Idaho Supreme Court
Idhw v. Beason
April 11, 2024
Summary
The court affirmed summary judgment setting aside two quitclaim deeds that transferred Medicaid recipients’ real-property interests to their grandchildren. It held that the four-year catch-all limitations period applied because the action did not concern the State’s title to the property and, although based on statutory liability, sought a forfeiture excluded from the three-year statutory-liability period. The court also held that the opposing grandson failed to produce admissible, nonconclusory evidence creating a genuine dispute about adequate consideration.