This Spring, the Idaho Supreme Court issued several opinions addressing issues of first impression. Below are the highlights from one of these opinions, Westover v. Cundick. We’ll discuss the other cases that have addressed new issues in the coming weeks.
In Westover v. Cundick, 2017 Opinion 33 (Apr. 14, 2017) (slip op.), the Supreme Court addressed the issue of whether Idaho Rule of Civil Procedure 54(c) imposes a duty on a district court to sua sponte grant injunctive relief when it is not requested. The Court addressed a prior version of Rule 54(c), which provided: “every final judgment shall grant the relief to which the party in whose favor it is rendered is entitled, even if the party has not demanded such relief in his pleadings.” (Emphasis added.) The Court concluded that a lower court was not obligated to grant unrequested relief based on the plain language of the Rule because the plaintiffs were “not the ‘party in whose favor’ the judgment was rendered.” Slip op. at 5. However, the Court noted that Rule 54(c) has been amended, effective July 2016, to provide: “final judgment should grant the relief to which each party is entitled, even if the party has not demanded that relief in its pleadings.” Id. at 5 n.1 (emphasis added). The Court provided no guidance as to how its holding would apply to the current Rule 54(c) language. With the holding in Cundick being closely tied to the very language modified in the Rule, it appears that this issue could come before the Court again in the coming years.