WAYNE MORRISON, TODD MORRISON, BRYANT MORRISON, and LYN DEESUE MORRISON v. CHRISTINA K. THOMPSON, as Trustee of the Petra E. Morrison Trust, and as Trustee of the Frank L. Morrison Trust, CHARLES THOMPSON and CHRISTINA THOMPSON, Husband and Wife, Individually; CRAIG THOMPSON, CAROLYN HASTINGS, and CARL THOMPSON
CourtIdaho Supreme Court
Date FiledJune 30, 2026
Docket52401
StatusPublished
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Full Opinion
IN THE SUPREME COURT OF THE STATE OF IDAHO
Docket No. 52401-2024
WAYNE MORRISON, )
)
Plaintiff-Counterdefendant- ) Boise, April 2026 Term
Appellant, )
) Opinion filed: June 30, 2026
and )
) Melanie Gagnepain, Clerk
TODD MORRISON, BRYANT MORRISON, )
and LYN DEESUE MORRISON, )
)
Plaintiffs-Appellants, )
)
v. )
)
CHRISTINA K. THOMPSON, as Trustee of )
the Petra E. Morrison Trust, and as Trustee )
of the Frank L. Morrison Trust, )
)
Defendant-Counterclaimant- )
Respondent, )
)
and )
)
CHARLES THOMPSON and CHRISTINA )
THOMPSON, husband and wife, )
individually; CRAIG THOMPSON, )
CAROLYN HASTINGS, and CARL )
THOMPSON, )
)
Defendants-Respondents, )
)
and )
)
DOES INDIVIDUALS/ENTITIES 1-10, )
)
Defendants. )
_____________________________ )
IN THE MATTER OF THE PETRA )
MORRISON TRUST, uta May 14, 2007, and )
as AMENDED September 16, 2016; )
CHRISTINA K. THOMPSON, Successor )
Trustee, )
1
)
Petitioner. )
_____________________________ )
IN THE MATTER OF THE FRANK )
MORRISON TRUST, uta February 13, 1986, )
CHRISTINA K. THOMPSON, Co-Trustee, )
)
Petitioner. )
)
Appeal from the District Court of the Fifth Judicial District of the State of Idaho,
Blaine County. Jonathan P. Brody, District Judge.
The decision of the district court is affirmed.
Elam & Burke, P.A., Boise, for Appellants. Kirsten Hahn argued.
Haemmerle Law, PLLC, Hailey, for Respondents Christina K. Thompson as
Successor Trustee of the Petra Morrison Trust and the Co-Trustee of the Frank
Morrison Trust; and Carolyn Hastings as Co-Trustee of the Frank Morrison Trust.
Fritz Haemmerle argued.
Stanek Law, PLLC, Hailey, for Respondents Christina Thompson, Charles
Thompson, Craig Thompson, Carolyn Hastings, and Carl Thompson. Joshua
Stanek argued.
ZAHN, Justice.
Wayne Morrison and his children (“the Morrisons”) appeal from several district court
orders concerning the administration and distribution of two trusts established by Wayne’s parents:
the Frank Morrison Trust (“FMT”) and the Petra Morrison Trust (“PMT”). Wayne’s sister,
Christina K. Thompson, is a trustee of both trusts. Christina’s daughter, Carolyn, is a co-trustee of
the FMT. The primary asset of each trust is a fractional ownership interest in a piece of real
property known as the Farnlun property.
Wayne filed a complaint against Christina in her individual and trustee capacities, asserting
a variety of claims against Christina that concerned her alleged breaches of the trust and of
fiduciary duty, and seeking an accounting. Wayne later amended the complaint twice to add
Christina’s husband and his and Christina’s children as parties, to assert a variety of claims
concerning Christina’s alleged fraud, and to seek partition of the Farnlun property by sale.
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Christina commenced her own petitions in the district court, in her capacity as trustee,
seeking to distribute the FMT and the PMT in-kind, which would allow the Farnlun property to
remain in the family. The Morrisons opposed the petitions, requested that the Farnlun property be
sold, and that the sale proceeds be distributed according to their respective interests in each trust.
The parties stipulated to consolidate the Morrisons’ and Christina’s cases before the district court.
The Morrisons filed a motion to remove Christina and Carolyn as trustees, which the
district court denied. Christina and her family (“the Thompsons”) filed several motions for
summary judgment. The district court granted the Thompsons’ motions and (1) dismissed the
partition action; (2) determined that Wayne had violated a “no-contest” clause in the PMT and
therefore was not entitled to any share of that trust; and (3) granted the petitions for distribution in
kind, determined the value of the Farnlun property, awarded Christina the entirety of the PMT and
determined the beneficiaries’ interests in the FMT. The Thompsons later filed a motion for attorney
fees under Idaho Code sections 15-8-208 and 12-121. The district court granted the motion and
assessed the attorney fee award against the Morrisons’ share of the FMT.
The Morrisons appeal and argue that the district court erred in five respects. First, they
argue that the district court erred by denying their petition to remove the trustees because there is
evidence that the trustees breached their fiduciary duties in the administration of the trusts. Second,
they argue the district court incorrectly concluded that they lacked standing to seek partition of the
Farnlun property. Third, they assert that the district court erred in its application of the no-contest
clause to disinherit Wayne from the PMT. Fourth, they claim the district court erred in its valuation
of the Farnlun property and erroneously calculated the beneficiaries’ interests in the Farnlun
property. Finally, they challenge the award of attorney fees. For the reasons discussed below, we
affirm.
I. FACTUAL AND PROCEDURAL BACKGROUND
Frank and Petra Morrison were married and had two children, Christina Thompson and
Wayne Morrison. This appeal concerns the administration and distribution of their respective
trusts.
A. The Frank Morrison Trust
Frank died in 1994. His will established the FMT. The trust corpus consisted of Frank’s
50% interest in a piece of real property known as the Farnlun property and funds in an Edward
Jones account. The FMT designated Christina as a co-trustee. During the time period relevant to
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this appeal, Christina’s daughter, Carolyn Hastings, was the other co-trustee. The FMT authorized
the trustees to use trust funds to care for Petra for the remainder of her life, and directed that, after
Petra’s death, the remainder of the FMT be distributed as follows: 25% to Christina; 25% to
Christina’s children; 25% to Wayne’s children; and 25% to remain in trust for Wayne’s benefit.
The FMT further stated that Frank made advances of money to Wayne during Frank’s life and
directed that those advances were “to be included in determining the shares to be distributed and
credited against the share to be received by” Wayne.
B. The Petra Morrison Trust
Petra created the PMT in 2007. At that time, the trust corpus consisted of Petra’s 50%
interest in the Farnlun property. After Petra created the PMT, she conveyed 16.35% of her interest
in the Farnlun property to Christina. As such, at the time of Petra’s death, the corpus of the PMT
was Petra’s remaining 33.65% interest in the Farnlun property.
Petra was the trustee of the PMT until her death in 2021. After Petra’s death, Christina
became the successor trustee of the PMT. The PMT provides that, after Petra’s death, trust funds
can be used to pay “all of Grantor’s or Trustee’s expenses of last illness, burial and debts . . . .”
After those expenses are paid, the PMT indicates that the “remaining trust principal and accrued
interest shall be distributed equally” between Wayne and Christina. The PMT also included a “no-
contest” clause, which provided that all distributions were conditioned upon the beneficiary neither
opposing any distributions, nor testing the validity of the trust agreement in any manner. In the
event a beneficiary opposed any distributions or tested the validity of the agreement, Petra revoked
all distributions to that beneficiary, and the beneficiary was to be treated as if the person had
predeceased Petra.
C. The Current Dispute
Shortly after Petra’s death, Christina sent an email to Wayne proposing to buy his portion
of the Farnlun property. Wayne’s attorney responded to Christina’s email and requested
documentation and an accounting of the value of the trust before responding to Christina’s offer.
Wayne asserts he never received the requested information and that Christina’s offer was for less
than the property’s fair market value. Wayne later filed a complaint against Christina in her
individual and trustee capacities and pleaded claims for declaratory judgment, breach of trust,
breach of fiduciary duty, and sought an accounting.
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Around the same time that Wayne filed his complaint, Christina, in her role as trustee of
the FMT and PMT, executed a quitclaim deed conveying the Farnlun property to herself and her
husband. Christina claimed she signed the deed because she believed it was required in connection
with a loan she obtained to make repairs on the Farnlun property. When Wayne learned of the
deed, he amended his complaint to include Christina’s husband as a defendant and to add claims
for unjust enrichment, constructive trust, conspiracy, fraudulent transfer of property, and
conversion. Christina and her husband conveyed the Farnlun property back to the trusts nearly a
year later.
Christina, as trustee of the FMT and PMT, filed petitions to distribute the trusts in-kind.
Christina amended the petitions for distribution several times to update the proposed distributions.
The parties stipulated to consolidate the petitions with Wayne’s lawsuit and the district court
entered an order consolidating the actions.
Chrisina filed an amended answer and counterclaim to Wayne’s amended complaint. In it,
she alleged that Wayne violated the no-contest clause in the PMT and should be removed as a
beneficiary of that trust.
Wayne later amended his complaint a second time to include his three children as plaintiffs
and Christina’s three children as defendants and to add a claim for partition by sale of the Farnlun
property. The Thompsons filed a motion for summary judgment to dismiss the Morrisons’ Second
Amended Complaint. The Morrisons filed a petition to remove Christina and Carolyn as trustees,
pursuant to Idaho Code section 15-7-308.
The district court denied the Morrisons’ petition to remove the trustees. It also granted the
Thompsons’ motion for summary judgment and dismissed all but the Morrisons’ claim for
declaratory judgment, which sought a declaration of their rights and legal obligations under the
trusts. The Thompsons then filed (1) a motion for summary judgment on their third amended
petition to distribute the FMT and (2) a motion for summary judgment on their counterclaim to
have Wayne removed as a beneficiary of the PMT because he breached its no-contest clause. The
district court granted both motions and entered a judgment distributing in kind the assets of the
FMT and PMT.
The Thompsons filed a motion for an award of attorney fees under Idaho Code sections
15-8-208 and 12-121. They asserted that the Morrisons’ claims were brought and defended
frivolously and without foundation because the claims lacked evidence and ignored the plain
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language of the trusts. The Thompsons also requested that the attorney fees be awarded against the
Morrisons’ shares of the FMT, pursuant to Idaho Code section 15-8-208. The district court granted
the Thompsons’ motion and awarded $100,869.67 in attorney fees against the Morrisons and stated
the award would be assessed against their shares of the FMT.
The Morrisons timely appealed.
II. ISSUES ON APPEAL
1. Whether the district court erred by denying the Morrisons’ motion to remove the trustees.
2. Whether the district court erred by dismissing the Morrisons’ claim for partition.
3. Whether the district court erred in its decision disinheriting Wayne from the PMT for
violating its no-contest clause and distributing the assets of the PMT to Christina.
4. Whether the district court erred in its distribution of the FMT.
5. Whether the district court erred in granting the Thompsons attorney fees under Idaho Code
section 12-121 and assessing the attorney fee award against the Morrisons’ share of the
FMT.
6. Whether the Thompsons are entitled to attorney fees on appeal.
III. STANDARDS OF REVIEW
When reviewing a decision on a petition to remove a trustee, this Court applies an abuse
of discretion standard. Edwards v. Lane, ___ Idaho ___, ___, 578 P.3d 525, 529 (2025).
When reviewing a district court’s summary judgment decision, this Court applies the same
standard used by the district court. DeKlotz v. NS Supp., LLC, ___ Idaho ___, ___, 574 P.3d 328,
331 (2025). “Summary judgment is proper if ‘the movant shows that there is no genuine dispute
as to any material fact and the movant is entitled to judgment as a matter of law.’ ” Owen v. Smith,
168 Idaho 633, 640, 485 P.3d 129, 136 (2021) (quoting I.R.C.P. 56(a)). On a motion for summary
judgment, the court must “liberally construe the facts, and draw all reasonable inferences in favor
of the nonmoving party.” Fragnella v. Petrovich, 153 Idaho 266, 271, 281 P.3d 103, 108 (2012).
We review an award of attorney fees under an abuse of discretion standard. Gilbert v.
Radnovich, 171 Idaho 566, 572, 524 P.3d 397, 403 (2023).
IV. ANALYSIS
A. The district court did not err by denying the Morrisons’ petition to remove the trustees.
The Morrisons petitioned the district court to remove Christina and Carolyn as trustees and
appoint TreSCo of Idaho as trustee of the FMT and the PMT. The Morrisons claimed that the
trustees breached their fiduciary duties, failed to provide accurate accountings, engaged in self-
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dealing, conspired to increase their families’ shares in the trust, and fraudulently transferred the
Farnlun property. Following a hearing, the district court denied the petition to remove.
The Morrisons argue that the district court erred by denying the petition because its
findings of fact were not supported by substantial and competent evidence, and it misapplied Idaho
Code section 15-7-308. The Thompsons argue that the Morrisons failed to articulate the proper
standard of review and that the arguments raised in the petition to remove are moot.
1. The applicable standard of review is abuse of discretion and the Morrisons have done
enough to support their argument and allow their appeal to proceed.
The Morrisons assert that the district court’s denial of their petition to remove should be
reversed due to clear error in the district court’s factual findings. The Thompsons contend that the
district court’s decision on the petition should be reviewed under an abuse of discretion standard.
They claim that the Morrisons’ appeal on this issue is “fatally deficient” because they failed to cite
or apply the abuse of discretion standard. While we agree that the district court’s decision is
reviewed for an abuse of discretion, we conclude that the Morrisons sufficiently supported their
challenge on appeal.
After the parties submitted their briefing on this issue, we issued our opinion in Edwards
v. Lane, holding that a decision on a petition to remove a trustee is reviewed for an abuse of
discretion. ___ Idaho ___, ___, 578 P.3d 525, 529 (2025). When reviewing a district court decision
for an abuse of discretion, this Court considers whether the district court “(1) correctly perceived
the issue as one of discretion; (2) acted within the outer boundaries of its discretion; (3) acted
consistently with the legal standards applicable to the specific choices available to it; and (4)
reached its decision by the exercise of reason.” Lunneborg v. My Fun Life, 163 Idaho 856, 863,
421 P.3d 187, 194 (2018). “[T]his Court does not impose a ‘formalistic requirement that the
standard of review be recited and the party claiming error attack a particular prong of that standard
of review.’ ” Midtown Ventures, LLC v. Capone, 173 Idaho 172, 180, 539 P.3d 992, 1000 (2023)
(quoting State v. Diaz, 170 Idaho 79, 92, 507 P.3d 1109, 1122 (2022)).
While the Morrisons did not recite the abuse of discretion standard in connection with their
arguments that the district court erred in denying their motion to remove the trustees, they argued
that the district court’s factual findings were clearly erroneous and therefore it did not correctly
apply the legal standards applicable to their motion. We have stated that a district court abuses its
discretion when its findings of fact are clearly erroneous. See Hayes v. Medioli (In Re Doe), 168
Idaho 511, 515–16, 484 P.3d 195, 199–200 (2021). Because making clearly erroneous findings of
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fact and acting inconsistently with the appropriate legal standards would each establish an abuse
of discretion, we hold that the Morrisons have done enough to preserve their argument on this
issue.
2. The issues raised in the petition to remove are not moot.
The Thompsons maintain that the arguments in the petition to remove are moot because
the district court denied the same arguments in its decision granting the Thompsons’ motion for
summary judgment on the Second Amended Complaint. The Thompsons further argue that, even
if Christina were removed as trustee, Carolyn Hastings would remain a trustee of the FMT, and
Carl Thompson, Christina’s son, would be the successor trustee of the PMT. As a result, the
Morrisons’ requested replacement trustee would not be appointed and the granting of the petition
to remove would not change the outcome of the case.
“A case becomes moot when the issues presented are no longer live or the parties lack a
legally cognizable interest in the outcome.” Smith v. Smith, 160 Idaho 778, 784, 379 P.3d 1048,
1054 (2016) (quoting Farrell v. Whiteman, 146 Idaho 604, 610, 200 P.3d 1153, 1159 (2009)). The
mere fact that there is overlap between the Morrisons’ arguments to remove the trustees and the
allegations made in their Second Amended Complaint does not moot the arguments they raised in
their petition to remove. The remedy sought in the two pleadings is distinct and the Morrisons had
a legally cognizable interest in replacing the trustees. Further, we disagree with the Thompsons’
assertion that, if the motion had been granted, Carolyn and Carl would have been the successor
trustees to Christina.
It is true that the Morrisons’ petition to remove relied on similar allegations to those made
in their Second Amended Complaint. Their petition claimed the trustees should be removed for
breach of trust and breach of fiduciary duty, failure to provide accurate accountings, self-dealing
and unjust enrichment, conspiracy to increase their shares in the trust, and fraud. The Morrisons’
Second Amended Complaint raised issues including breach of trust and fiduciary duty,
accountings, unjust enrichment, conspiracy, and fraudulent transfer. However, seeking removal of
the trustees for misconduct is a different and distinct remedy than seeking to deny the petitions for
distribution and force the sale of the Farnlun property. If the district court had removed Christina
and Carolyn as trustees, a successor trustee may have taken different actions to resolve the claims,
including not seeking to distribute the assets in kind, not seeking to invoke the no-contest clause
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of the PMT, or conducting a new valuation of the Farnlun property. As such, the Morrisons
possessed a legally cognizable interest in the outcome of the petition to remove.
We also disagree with the Thompsons’ suggestion that, if Christina were removed, Carolyn
and Carl would succeed her. This argument ignores the fact that the Morrisons also sought to
remove Carolyn as co-trustee of the FMT. If their petition was successful, Carolyn would not
succeed Christina because Carolyn would also be removed.
The Thompsons’ argument regarding Carl requires us to interpret the relevant provision of
the PMT. The PMT provides that, “[i]n the event the Trustee shall for any reason resign or cease
to act, CHRISTINA K. THOMPSON shall be successor Trustee of any Trust established herein.
In the event CHRISTINA K. THOMPSON for any reason fails to act, CARL W. THOMPSON
shall be alternate successor Trustee.” (Capitalization in original; emphasis added.) While the
Thompsons have interpreted this to mean that Carl would automatically succeed Christina if she
were removed, the Morrisons disagree. They argue that the provision only means that Carl will
succeed Christina if she declines to act as trustee.
We agree with the Morrisons on this point. When interpreting a trust, our objective is to
discover the grantor’s intent by viewing the document as a whole. See Salfeety v. Seideman (In re
Est. of Kirk), 127 Idaho 817, 827, 907 P.2d 794, 804 (1995). The PMT provides that Christina will
become the successor trustee when Petra “resign[s] or cease[s] to act.” (Emphasis added.) On the
other hand, Carl only becomes the successor trustee if Christina “fails to act.” (Emphasis added.)
The use of “fail” rather than “cease,” indicates that different circumstances govern whether
Christina and Carl will be designated as trustees. To “cease” means to stop something that one is
already doing. See Cease, Merriam-Webster Dictionary, https://www.merriam-
webster.com/dictionary/cease (last visited Jun. 26, 2026) (“[T]o come to an end[.]”). On the other
hand, “fail” means to not act at all. See Fail, Merriam-Webster Dictionary, https://www.merriam-
webster.com/dictionary/fail (last visited Jun. 26, 2026) (“[T]o leave undone[.]”).
Given the different words used in the PMT concerning Christina and Carl, the plain
language of the PMT provides that Carl would become the successor trustee only if Christina never
acted as trustee. Because Christina did act as trustee, Carl would not assume the role of trustee if
Christina was removed. As a consequence, the Morrisons have a live interest in removing Christina
so they can propose a new trustee. For these reasons, their arguments related to the district court’s
denial of the petition to remove are not moot.
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3. The district court did not err by denying the Morrisons’ petition to remove the trustees.
The Morrisons’ petition alleged five grounds for removal: (1) breach of trust and breach of
fiduciary duty; (2) failure to provide accurate accountings; (3) self-dealing and unjust enrichment;
(4) conspiracy to increase trust shares to the detriment of the beneficiaries; and (5) fraud and
fraudulent transfer. The district court addressed these five grounds for removal and denied the
petition to remove. The Morrisons argue that the district court erred because its factual findings
were not supported by substantial and competent evidence and it misapplied the relevant law.
The removal of a trustee is addressed by Idaho Code section 15-7-308, which identifies six
grounds for removing a trustee:
(a) If the trustee has committed a material breach of trust;
(b) If the trustee is unfit or unable to administer the trust;
(c) If lack of cooperation among cotrustees substantially impairs the administration
of the trust;
(d) If the investment decisions of the trustee, although not constituting a breach of
trust, have resulted in investment performance persistently and substantially below
those of comparable trusts;
(e) If, because of changed circumstances, removal of the trustee would
substantially further the trustor’s purpose in creating the trust; or
(f) For other good cause shown.
I.C. § 15-7-308(2)(a) to (f). The Morrisons claim the district court erred in not removing the
trustees because their petition established that the trustees had committed a material breach of the
trust, and that other good cause existed to remove the trustees. See I.C. § 15-7-308(2)(a), (f).
When reviewing a district court’s factual findings, this Court does not reweigh the evidence
or analyze whether it would have reached a different conclusion. Barr v. Citicorp Credit Serv.,
Inc. USA, 161 Idaho 136, 137, 384 P.3d 383, 384 (2016). Rather, it reviews the decision to ensure
it is supported by substantial and competent evidence. Id. The record demonstrates that the district
court addressed each ground raised by the Morrisons, that its findings were supported by
substantial and competent evidence, and that it properly exercised its discretion in denying their
motion.
The Morrisons’ argument that the trustees breached the trust agreement was premised on
Christina’s failure to provide notice prior to transferring the property, emails between the
Thompson family about purchasing the Farnlun property, Petra conveying a portion of the Farnlun
10
property to Christina, and disputes over Christina’s claims for reimbursement of loans made to
Petra and for Christina’s time spent providing care to Petra.
The district court addressed each of these allegations and found that the trustees were not
required to give the beneficiaries notice when they transferred the property and that the email
conversations took place while Petra was still alive and thus before Christina became trustee of
the PMT. It additionally found that the emails exhibited a clear concern for following the law. It
also found that Petra’s conveyance of a portion of the property to Christina was solely attributable
to Petra, and that disputes over the loan and caregiving fees were factual matters related to the
beneficiaries’ respective interests in the trusts rather than a breach of the trust agreement. The
district court’s findings are supported by substantial and competent evidence in the form of the
emails between the Thompsons, the deed conveying a portion of the Farnlun property to Christina,
and the trust documents.
Finally, the Morrisons’ petition to remove alleged that good cause existed to remove the
trustees because the trustees failed to perform accurate accountings, engaged in self-dealing and
unjust enrichment by transferring the Farnlun property to Christina and her husband, conspired to
increase their shares in the trust, and committed fraud. The district court found that the Morrisons
were provided with multiple accountings. That finding is supported by declarations from the
parties’ attorneys describing the accountings the Morrisons had been provided. The district court
also found that Christina’s conveyance of the Farnlun property to herself and her husband had been
rectified. This is supported by a deed conveying the property back to the trusts. Finally, the district
court found that, based on its summary judgment decision dismissing the Morrisons’ conspiracy
and fraud claims, the Morrisons had not established that the trustees had conspired or committed
fraud.
The Morrisons claim that the district court’s decision was erroneous because it failed to
address each factual allegation made in support of their petition to remove. They argue that, when
all their factual allegations are taken together, they establish that Christina materially breached the
terms of the trust. To the extent the Morrisons ask this Court to reweigh the evidence before the
district court, we decline to do so. See Neustadt v. Colafranceschi, 167 Idaho 214, 227, 469 P.3d
1, 14 (2020) (holding that appellate courts do not reweigh evidence). However, it appears their
argument is more that the district court failed to address each and every factual allegation argued
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in support of their petition to remove. They argue that “[t]hese omissions alone render the court’s
findings clearly erroneous.”
The district court was under no obligation “to recite every piece of evidence and either
adopt it or reject it . . . .” Browning v. Ringel, 134 Idaho 6, 14, 995 P.2d 351, 359 (2000) (quoting
9 Moore’s Federal Practice § 52.15[2][b] (3d ed. 1997)).
The fact that counsel for a party sincerely contended for a position does not mean
that findings must be made on that position. A decision between the positions of
two litigants necessarily rejects contentions made by one or the other. The trial
court’s failure to discuss each party’s contentions does not make the findings
inadequate or suggest that the court failed to understand the propositions.
Id. (9 Moore’s Federal Practice, supra, at § 52.15[2][b]). Each of the district court’s findings was
supported by substantial and competent evidence. The district court’s failure to address each and
every factual contention raised by the Morrisons or to expressly weigh each piece of the Morrisons’
evidence against the Thompsons’ evidence did not eliminate the substantial and competent
evidence that supported its factual findings.
Moreover, the decision whether to grant a petition to remove a trustee is a discretionary
one. I.C. § 15-7-308(1) (“A trustee may be removed . . . .” (emphasis added)). The district court’s
findings supported its discretionary decision to deny the Morrisons’ motion to remove the trustees.
While the Morrisons essentially argue the district court should have spent more time in its written
decision grappling with the factual contentions that formed the basis for their motion, the fact that
it did not address each and every factual contention they raised does not, standing alone, establish
an abuse of discretion.
The Morrisons also argue that the district court applied the incorrect legal standard. They
argue that the district court failed to analyze their conspiracy and fraud/fraudulent transfer
allegations under section 15-7-308(2)(a) to (f). However, the district court had already concluded
in its summary judgment decision that the Morrisons failed to establish a genuine issue of material
fact to support their conspiracy and fraud claims. The Morrisons did not submit any additional
evidence in support of their petition to remove. In the absence of any additional evidence, the
district court did not err when it relied on its prior summary judgment decision to conclude that
the Morrisons had failed to establish that the trustees engaged in a conspiracy or committed fraud.
In sum, for the reasons discussed above, the district court did not err by denying the
Morrisons’ petition to remove the trustees.
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B. The district court did not err by dismissing the Morrisons’ partition claim because they
lacked standing to seek partition of the Farnlun property.
The Second Amended Complaint sought a partition by sale of the Farnlun property. The
Thompsons moved for summary judgment on the claim, arguing that the Morrisons did not have
standing to seek partition. The district court granted the Thompsons’ motion after determining that,
because the Morrisons were not cotenants, joint tenants, or tenants in common, they could not seek
partition under Idaho law.
On appeal, the Morrisons argue that, as trust beneficiaries, they have an equitable property
interest in the Farnlun property, which permits them to seek partition under Idaho Code sections
6-502 and 15-3-911. We disagree and hold that neither statute granted the Morrisons authority to
seek partition of the property.
“Issues of statutory interpretation are questions of law which this Court reviews de novo.”
Genho v. Riverdale Hot Springs, LLC, 174 Idaho 894, 901, 560 P.3d 1041, 1048 (2024) (citing
Idaho Dep’t of Health & Welfare v. Doe (2022-32) (In re Doe), 171 Idaho 677, 680, 525 P.3d 715,
718 (2023)). “Statutory interpretation begins with the literal language of the statute.” Hess v. Hess,
174 Idaho 524, 535–36, 558 P.3d 254, 265–66 (2024) (quoting Nelson v. Evans, 166 Idaho 815,
820, 464 P.3d 301, 306 (2020)). “If the statutory language is unambiguous, the clearly expressed
intent of the legislative body must be given effect, and there is no occasion for a court to consider
rules of statutory construction.” Farmers Nat’l Bank v. Green River Dairy, LLC, 155 Idaho 853,
856, 318 P.3d 622, 625 (2014) (citation modified) (quoting St. Luke’s Reg’l Med. Ctr., Ltd. v. Bd.
of Comm’rs of Ada Cnty., 146 Idaho 753, 755, 203 P.3d 683, 685 (2009)).
We begin with Idaho Code section 6-501, which discusses when a partition action “may be
had”:
When several cotenants hold and are in possession of real property as parceners,
joint tenants or tenants in common, in which one (1) or more of them have an estate
of inheritance, or for life or lives, or for years, an action may be brought by one (1)
or more of such persons for a partition thereof, according to the respective rights of
the persons interested therein, and for a sale of such property, or a part thereof, if it
appears that a partition cannot be made without great prejudice to the owners.
I.C. § 6-501 (emphasis added). The Morrisons neither held nor had possession of the Farnlun
property when they filed their partition action. As beneficiaries of the trusts, the Morrisons
certainly possessed an interest in the trust assets. Est. of Cornell v. Johnson, 159 Idaho 778, 782–
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83, 367 P.3d 173, 177–78 (2016). However, because those assets had not yet been distributed, they
did not have a possessory interest in the Farnlun property.
Our opinion in McKay v. Walker explained that a possessory interest in real property is
“[t]he present right to control property, including the right to exclude others, by a person who is
not necessarily the owner.” 160 Idaho 148, 152, 369 P.3d 926, 930 (2016) (alteration in original)
(quoting Possessory interest, Black’s Law Dictionary (9th ed. 2009)). “[A] possessory interest in
land exists where a person has: ‘(a) a physical relation to the land of a kind which gives a certain
degree of physical control over the land, and an intent so to exercise such control as to exclude
other members of society in general from any present occupation of the land . . . .’ ” Id. (last
alteration in original) (quoting Restatement (First) of Property § 7 (1936)). McKay establishes that
parties have a possessory interest in real property when they have a present right to control the
property. See id. The Morrisons failed to establish that they possessed this present right.
The extent of the Morrisons’ rights to the Farnlun property are defined by the trust
documents. Neither trust provides the Morrisons with a present right to control the Farnlun
property. Under the FMT, Wayne is entitled to 25% of the trust, to be retained in trust for his
benefit. As such, Wayne had no possessory interest in the assets of the FMT. Instead, the trustee
was directed to hold Wayne’s share of the assets for Wayne’s benefit. For Wayne’s children, the
FMT grants the trustee absolute discretion on how to distribute the property. They would not have
a present possessory interest until the trustee distributed the property in kind. Because the trust
property had not been distributed in kind, they did not have a present possessory interest in the
Farnlun property at the time they filed the partition action.
Under the PMT, Wayne had an interest in half of the remaining assets of the PMT, but it
was not a present possessory interest. The PMT granted the trustee sole authority “to partition,
allot, and distribute the Trust Estate in undivided interests or in kind, or partly in money and partly
in kind at valuations determined by the Trustee and to sell such property as the Trustee may deem
necessary to make division or distribution.” Wayne would only obtain a present possessory interest
after the trustee distributes the property to him in kind. Because the PMT had not been distributed
in kind, he did not hold a present possessory interest in the Farnlun property when the partition
claim was filed.
Nor did Idaho Code section 15-3-911 permit the Morrisons to seek partition. That section
provides:
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When two (2) or more heirs or devisees are entitled to distribution of undivided
interests in any real or personal property of the estate, the personal representative
or one (1) or more of the heirs or devisees may petition the court prior to the formal
or informal closing of the estate, to make partition.
I.C. § 15-3-911 (emphasis added). “Legislative definitions of terms included within a statute
control and dictate the meaning of those terms as used in the statute.” Mayer v. TPC Holdings,
Inc., 160 Idaho 223, 226, 370 P.3d 738, 741 (2016) (quoting State v. Yzaguirre, 144 Idaho 471,
477, 163 P.3d 1183, 1189 (2007)). The Morrisons do not meet the definitions of personal
representatives, heirs, or devisees in Title 15 of the Idaho Code.
The term “ ‘personal representative’ includes executor, administrator, successor personal
representative, special administrator, and persons who perform substantially the same function
under the law governing their status.” I.C. § 15-1-201(35). The Morrisons are not executors or
administrators of the trusts and therefore do not fall within the definition of “personal
representative.”
An heir includes “those persons, including the surviving spouse, who are entitled under the
statutes of intestate succession to the property of a decedent.” I.C. § 15-1-201(22). The Farnlun
property is being distributed via trust, not through intestate succession. Thus, the Morrisons do not
fall within the definition of “heirs.”
A “devisee” is “any person designated in a will to receive a devise. In the case of a devise
to an existing trust or trustee, or to a trustee or trust described by will, the trust or trustee is the
devisee and the beneficiaries are not devisees.” I.C. § 15-1-201(12). In the case of a trust,
“beneficiaries are not devisees.” Id. As such, the Morrisons do not fall within the definition of a
“devisee.”
For these reasons, neither section 6-501 nor section 15-3-911 permitted the Morrisons to
bring a partition claim concerning the Farnlun property. The district court did not err when it
granted summary judgment on the basis of standing and dismissed their partition claim.
C. The distric