TEDRA Grants District Courts Broad Subject-Matter Jurisdiction to Decide Declaratory Rights in Estate Assets Despite Ongoing Probate

TEDRA Grants District Courts Broad Subject-Matter Jurisdiction to Decide Declaratory Rights in Estate Assets Despite Ongoing Probate

Introduction

Nelson v. Wylie (Idaho Supreme Court, January 6, 2026) addresses whether Idaho’s Trust and Estate Dispute Resolution Act (“TEDRA”), I.C. §§ 15-8-101 to -305, gives a district court subject matter jurisdiction to adjudicate claims involving the administration and distribution of probate assets while a probate proceeding is already pending in magistrate court.

The dispute arose after Glenna Mae Wylie-Nelson died testate, leaving her husband, Larry T. Nelson, a life estate in the marital home and devising the remainder to her son, Leslie H. Wylie. Larry alleged decades of community-funded maintenance, improvements, and taxes increased the property’s value and sought relief under TEDRA—initially including partition by sale and later (by proposed amendment) declaratory and injunctive relief to establish and compensate his asserted “community-property portion” interest. The district court dismissed for lack of TEDRA jurisdiction, denied leave to amend, and awarded attorney fees to Respondents.

The Idaho Supreme Court vacated and reversed, holding that TEDRA’s text confers broad jurisdiction over “matters” concerning estates and assets, including questions about property interests “passing at death,” and that a court may not treat perceived weakness on the merits as a jurisdictional defect.

Summary of the Opinion

  • Jurisdiction: The district court did have subject matter jurisdiction under TEDRA to consider Larry’s petition (and proposed amended petition) because it sought a declaration of rights regarding an asset or property interest passing at death and questions arising in estate administration. The district court erred by dismissing on jurisdictional grounds.
  • Amendment: Denial of leave to amend was an abuse of discretion because it rested on an incorrect legal premise about TEDRA jurisdiction and failed to apply I.R.C.P. 15’s liberal amendment standard.
  • Attorney fees: Because the dismissal and denial of amendment were erroneous, the fee awards under I.C. § 12-121 and I.C. § 15-8-208 were reversed.
  • Fees on appeal: Respondents were denied appellate fees because they did not prevail; TEDRA fees were also declined because the merits were unresolved on remand.

Analysis

Precedents Cited

1) TEDRA’s scope and function

  • Vouk v. Chapman, 171 Idaho 324, 521 P.3d 712 (2022): The Court relied on Vouk’s description of TEDRA’s purpose and structure—while it promotes nonjudicial resolution, it also authorizes judicial proceedings for declarations of rights or legal relations. Vouk’s key framing (“TEDRA provides a statutory cause of action for a declaratory judgment”) was central to rejecting the district court’s narrow jurisdictional view.
  • Frizzell v. DeYoung, 163 Idaho 473, 415 P.3d 341 (2018): Cited for TEDRA’s “full power and authority” and the statutory backstop that if TEDRA is “inapplicable, insufficient or doubtful,” the court may proceed “in any manner and way that to the court seems right and proper.” Frizzell reinforced the breadth—and remedial character—of TEDRA jurisdiction.

2) Subject matter jurisdiction review and framing

  • Sentry Dynamics, Inc. v. Ada County, 175 Idaho 663, 569 P.3d 484 (2025) (quoting State v. Wolfe, 158 Idaho 55, 343 P.3d 497 (2015)): Used for the de novo standard of review on subject matter jurisdiction, underscoring that the Supreme Court owed no deference to the district court’s jurisdictional conclusion.
  • Nemeth v. Shoshone County, 165 Idaho 851, 453 P.3d 844 (2019) (quoting Paslay v. A&B Irrigation Dist., 162 Idaho 866, 406 P.3d 878 (2017)): Reinforced “free review” over jurisdictional dismissals and supported the Court’s independent assessment of TEDRA’s statutory grant.
  • Bell v. Hood, 327 U.S. 678 (1946): Provided the critical jurisdiction/merits boundary: jurisdiction is not defeated by the possibility the allegations fail to state a claim. This citation directly undercut the district court’s approach of treating alleged legal infirmities (e.g., the property being “indisputably separate”) as a jurisdictional bar.

3) Amendment standards and abuse of discretion

  • Elliott v. Murdock, 161 Idaho 281, 385 P.3d 459 (2016) and Lunneborg v. My Fun Life, 163 Idaho 856, 421 P.3d 187 (2018): Supplied the abuse-of-discretion framework. The Court applied Lunneborg to conclude the district court failed to apply the correct legal standards (misunderstanding TEDRA jurisdiction), and thus its discretion was not exercised consistently with governing law.
  • McCreery v. King, 172 Idaho 598, 535 P.3d 574 (2023) (quoting Atwood v. Smith, 143 Idaho 110, 138 P.3d 310 (2006)): Used to emphasize I.R.C.P. 15’s liberal policy (“freely give leave when justice so requires”) and the limited permissible considerations (valid claim, prejudice from undue delay, defenses), while prohibiting weighing the evidence.
  • Zeyen v. Pocatello/Chubbuck School Dist. No. 25, 165 Idaho 690, 451 P.3d 25 (2019): Cited to reiterate the “liberal standard” for allowing amendment and to highlight the error in denying amendment based on an incorrect jurisdictional premise.

4) Attorney fees when prevailing party status is unresolved

  • Portfolio Recovery Assocs., LLC. v. MacDonald, 162 Idaho 228, 395 P.3d 1261 (2017): Supported denial of appellate fees where there is no present prevailing party and left open that fees for the appeal may be considered by the trial court after remand depending on ultimate success.

Legal Reasoning

  1. Textual breadth of TEDRA “matters” controls. The Court anchored its analysis in TEDRA’s express language:
    • I.C. § 15-8-102(1)(a): courts have “full and ample power and authority” to administer and settle “all matters” concerning estates and assets of deceased persons;
    • I.C. § 15-8-103(1)(c): TEDRA includes “[t]he determination of any question arising in the administration of an estate” or “with respect to any other asset or property interest passing at death,” and the enumerated list “may include, without limitation” certain issues (including construction of wills);
    • I.C. § 15-8-201(1)(a), (b): authorizes a judicial proceeding for a declaration of rights or legal relations regarding any “matter” or “any other case or controversy;”
    • I.C. § 15-8-202(2)-(3): a TEDRA judicial proceeding may be commenced as a new action or incidental to an existing proceeding and may later be consolidated or converted for good cause.
    On that text, Larry’s request for a declaratory judgment about his asserted interest in devised property fit squarely within “any question” concerning estate administration and an “asset or property interest passing at death.”
  2. Non-exhaustive statutory examples cannot be treated as jurisdictional limits. Respondents emphasized that Larry’s proposed amended petition did not focus on “construction” of the Will. The Court rejected that narrowing move because I.C. § 15-8-103(1)(c) is explicitly non-exhaustive (“without limitation”). The jurisdictional inquiry is whether the dispute is a TEDRA “matter,” not whether it matches an enumerated example.
  3. Merits disputes do not negate subject matter jurisdiction. The Estate argued the property was “indisputably” separate and Larry had only reimbursement-type claims. The Supreme Court held this was a merits argument improperly recast as a jurisdictional defect. Citing Bell v. Hood, the Court clarified that even if a claim might fail under I.R.C.P. 12(b)(6) or 12(c), that does not deprive the court of jurisdiction to hear it under TEDRA.
  4. Denial of leave to amend was legally erroneous and therefore an abuse of discretion. Because the district court’s sole stated reason for denying amendment was its mistaken belief that TEDRA jurisdiction was absent, it failed to apply I.R.C.P. 15’s “freely give leave” standard and thus acted inconsistently with applicable legal standards under Lunneborg v. My Fun Life.
  5. Fee awards fell with the erroneous dismissal. With dismissal reversed and merits unresolved, the attorney-fee awards under I.C. § 12-121 and I.C. § 15-8-208 could not stand. Likewise, on appeal, Respondents could not recover fees because they did not prevail, and TEDRA fees were premature without a prevailing party determination (consistent with Portfolio Recovery Assocs., LLC. v. MacDonald).

Impact

  • Clarifies TEDRA as an affirmative jurisdictional pathway during probate. The decision confirms that TEDRA can be used to bring a district-court judicial proceeding for declaratory relief over rights in estate assets even while probate is pending elsewhere, consistent with I.C. § 15-8-202’s new-action/incidental-action framework.
  • Reinforces the jurisdiction-versus-merits boundary in estate litigation. By invoking Bell v. Hood, the Court signals to trial courts that they must not dismiss TEDRA petitions for “lack of jurisdiction” merely because underlying property-law theories appear weak or contested; the proper tools are merits-based motions.
  • Promotes procedural flexibility (consolidation/conversion) rather than gatekeeping. TEDRA’s design—allowing a separate action and later consolidation—suggests courts should manage parallel proceedings pragmatically instead of treating the existence of a probate case as a jurisdictional obstacle.
  • Practical litigation consequence: Parties asserting claims tied to estate administration (including reimbursement or equitable interests in devised assets) may more confidently plead declaratory-judgment claims under TEDRA in district court; opposing parties must meet them on merits, not jurisdictional formalisms.

Complex Concepts Simplified

  • Subject matter jurisdiction: A court’s legal authority to hear a type of case. If subject matter jurisdiction exists, the court can decide the dispute—even if one side ultimately loses on the merits.
  • TEDRA: Idaho’s statutory framework for resolving estate and trust disputes, including judicial proceedings for a “declaration of rights” over broadly defined “matters” involving estates, trusts, and assets passing at death.
  • Declaratory judgment: A court order stating the parties’ rights and obligations (e.g., whether someone has an interest in an estate asset), without necessarily ordering immediate transfer of property.
  • Life estate / remainder: A life estate grants the right to use property during a person’s lifetime; the remainder passes to another person when the life tenant dies.
  • Community property reimbursement theory (as pled): Larry alleged community funds and labor increased the value of separate property, entitling him to compensation. The Supreme Court did not decide whether that theory is correct—only that the district court had power to hear it under TEDRA.
  • I.R.C.P. 12(b)(1) vs. 12(b)(6): 12(b)(1) challenges jurisdiction; 12(b)(6) argues that, even if the facts are true, the law provides no remedy. The Court emphasized these must not be conflated.
  • Leave to amend (I.R.C.P. 15): Courts should usually allow amended pleadings unless there is a sound reason (e.g., undue delay causing prejudice). A mistaken view of jurisdiction is not a sound reason.

Conclusion

Nelson v. Wylie establishes a clear procedural rule for Idaho estate litigation: TEDRA’s broad definition of “matters” gives district courts subject matter jurisdiction to entertain declaratory-rights disputes about estate assets and property interests passing at death, even amid ongoing probate proceedings, and courts must not convert merits skepticism into jurisdictional dismissal. The decision also reinforces liberal amendment practice under I.R.C.P. 15 and cautions against premature fee shifting when the merits have not been adjudicated.

Case Details

Year: 2026
Court: Supreme Court of Idaho

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