Omaechevarria v. Idaho
246 U.S. 343 (1918)

  • 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.