Jadwiga Melton v. Heinz Alt, 44768

Heinz, son/stepson, alleged he loaned $102,574.50 to Hedy and Robert to build a home in exchange for reciprocal wills leaving their estates to him; only Hedy signed handwritten notes acknowledging the debt.
Hedy died in 2008; her will was never probated. Robert remarried Jadwiga in 2010 and executed a new will; Robert died in 2013.
Jadwiga opened a joint probate for both Hedy and Robert under Idaho Code §15-3-111 (permitting joinder where the first spouse’s estate was never probated and the survivor died later).
Heinz filed a creditor claim for the debt after Robert’s death; Jadwiga disallowed the claim as untimely with respect to Hedy’s estate, arguing the claim was not presented within three years of Hedy’s death as required by Idaho Code §15-3-803.
Magistrate court held Heinz’s claim against Hedy’s estate was time-barred; district court reversed, holding §15-3-111’s tolling of the probate limitation in §15-3-108 also tolled the §15-3-803 creditor claim deadline for the first spouse to die.
Idaho Supreme Court reversed the district court: §15-3-111 unambiguously tolls only the probate-commencement rule in §15-3-108, not the creditor-claim deadline in §15-3-803; Heinz’s claim against Hedy’s estate is barred, but claims against Robert’s estate may proceed. No appellate fees or costs awarded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §15-3-111 extends/tolls the §15-3-803 creditor-claim deadline for the first spouse to die when estates are jointly probated.	Jadwiga: §15-3-111 does not mention §15-3-803; creditor claims are barred three years after the decedent’s death — Heinz’s claim against Hedy is untimely.	Heinz: §15-3-111 tolled time limits for joint probate proceedings (per the §15-3-108 amendment) and the probate code should be read as a whole to allow creditor claims within three years of the second spouse’s death.	Court: §15-3-111 is unambiguous and references only §15-3-108; it does not extend the §15-3-803 creditor deadline. Claim against Hedy’s estate is barred; claim against Robert’s estate survives.
Whether either party is entitled to attorney fees and costs on appeal.	Jadwiga sought fees/costs.	Heinz sought fees/costs.	No fees or costs awarded because there is no prevailing party (matter remanded on claims against Robert’s estate).

Gracie, LLC v. Idaho State Tax Comm’n, 149 Idaho 570 (summary judgment standard and review)
Castorena v. General Electric, 149 Idaho 609 (construction of disputed facts for summary judgment)
State v. Schulz, 151 Idaho 863 (statutory interpretation begins with literal language)
State v. Dunlap, 155 Idaho 345 (objective of statutory interpretation; words given ordinary meaning)
Porter v. Board of Trustees, Preston School Dist. No. 201, 141 Idaho 11 (definition of statutory ambiguity)
Saint Alphonsus Regional Med. Ctr. v. Gooding County, 159 Idaho 84 (courts reluctant to insert words into statutes)
Burnight, 132 Idaho 654 (apply clear statutory language without construction)