Farber v. Idaho State Insurance Fund, 147 Idaho 307

Summary

The Idaho Supreme Court held that Idaho Code § 72-915 unambiguously requires the Idaho State Insurance Fund to distribute declared dividends proportionately among eligible policyholders based on prior paid premiums. The court concluded that the Fund manager had discretion whether to declare a dividend, but not discretion to impose a $2,500 premium threshold or otherwise alter the statutory distribution formula. The court reversed the district court's summary judgment for the Fund and remanded the case.

Holdings

1. Section 72-915 is unambiguous. It gives the Fund manager discretion whether to declare a dividend, but it does not give the manager discretion to exclude qualifying policyholders or impose an arbitrary $2,500 premium threshold.
2. The general authority granted to the Fund and its manager by Idaho Code sections 72-901(3) and 72-902 does not override the specific distribution method prescribed by section 72-915.
3. The Fund's interpretation was not entitled to agency deference because it was unreasonable and the statute precisely addressed the method of distributing dividends.

Questions Presented

1. Whether Idaho Code section 72-915 is ambiguous regarding the method for distributing dividends to qualifying Idaho State Insurance Fund policyholders.
2. Whether section 72-915 requires dividends, once declared, to be distributed proportionately according to qualifying policyholders' prior paid premiums.
3. Whether the Fund's interpretation of section 72-915 was entitled to agency deference.
4. Whether the district court properly granted partial summary judgment to the Fund.

Disposition

reversed_and_remanded