Article I, section 7 of the Idaho Constitution guarantees that “[t]he right of trial by jury shall remain inviolate.”[1] In Worthington v. Crazy Thunder, the Idaho Supreme Court considered the extent of that right when a plaintiff seeks an equitable remedy that involves disputed factual questions.[2]

Carlene Crazy Thunder rented residential property in Blackfoot, Idaho, from Dallen and Rachel Worthington.[3] In June 2021, Crazy Thunder served the Worthingtons with a three-day notice for repairs.[4] In response, the Worthingtons notified Crazy Thunder that her tenancy was terminated, alleging that she had violated the lease.[5] Crazy Thunder refused to leave, so the Worthingtons sued her for unlawful detainer.[6]

Crazy Thunder answered the complaint with several affirmative defenses, ultimately claiming that because the pleadings presented issues of fact, she was entitled to a jury trial.[7] The magistrate court denied her request for a jury trial both before and after the Worthingtons amended their complaint.[8] Instead, it applied Idaho Code section 6-311A, which provides that an action for unlawful detainer of property involving five acres or less of land “shall be tried by the court without a jury.” The court then proceeded with a bench trial over Crazy Thunder’s objection, and it found in favor of the Worthingtons.[9]

Crazy Thunder appealed to the district court. She argued that Idaho Code section 6-311A violates the Idaho Constitution’s jury-trial guarantee.[10] The district court sided with Crazy Thunder, finding that the statute was unconstitutional and that she was entitled to a jury trial.[11] The Worthingtons appealed.[12]

In a unanimous opinion authored by Chief Justice G. Richard Bevan, the Idaho Supreme Court affirmed the district court, although on different grounds.[13] It first determined that section 6-311A did not violate the Idaho Constitution’s jury-trial guarantee, because the constitutional right to a jury trial only applies to claims in law, not equity.[14] Section 6-311A is limited to claims for unlawful detainer, meaning it is concerned with claims over the right of possession.[15] Because the Worthingtons were seeking only to restore possession of land, they were seeking an equitable remedy.[16] 

The court then considered whether Crazy Thunder was entitled to a jury under Idaho Code section 6-313, which provides that “[w]henever an issue of fact is presented by the pleadings it must be tried by a jury.”[17] The court determined that section 6-311A would be unconstitutional if section 6-313 was not applied.[18] And in the instant case, Crazy Thunder was entitled to a jury on the legal issues presented by her affirmative defenses.[19] Specifically, she asserted that a jury was necessary to determine whether the Worthingtons unlawfully retaliated against her for requesting repairs, whether the Worthingtons failed to provide the requisite statutory notice to pay rent or vacate, and whether the Worthingtons waived their right to evict Crazy Thunder for failing to pay rent when they accepted her payment.[20] These were “precisely the questions of fact to which she is entitled a jury trial under Idaho Code section 6-313.”[21]

Ultimately, the court determined that “Idaho Code section 6-311A is constitutional insofar as it applies to cases when no issues of fact have been presented ‘by the pleadings.’”[22]  Accordingly, when a case under section 6-311A presents questions of fact, “the right to jury trial on claims at law remains inviolate.”[23] Because Crazy Thunder was entitled to a jury and did not waive that right, the court affirmed the district court.[24]

 

[1] Idaho Const. art. I, § 7, available at https://sos.idaho.gov/elect/stcon/article_I.html.

[2] Worthington v. Crazy Thunder, 541 P.3d 694, 696 (Idaho 2024).

[3] Id.

[4] Id.

[5] Id. at 696–97.

[6] Id. at 697.

[7] Id.

[8] Id.

[9] Id.

[10] Id. at 697–98.

[11] Id. at 698.

[12] Id.

[13] Id. at 699.

[14] Id.

[15] Id. at 699–700.

[16] Id. at 700.

[17] Id.

[18] Id.

[19] Id. at 700–01.

[20] Id.

[21] Id. at 701.

[22] Id. (quoting Idaho Code § 6-313).

[23] Id.

[24] Id. at 703.

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