Davis v. Blast

Summary

The Idaho Supreme Court answered a certified question, holding that a trial court deciding a motion to amend a pleading to add a prayer for punitive damages must determine whether the moving party has presented substantial, admissible evidence showing a reasonable probability of proving punitive damages at trial. The court clarified that the statutory phrase “weighing the evidence presented” does not require a full evidentiary hearing and that the appropriate standard is substantial‑evidence, not clear and convincing, with “sufficient” meaning legal cognizability and substantial proof. The decision provides guidance for both state and federal courts on applying Idaho Code §6‑1604(2).