Medical Recovery Svcs V. Eddins, 494 P.3d 784

In 2014 Eddins received emergency treatment (appendectomy) from Intermountain Emergency Physicians (IEP) and Intermountain Anesthesia (IA); unpaid accounts were allegedly assigned to Medical Recovery Services, LLC (MRS).
MRS sued Eddins to collect two debts (IEP: ~$996; IA: ~$1,634). After summary judgment proceedings limited to reasonableness of charges, the parties waived a jury and tried the case to the magistrate court.
At trial MRS proffered two assignment documents (Exhibit 2 for IEP signed by Kerrie Finuf; Exhibit 6 for IA signed by Jennifer Waddell). The magistrate conditionally admitted both exhibits to show reliance but withheld full-admission pending foundation testimony.
Finuf testified and authenticated Exhibit 2; Waddell did not testify and no other IA witness established Exhibit 6’s foundation. The magistrate dismissed MRS’s complaint for lack of standing because assignment signatories’ authority was not proven.
The district court reversed, holding both exhibits should have been admitted and that Eddins was judicially estopped from contesting assignment; the Idaho Supreme Court affirmed in part and reversed in part: Exhibit 2 should have been admitted and MRS had standing as to IEP; Exhibit 6 was not authenticated and IA’s claim is reinstated in Eddins’ favor; the case is remanded for determination of reasonableness and fee allocation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Eddins is judicially estopped from challenging assignment	MRS: Eddins failed to dispute assignment earlier, so he should be estopped from raising it at trial	Eddins: He never took an inconsistent position and standing can be raised any time	Court: Judicial estoppel inapt; Eddins not estopped (district court erred)
Admissibility/authentication of Exhibit 2 (IEP assignment)	MRS: Exhibit 2 is authentic; Finuf’s testimony and Lugo’s testimony suffice to admit for all purposes	Eddins: Foundation lacking; need principal-level testimony or clearer proof of authority	Court: Magistrate abused discretion by refusing full admission after Finuf’s testimony; Exhibit 2 admissible for all purposes
Admissibility/authentication of Exhibit 6 (IA assignment)	MRS: Same as Exhibit 2 — exhibit should be admitted	Eddins: No witness (Waddell) testified and foundation not supplied	Court: Exhibit 6 was never authenticated; magistrate correctly limited admission; IA assignment not proven
Standing/agency and resulting disposition of claims	MRS: Had authority/agency to prosecute both providers’ claims via assignments to MRS	Eddins: MRS lacked standing because the signatories’ authority wasn’t established	Court: Substantial evidence supports agency for IEP (Finuf’s testimony) so MRS has standing for IEP; no evidence for IA so IA’s claim remains dismissed; remand for merits (reasonableness) and fee allocation

Medrain v. Lee, 166 Idaho 604 (2020) (standard for reviewing district court decisions when sitting in appellate capacity)
Nelson v. Kaufman, 166 Idaho 270 (2020) (distinguishing fact question of agency from legal sufficiency review)
Simplot Soilbuilders, Inc. v. Leavitt, 96 Idaho 17 (1974) (an agent may testify about her authority at trial; such testimony is admissible and not mere hearsay)
Brunette v. Idaho Veneer Co., 86 Idaho 193 (1963) (apparent authority is proven by principal's acts; an agent's own statements cannot alone create apparent authority)
United States v. Workinger, 90 F.3d 1409 (9th Cir. 1996) (prima facie authentication standard: once a prima facie case is made, admissibility is proper and authenticity is for the factfinder)
Houpt v. Wells Fargo Bank, N.A., 160 Idaho 181 (2016) (standing as the real party in interest can be raised at any time)
Loomis v. Church, 76 Idaho 87 (1954) (Idaho adoption of judicial estoppel doctrine)