Kara Alexander v. Vianna Stibal, 385 P.3d 431

Vianna Stibal operated Nature Path, Inc./ThetaHealing Institute (THInK) and marketed a "Doctorate of Ministry in ThetaHealing;" Kara Alexander paid for classes after THInK announced a doctoral program and later received a plaque stating the doctorate.
Alexander sued Stibal for fraudulent misrepresentations about healings and for breach of contract alleging Stibal failed to provide a "valid" doctorate; Robinson’s related claims were dismissed before trial.
At trial the jury awarded Alexander $17,000 for fraud, $111,000 for breach of contract, and $500,000 punitive damages; the district court reduced punitive damages to $384,000 and denied JNOV and new trial motions by Stibal.
The fraud claims centered on several alleged misrepresentations, with the opinion focusing on Stibal’s claim that she cured herself of cancer; medical records were inconclusive and experts disagreed about a definitive cancer diagnosis.
On appeal the Idaho Supreme Court reversed the denial of JNOV on the contract claim (finding the purported contract too vague), affirmed denial of JNOV/new trial on fraud, allowed punitive damages liability but reduced the amount to $100,000, and remanded for entry of judgment consistent with these rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a contract for a "valid" ThetaHealing doctorate was enforceable	Alexander: Stibal promised a valid doctorate; she relied and paid for classes	Stibal: Degree promotion was vague/ honorary; no enforceable contract	Reversed district court; JNOV granted for contract claim — terms too vague to enforce
Sufficiency of evidence for fraud (cancer claim)	Alexander: Stibal stated she was diagnosed and instantaneously cured; this was false and induced reliance	Stibal: Evidence conflicted; medical records didn’t prove falsehood beyond doubt; reliance not justified	Affirmed denial of JNOV/new trial on fraud — sufficient evidence on nine fraud elements for jury
Whether punitive damages could be pled/submitted and sustained	Alexander: Commercial marketing of false healings supports punitive damages	Stibal: ThetaHealing is religious/protected; punitive damages improper	Amendment and submission to jury affirmed; punitive damages liability sustained, but amount reduced on constitutional grounds
Proper constitutional amount of punitive damages	Alexander: Higher punitive award justified by reprehensibility and deterrence	Stibal: Award excessive and unconstitutional relative to compensatory damages	Jury $500,000 reduced by court; Idaho Supreme Court orders punitive damages reduced to $100,000 (approx. 6:1 ratio)

Olson v. EG&G Idaho, Inc., 134 Idaho 778 (standards for JNOV/directed verdict)
Waterman v. Nationwide Mut. Ins. Co., 146 Idaho 667 (same standard for directed verdict review)
April Beguesse, Inc. v. Rammell, 156 Idaho 500 (review standard and evidentiary inferences)
Griffith v. Clear Lakes Trout Co., 143 Idaho 733 (contract unenforceability for vagueness)
Silicon Int’l Ore, LLC v. Monsanto Co., 155 Idaho 538 (meeting of the minds and contract certainty)
Bank of Commerce v. Jefferson Enters., LLC, 154 Idaho 824 (elements of fraud)
Gray v. Tri-Way Const. Servs., Inc., 147 Idaho 378 (Restatement §544 on reliance)
Carrillo v. Boise Tire Co., 152 Idaho 741 (new trial standards under Rule 59)
Akers v. D.L. White Const., Inc., 156 Idaho 37 (Idaho punitive damages statutory framework)
Weinstein v. Prudential Prop. & Cas. Ins. Co., 149 Idaho 299 (guideposts and constitutional review of punitive awards)