Because they were worried
about overgrazing, Idaho enacted a law (§6872) that prohibited sheep from grazing on
Federally-owned lands previously used by cattle.
Omaechevarria was a sheep
farmer and let his sheep graze on cattle land. He was fined. He
appealed.
Omaechevarria argued that
the law was a violation of the Equal Protection Clause of the 14th Amendment
because it put him at a disadvantage compared to the cattle ranchers.
Omaechevarria also argued
that it was a violation of the Due Process Clause of the 14th Amendment,
because the law was vague about what was considered a 'range' and didn't
define what it meant by 'previously used'.
The Idaho Supreme Court
affirmed. Omaechevarria appealed.
The US Supreme Court affirmed.
The US Supreme Court found
that the police power of the State extends over Federal lands in the
State (where there is no legislation by Congress on point).
The Court found that the law
didn't violate the Equal Protection Clause or the Due Process Clause because there was a rational basis for the Idaho law.
The rational basis was that it kept the peace between cattle
ranchers and sheepherders, and prevented overgrazing.
Since there was no fundamental
right or suspect class at issue, in order to be constitutional,
there only needs to be a rational basis for the law.
The Court found that the law
wasn't so vague as to be a violation of due process.
