provide guidance to the applicant and affected persons on what evidence is requested in order to attempt to resolve the dispute. For example, if no fire protection plan is submitted, the government entity could, in its discretion, continue the hearing to allow submission of the plan. This is not always required, but could be recommended in order to ensure that the record contains sufficient evidence to support resolution of a factual dispute.

3. Explain the rationale for legal conclusions.

The final decision cannot rely on conclusory statements, but must articulate why the government entity reached its particular conclusion. Applicants and affected persons should take action to assist the government entity in drafting a non-conclusory decision. In doing so, it is important to consult with legal counsel early. Legal counsel can assist in drafting a narrative to the government entity designed to provide a roadmap for a potential decision. If may be helpful to draft the narrative in a way that will essentially serve as a first draft of the government entity’s well-reasoned decision. In other words, the narrative should be transparent on the factual disputes, identify the facts that can be relied on to resolve those disputes, and explain the rationale for concluding why each standard and criteria in the zoning ordinance has been satisfied by the applicant (or will be satisfied with conditions of approval imposed).

Affected persons opposed to an application likewise can draft a public comment illuminating factual disputes, identifying facts the government should rely on to resolve disputes, and explaining the rationale for concluding why the application does not meet the standards and criteria in the zoning ordinance.

In both instances, the narrative or public comment should be structured logically by identifying the relevant legal standards, articulating the factual disputes, identifying the key facts that resolve the dispute, and explaining why those facts support a legal conclusion that the standards have or have not been satisfied. Further, the document should clearly cite to evidence in the record, such as reports, studies, or photographs, which the government entity can refer to in drafting its final decision. A good narrative or public comment is one that the government entity can copy and paste into its final decision.

Checklist To Help Achieve a Well-Reasoned Decision

The government entity drafts and approves the final decision on land use applications. However, applicants and affected persons can take steps to assist the government entity in creating a well-reasoned decision. The following checklist may be used to encourage a government entity to draft a well-reasoned decision:

1. Research the standards and criteria in the local zoning ordinance applicable to your application.
2. Meet with neighboring property owners and obtain feedback on your proposed use.
3. Meet with government agencies and obtain feedback on your proposed use.
4. Gather evidence that will support a finding that your application meets the criteria set for in the zoning ordinance.
5. Submit a thorough and well-organized application.
   1. Include detailed site plans, impact assessments, studies, reports, and other documents as necessary to satisfy the applicable standards and criteria.
   2. Address potential factual disputes and concerns and provide evidence to support your position.
   3. Draft a narrative that is transparent on the factual disputes, identifies the facts that can be relied on to resolve those disputes, and explains the rationale for concluding why each standard and criteria in the zoning ordinance has been satisfied by the application.
6. Present a convincing argument during the public hearing
   1. Provide a compelling overview of the application
   2. Identify factual disputes and explain why the government entity should resolve those facts in your favor.
   3. Point to evidence in the record that supports your position.
   4. Explain how the application satisfies the criteria set forth in the zoning ordinance.

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