David W. Stiles v. Walter A. Amundson, 376 P.3d 734

Owner Walter Amundson removed a heavy bay window from a rental house and left it on the property while attempting to sell it; the window later had a broken pane with jagged glass exposed.
The bay window was moved from the front fence to a cedar fence near a side walkway; parties disputed who moved it and whether Walter knew it had been moved or broken.
A piece of wood (described as a stump/branch/root) lay in the walkway near the window; no evidence explained how or when it got there.
A social guest of a tenant, David Stiles, tripped over the stump at night, fell into the broken window, and suffered severe lacerations from the glass shards.
Stiles sued Walter for premises liability alleging Walter knew or should have known of the dangerous conditions, owed a duty (general or to warn), breached it, and proximately caused the injuries; the district court granted summary judgment for Walter.
On appeal the Idaho Supreme Court affirmed, holding landlords generally owe no duty to tenant guests except when the landlord negligently undertakes repairs, and Walter’s actions were not the proximate cause of Stiles’s injury.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Did Walter owe a general duty of care to a tenant's social guest?	Stiles: Landowners owe a duty of reasonable care to all entrants; landlord therefore owed a duty to Stiles.	Walter: Landlord does not owe general duty to tenant's social guests; tenant (possessor) bears duty.	Held: No general duty; tenant/possessor bears duty to guests; landlord only liable for negligent repairs it undertook.
2. Did Walter owe a duty to warn Stiles of dangerous conditions?	Stiles: Walter knew or should have known of dangerous conditions and thus had duty to warn.	Walter: Absent control/possession or voluntary repair, landlord has no duty to warn tenant's guests.	Held: No duty to warn by landlord in these circumstances; possessor (tenant) is responsible.
3. Was Walter’s removal/handling of the window a negligent "repair" and proximate cause of injury?	Stiles: Removing and leaving the broken window constituted a negligent repair or failed repair that caused injury.	Walter: Moving/removing window was not part of a repair causing the injury; other causes (stump) intervened.	Held: Although negligent repair doctrine can impose liability, as a matter of law Walter’s actions were not the proximate cause; summary judgment proper.
4. Is Walter entitled to appellate attorney’s fees?	Walter: Appeal lacked merit; fees appropriate under Idaho Code.	Stiles: Appeal not frivolous; fees unwarranted.	Held: Denied; appeal was not frivolous or baseless.

Ball v. City of Blackfoot, 152 Idaho 673 (Idaho 2012) (landowner's duty to licensees is limited to sharing knowledge of dangerous conditions)
Harrison v. Taylor, 115 Idaho 588 (Idaho 1989) (tenant in control is deemed owner for liability to third parties; landlord liable for negligent repairs voluntarily undertaken)
Robinson v. Mueller, 156 Idaho 237 (Idaho 2014) (landlord owes duty to tenant's guests only when landlord voluntarily undertakes repairs; tenant occupies role of possessor with respect to guests)
Holzheimer v. Johannesen, 125 Idaho 397 (Idaho 1994) (premises liability duties depend on entrant status)