Henrie v. Corporation of the President of the Church of Jesus Christ of Latter-Day Saints
162 Idaho 204
| Idaho | 2017Background
- Bryan Henrie, an active member and Elders Quorum president, participated voluntarily in a Church-run "Helping Hands" post-fire cleanup in July 2012 after being asked by his bishop.
- At the cleanup staging area Henrie was handed an oversized Helping Hands smock by an unidentified volunteer and told he had to wear it to participate.
- While throwing a burned tree stump down an embankment, the stump caught on Henrie’s smock and pulled him down the embankment, causing a severe right-knee injury.
- Henrie sued the Church for negligence, alleging the Church breached a duty by supplying dangerous/oversized clothing and by failing to supervise volunteers who directed him.
- The Church moved in limine to exclude Henrie’s testimony about statements of the unidentified volunteer (hearsay/not an agent admission) and moved for summary judgment arguing lack of duty, lack of foreseeability, and lack of admissible evidence of causation.
- The district court granted summary judgment, finding no special relationship or duty to protect, the injury was not foreseeable as a matter of law, and excluded the volunteer’s statements as hearsay. Henrie appealed; the Idaho Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a special relationship existed creating an affirmative duty to control/protect Henrie | Henrie felt compelled by his ecclesiastical role and bishop’s "order," so Church had right/ability to control him | Participation was voluntary; Church had no legal right to control adult members in volunteer activity | No special relationship; no affirmative duty (affirmed) |
| Whether Church owed a general duty because injury was foreseeable | Church’s provision of oversized smock created foreseeable risk of injury during cleanup | The specific injury (knee injury caused by smock catching while throwing a stump) was not a foreseeable result of giving a smock | No general duty—injury not reasonably foreseeable as matter of law (affirmed) |
| Admissibility of Henrie’s testimony about the unidentified volunteer’s statements (motion in limine) | Statements showed Church mandated smock-wearing and thus were admissions by agent | Statements are hearsay and declarant is unknown/unidentified so cannot be shown to be Church agent admissions | Court excluded statements as hearsay; Supreme Court did not reach merits because no duty existed (affirmed by implication) |
| Whether Henrie produced admissible evidence of proximate cause | Henrie lacked non-hearsay evidence linking Church action to injury mechanism; claims for jury resolution | Church argued insufficient admissible evidence to prove causation | Court did not decide causation issue because lack of duty disposes of case (summary judgment affirmed) |
Key Cases Cited
- Doe v. Garcia, 131 Idaho 578 (1998) (general duty to use reasonable care to avoid foreseeable harm)
- Alegria v. Payonk, 101 Idaho 617 (1980) (foreseeability standard and when summary judgment on foreseeability is appropriate)
- Coghlan v. Beta Theta Pi Fraternity, 133 Idaho 388 (1999) (special-relationship analysis; no duty to protect adult students from voluntary risks)
- Beers v. Corporation of President of Church of Jesus Christ of Latter-Day Saints, 155 Idaho 680 (2013) (no special relationship imposing duty on church for voluntary member activities)
- Rife v. Long, 127 Idaho 841 (1995) (policy factors and multi-factor balancing for recognizing duties)