Brooksby v. Geico General Insurance, 286 P.3d 182

Brooksby, injured third party, seeks declaratory judgment against GEICO regarding coverage under her father's policy after GEICO denied under household exclusion.
Father had a GEICO auto policy; December 2007 accident in Bonneville County left Brooksby injured.
Brooksby filed suit against Father in 2009 but pursued the instant action against GEICO in 2010 seeking coverage determination.
District court granted GEICO’s 12(b)(6) motion for lack of standing; ruled Uniform Declaratory Judgment Act does not confer standing where none exists.
Court reaffirmed no direct-action rule: third parties cannot sue an insurer absent statutory/contractual authorization; declaratory relief cannot create standing.
Insurer may join an injured third party in a coverage dispute, but cannot create standing for the third party to sue de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brooksby had standing to seek a declaratory judgment against GEICO.	Brooksby contends standing exists for declaratory relief.	GEICO argues no standing absent statutory/contractual authorization.	District court’s dismissal affirmed; Brooksby lacks standing.

Graham v. State Farm Mut. Auto. Ins. Co., 138 Idaho 611 (2003) (no direct action absent authorization (contractual or statutory))
Hartman v. United Heritage Prop. & Cas. Co., 141 Idaho 193 (2005) (insured’s assignee may sue; no third-party standing absent rights)
Stonewall Surplus Lines Ins. Co. v. Farmers Ins. Co. of Idaho, 132 Idaho 318 (1998) (third-party standing limited by contract)
Downing v. Travelers Ins. Co., 107 Idaho 511 (1984) (no direct action without authorization)
Selkirk-Priest Basin Ass’n v. State ex. rel. Batt, 128 Idaho 831 (1996) (Declaratory Judgment Act does not create standing)
State v. Rhoades, 119 Idaho 594 (1991) (existence of justiciable controversy required for declaratory relief)
Temperance Ins. Exch. v. Carver, 83 Idaho 487 (1961) (insurer may be joined in coverage disputes; focus on standing)