Hausladen v. Knoche, 149 Idaho 449

Summary

The Idaho Supreme Court reviewed whether a parenting coordinator was entitled to compensation for services provided under an appointment order. The court held that the district court erred in affirming the judgment requiring payment without determining whether the services fell within the parenting coordinator’s statutory and procedural authority, and remanded for that determination.

Holdings

1. The district court erred in affirming the magistrate court's judgment requiring Hausladen to pay for Sahlin's services because the record did not establish that the billed services were authorized.
2. Idaho Code section 32-717D(3) and Idaho Rule of Civil Procedure 16(l)(1) grant a parenting coordinator general authority to take actions that empower the parties to engage in effective parenting and decision-making.
3. A parenting coordinator may not make changes to the parties' judgment or exercise the court's final decision-making function unless specifically authorized by the court.
4. The statute and rule do not authorize a parenting coordinator to intervene in disputes that do not involve parenting, unless the parents request assistance with those disputes.

Questions Presented

1. Whether the district court erred in affirming the magistrate court's judgment requiring Hausladen to pay Sahlin's fees when the order of appointment did not specifically authorize Sahlin's challenged actions.
2. Whether Idaho Code section 32-717D(3) and Idaho Rule of Civil Procedure 16(l)(1) confer general authority on a parenting coordinator to perform parenting-related services and thereby support an award of fees.
3. Whether a parenting coordinator may make binding changes to a custody judgment or intervene in nonparenting disputes without specific authorization or a request by the parents.

Disposition

vacated