In re Prefiling Order Declaring Vexatious Litigant, Pursuant to I.C.A.R. 59., 434 P.3d 190

Ronald Van Hook lost custody in a contentious divorce from Dawn Cannon and proceeded to file numerous pro se motions after successive attorneys withdrew.
Between 2014–2017 Van Hook filed multiple additional lawsuits across Canyon, Owyhee, and Adams Counties, mostly seeking custody or challenging the divorce outcome; several were dismissed or denied.
The magistrate court in the Canyon County divorce matter issued an Order for Referral asking the administrative district judge to consider a vexatious-litigant designation under I.C.A.R. 59.
The administrative district judge opened a separate file, issued a proposed prefiling order, held a hearing, and on September 20, 2017 declared Van Hook a vexatious litigant under multiple I.C.A.R. 59(d) prongs.
The order required Van Hook to obtain leave of a judge before filing new pro se litigation; Van Hook appealed to the Idaho Supreme Court.
The Supreme Court affirmed, concluding the administrative district judge did not abuse his discretion in applying I.C.A.R. 59(d).

Issue	Van Hook's Argument	State/Respondent's Argument	Held
Whether Van Hook met I.C.A.R. 59(d)(1) (≥3 adverse pro se litigations in 7 years)	His prior dismissals were not final due to alleged due process/equal protection violations	Multiple pro se actions across counties were dismissed/denied and final; constitutional claims should have been raised earlier	Court held Van Hook met 59(d)(1); constitutional challenges not preserved here
Whether Van Hook met I.C.A.R. 59(d)(2) (repeated relitigation)	His repeated filings were persistent but reasonably grounded	His filings were collateral attacks aimed at relitigating custody/divorce determinations	Court held filings constituted repeated attempts to relitigate; 59(d)(2) satisfied
Whether Van Hook met I.C.A.R. 59(d)(3) (repeated frivolous filings/tactics)	He had reasonable grounds for filings	He repeatedly filed similar, unmeritorious motions causing delay (recusal motions, etc.)	Court held filings were frivolous/repetitive and 59(d)(3) satisfied
Whether magistrate lacked jurisdiction to refer vexatious-litigant matter because of pending appeal (automatic stay)	Referral was void because App. R.13 stay applied after his notice of appeal	Referral created a new case for separate Rule 59 proceedings; stay did not prevent referral	Court held magistrate had authority to refer and filing a separate case was proper; stay did not bar Rule 59 process

Telford v. Nye, 154 Idaho 606, 301 P.3d 264 (2013) (appellate review of prefiling orders applies abuse-of-discretion standard; issues not raised below are forfeited)
Lunneborg v. My Fun Life, 163 Idaho 856, 421 P.3d 187 (2018) (framework for assessing abuse of discretion)
Hull v. Giesler, 163 Idaho 247, 409 P.3d 827 (2018) (factual findings reviewed under clearly erroneous standard supported by substantial evidence)