Evangelical Lutheran Good Samaritan Society v. Bd of Equalization of Ada County, 161 Idaho 378

Evangelical Lutheran Good Samaritan Society ("Society"), a 501(c)(3) public charity, operates Boise Village, a 96‑bed skilled nursing facility in Ada County, Idaho. Society operates multiple facilities nationwide.
Boise Village charged residents rates comparable to local commercial skilled nursing facilities and historically admitted only residents who could pay; it never knowingly admitted residents unable to pay. Residents sign admission agreements obligating payment; collections and occasional lawsuits were used for overdue accounts.
Boise Village received small unrestricted donations ($72k in 2012; $39k in 2013) and substantial volunteer hours, but donations comprised roughly 0.5% of operating revenue; 87–94% of revenue (2011–2013) came from government programs (Medicaid, Medicare, VA). Boise Village reported net profits during the period.
Ada County denied Society property tax exemptions for Boise Village for 2012–2014; district court awarded Society a full charitable exemption and a partial religious exemption. Ada County appealed the charitable exemption ruling.
The Idaho Supreme Court reviews charitable-exemption questions de novo, strictly construes exemption statutes against taxpayers, and applies the Sunny Ridge Manor multi‑factor test to determine charitable status under I.C. § 63‑602C.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Society qualify as a "charitable organization" under I.C. § 63‑602C (Sunny Ridge factors)?	Society provides public benefit via ministry care for elderly/disabled, is a public charity, receives donations and volunteer support, has policies against evicting residents for nonpayment, and awards some charitable allowances.	Boise Village operates like a commercial facility: charges market rates, largely funded by government programs, produces profits, donations are nominal and do not reduce resident costs, and charity is not provided on a need‑based sliding scale.	Reversed: Society is not a charitable organization under Sunny Ridge. Court found most factors (functionality, donations, public benefit, profit, need‑based charity) weighed against Society; therefore no charitable exemption.

Sunny Ridge Manor, Inc. v. Idaho State Tax Commission, 106 Idaho 98, 675 P.2d 813 (Idaho 1984) (establishes multi‑factor test for charitable status)
Housing Southwest, Inc. v. Washington County, 128 Idaho 335, 913 P.2d 68 (Idaho 1996) (government subsidies undermine charitable‑function and public‑benefit factors)
Evangelical Lutheran Good Samaritan Soc’y v. Bd. of Equalization of Latah County, 119 Idaho 126, 804 P.2d 299 (Idaho 1990) (prior treatment of similar Society operations and profit considerations)
Owyhee Motorcycle Club, Inc. v. Ada County, 123 Idaho 962, 855 P.2d 47 (Idaho 1993) (donations must reduce public cost to weigh in favor of exemption)
Community Action Agency, Inc. v. Bd. of Equalization of Nez Perce County, 138 Idaho 82, 57 P.3d 793 (Idaho 2002) (strict construction of tax‑exemption statutes against taxpayer)