Your state’s pack. New issues arrive periodically on Mondays. Bookmark it. I built this for the Idaho T&E solo who knows the Uniform Probate Code (Idaho Code Title 15) cold but still loses an afternoon a week hunting the current homestead number, the Aged & Disabled Waiver (Idaho Medicaid, run by DHW) slot posture, whether the latest Idaho bar ethics opinion changes how you scope an engagement, or whether a recent Idaho Court of Appeals decision just moved the law on capacity, undue influence, or a trustee’s duties. What’s below is what mattered in Idaho lately — the week’s developments and the recent rulings from the bench.
For licensed attorneys. This pack is general legal information and professional commentary for practicing attorneys — it is not legal advice, does not apply to any specific matter, and creates no attorney-client relationship. Verify every authority against the cited primary source before relying on it with a client. Published by Mike Moss, a Utah-admitted attorney, as an AI-enablement information product; it is not an offer of legal services and is not a representation that the author is admitted to practice in your jurisdiction.
Three developments from the last several weeks that I think actually matter to an Idaho T&E solo. Each one has a read that lands on your practice specifically — and each one comes with the citation so you can verify the detail yourself before you use it with a client.
The Department of Health and Welfare’s managed-care page now states the shift to a comprehensive managed-care model is delayed to January 1, 2030, after litigation stalled the procurement (delay announced about April 30, 2026). IMPlus — DHW’s pre-existing mandatory program for dual-eligibles — continues, but it is not the HB 345 comprehensive rollout. DHW is running statewide listening sessions on program design under the Legislative Medicaid Review Panel.
If you told LTC-planning clients that comprehensive managed care was arriving imminently, the agency’s own page now says otherwise — a four-year runway changes how you sequence eligibility planning and provider-network advice. Track the listening sessions; program design is being written now.
Idaho DHW, The Future of Idaho Medicaid is Managed Care (read July 11, 2026) · healthandwelfare.idaho.gov
HB 913 requires able-bodied Medicaid-expansion adults to complete 80 hours per month of work or community engagement, with three months’ compliance before enrollment. State adoption is set for December 31, 2026, with federal compliance by 2027.
This sits at the eligibility front door for a slice of your clients’ households. While LTC eligibility for the aged and disabled runs on different rules, expansion-adult family members (and clients near the disability line) can be swept into the work-requirement screen — factor it into household-level planning and don’t assume a working-age relative’s coverage is automatic.
Idaho HB 913 (2026) · legislature.idaho.gov · H0913 (2026)
Idaho has not adopted the URPTODA: there is no real-property transfer-on-death / beneficiary deed (TOD exists for securities only). Substitutes are a living trust, joint tenancy WROS, or community property with right of survivorship (§ 15-6-401). And § 56-218 authorizes recovery for recipients age 55+ from the recipient’s estate AND the spouse’s estate, voiding inadequate-consideration transfers.
Two out-of-state habits will burn you here. First, never reach for a beneficiary deed — it doesn’t exist in Idaho; use CPWROS, joint tenancy, or a trust. Second, probate-avoidance is not recovery-avoidance: because recovery reaches the spouse’s estate, planning that simply moves assets to the well spouse can still be exposed. Plan the recovery question explicitly, not as an afterthought.
Idaho Code § 56-218 (estate recovery) & § 15-6-401 (CPWROS) · legislature.idaho.gov · § 56-218
Decisions that bind an Idaho practitioner — Idaho’s appellate courts and the federal courts covering Idaho, including the U.S. Ninth Circuit — read for what actually changes how you draft, advise, and plan. Trusts and estates broadly, not Medicaid alone: wills and capacity, undue influence, fiduciary duty, trust construction, and estate recovery. One read, the holding, and the official cite.
Two parent trusts each held a fractional interest in the same Idaho ranch property. The son sued his sister, the trustee, for breach of trust and fiduciary duty, sought an accounting, added her family as parties, and sought partition of the property by sale. The trustee petitioned to distribute both trusts in kind so the property would stay in the family. The district court denied removal of the trustees, dismissed the partition claim for lack of standing, enforced the mother’s trust’s no-contest clause to strip the son of his entire share, granted distribution in kind, and assessed fees under Idaho Code §§ 15-8-208 and 12-121 against the son’s share of the father’s trust. The Supreme Court affirmed on every point. On standing: neither § 6-501 nor § 15-3-911 reaches these plaintiffs, because a beneficiary of an undistributed trust has an interest but not a present possessory interest, and Title 15 expressly provides that the trust or trustee — not the beneficiaries — is the “devisee.” On the no-contest clause: such clauses are enforceable in Idaho and yield only to probable cause, which the son lacked, because the trust gave the trustee sole authority to distribute in kind.
The teeth here are in the breadth of the clause. This one revoked the share of any beneficiary who would “oppose any distributions” — and the court read that to reach a challenge to the trustee’s chosen method of distribution, not merely an attack on the trust’s validity. If you draft no-contest clauses in Idaho, understand you may be arming the trustee against ordinary beneficiary pushback; if you advise a beneficiary, read the clause before the first objection is filed and know that Ferguson’s probable-cause safe harbor asks whether a properly advised person would have seen a substantial likelihood of success — and that discretion expressly granted to the trustee is very hard to overcome. One more practical note: the partition holding forecloses a common workaround. A beneficiary who wants the real property sold has to take that up as a trust matter, not by filing a partition action.
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, Docket No. 52401-2024 (Idaho June 30, 2026) — affirmed. · API.ISC.IDAHO.GOV · official opinion
A personal representative hired counsel to handle her mother’s probate. The two heirs had a private understanding about valuing and refinancing the family home; the personal representative later emailed counsel candidly about managing her brother, and counsel showed that email to the brother at a joint meeting. The arrangement collapsed. The estate sued counsel for legal malpractice, breach of contract, unjust enrichment, and violation of the Idaho Consumer Protection Act, and on appeal pressed only the last two. The Supreme Court affirmed summary judgment for the lawyer. Unjust enrichment could not stand as an independent claim because it rested on the same alleged misconduct as the malpractice claim. And while attorneys are not exempt from the ICPA — Litster Frost confirms a firm can violate it, for instance by misrepresenting fee terms — the estate’s allegations all concerned the quality of legal services, handling of privileged material, litigation communications, and withdrawal, none of which is consumer-facing deception under § 48-603(17). The court also noted the estate produced no signed engagement contract, only a one-page intake form with unsigned initial lines.
Two lessons, and the second one is about your file, not your liability theory. First, if you defend or bring claims against estate counsel in Idaho, expect the ICPA and unjust-enrichment counts to be pared back to the malpractice claim unless the conduct is genuinely transactional deception — a fee misrepresentation, not a judgment call. Second, read what actually happened here as a warning about role clarity in a two-heir probate. Counsel represented the estate through its personal representative, sat with both siblings, and disclosed one sibling’s candid email to the other. The court found no ICPA violation, but it also went out of its way to say the estate had raised “valid and serious concerns” about counsel’s advice and communications, and declined to call the appeal frivolous. Put the engagement in writing, name the client, tell the non-client heir in writing that you do not represent them, and decide before the meeting what you will and will not share.
The Estate of Laurel Ann Kalinski, through Personal Representative Crystal Marie Kalinski v. Murphy Law Office, PLLC, and Michaelina Brady Murphy, Docket No. 52242 (Idaho May 5, 2026) — affirmed. · API.ISC.IDAHO.GOV · official opinion
This week in Idaho for the T&E solo with Idaho Medicaid clients: the developments from the Idaho State Bar (Taxation, Probate & Trust Law Section) and the Department of Health and Welfare that actually moved your practice this period — each one primary-source verified.
Bar and Medicaid changes land on different schedules and aren’t indexed by practice focus. Every item here was checked against its primary source, with the link, so you can verify before relying on it.