GSN Capital, LLC v. Shoshone City & Rural Fire District

Summary

The Idaho Supreme Court affirmed dismissal of GSN’s negligence claim because the fire district owed GSN no tort duty under any of the asserted theories. The court held that the governing statute created no individualized affirmative duty, that no special relationship existed because the district lacked custody or control of GSN’s property, and that the district had not undertaken firefighting services for GSN before the relevant loss. The court also abandoned a rigid required sequence for analyzing claims under the Idaho Tort Claims Act and declined to decide immunity issues because the absence of duty was dispositive.