White v. ITD

Summary

The Idaho Supreme Court held that the common-law necessity defense is unavailable in an administrative license-suspension proceeding because the governing statute identifies the exclusive grounds for vacating a suspension and does not include necessity. The court also held that excluding the defense did not violate White's Sixth Amendment or procedural due-process rights because the proceeding was civil, White received multiple opportunities to be heard, and the government's interest in promptly removing intoxicated drivers outweighed his private interest. The court affirmed the suspension, denied ITD attorney fees because the issue was one of first impression, and awarded ITD appellate costs.