Raymond v. Idaho State Police

Raymond · Supreme Court of the State of Idaho · October 18, 2019 · No. 46272

Summary

The Idaho Supreme Court formally adopted the tort of intentional interference with a prospective civil action by third-party spoliation of evidence. The Court held that Raymond’s complaint sufficiently alleged the elements of the tort under Idaho’s notice-pleading standard and that dismissal under Idaho Rule of Civil Procedure 12(b)(6) was improper. The Court reversed the dismissal, vacated the judgment in favor of Idaho State Police, denied attorney fees, and awarded appellate costs to Raymond.

Holdings

  1. Idaho formally recognizes the tort of intentional interference with a prospective civil action by spoliation of evidence by a third party.
  2. A plaintiff must prove: (1) a pending or probable lawsuit involving the plaintiff; (2) the defendant's knowledge of the potential or probable lawsuit; (3) wrongful destruction, mutilation, alteration, or concealment of evidence designed to disrupt or defeat the potential lawsuit; (4) disruption of the potential lawsuit; (5) a causal relationship between the spoliation and disruption; and (6) damages proximately caused by the defendant's acts.
  3. The indeterminate nature of damages in a third-party spoliation case does not bar recovery if the plaintiff proves the extent of damages by a just and reasonable inference; damages may not rest on mere speculation or guess.
  4. Raymond's complaint sufficiently stated a claim for intentional interference with a prospective civil action by third-party spoliation and should not have been dismissed.
  5. The court declined to address or recognize negligent spoliation of evidence as a viable cause of action.

Questions Presented

  1. Whether Idaho recognizes an independent tort of intentional interference with a prospective civil action by third-party spoliation of evidence.
  2. Whether Raymond's complaint alleged sufficient facts to survive dismissal under Idaho Rule of Civil Procedure 12(b)(6).
  3. Whether Idaho State Police was entitled to attorney fees and costs on appeal.

Disposition

reversed_and_remanded

Cases Cited (27)

  • Idaho Wool Growers Association, Inc. v. State, 154 Idaho 716, 302 P.3d 341 (2012)(followed)
  • Hoffer v. City of Boise, 151 Idaho 400, 257 P.3d 1226 (2011)(followed)
  • Hammer v. Ribi, 162 Idaho 570, 401 P.3d 148 (2017)(followed)
  • Young v. City of Ketchum, 137 Idaho 102, 44 P.3d 1157 (2001)(followed)
  • Savage v. Scandit Inc., 163 Idaho 637, 417 P.3d 234 (2018)(followed)
  • Yoakum v. Hartford Fire Insurance Co., 129 Idaho 171, 923 P.2d 416 (1996)(followed)
  • Cook v. State Department of Transportation, 133 Idaho 288, 985 P.2d 1150 (1999)(followed)
  • Ricketts v. Eastern Idaho Equipment Co., Inc., 137 Idaho 578, 51 P.3d 392 (2002)(followed)
  • Waters v. All Phase Construction, 156 Idaho 259, 322 P.3d 992 (2014)(distinguished)
  • Hills v. United Parcel Service, Inc., 232 P.3d 1049 (Utah 2010)(persuasive)

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