County of Boise v. Idaho Counties Risk Management Program, 151 Idaho 901

County Boise sued in federal court alleging FHA violations; ICRMP declined to defend under policy terms.
Policy provides defense for covered claims and errors and omissions coverage with defined 'Wrongful Act' and several exclusions.
Alamar's complaint alleged planning/zoning actions violated the FHA and sought damages; district court found coverage excluded by land use regulation exclusion.
District court held no duty to defend due to policy exclusion for land use regulation/planning and zoning activities; found no resurrection via Exclusion Sixteen.
On appeal, court affirms district court, ruling land use exclusion bars coverage and Exclusion Sixteen does not resurrect coverage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does land use regulation/planning and zoning exclusion bar coverage?	Alamar's FHA claims could be covered; exclusion not expressly tied to civil rights.	Exclusion plainly covers land use regulation; claims arise from land use decisions.	Yes, the land use exclusion bars coverage.
Does Exclusion Sixteen resurrect coverage for civil rights claims?	Exclusion allows coverage to be revived for tort/civil rights claims.	Exclusion Sixteen does not revive coverage; would nullify other exclusions.	No, Exclusion Sixteen does not resurrect coverage.

Hoyle v. Utica Mut. Ins. Co., 137 Idaho 367, 48 P.3d 1256 (2002) (Idaho 2002) (duty to defend depends on potential coverage from complaint)
Martel v. Bulotti, 138 Idaho 451, 65 P.3d 192 (2003) (Idaho 2003) (summary judgment standard; standard of review for legal rulings)