Smith v. Smith, 423 P.3d 998

Sharon (formerly Smith) obtained a 1991 divorce-related money judgment against Vernon (reduced to $194,936.13) and a 1999 judgment for child support and spousal maintenance. Neither judgment has been satisfied.
The 1991 judgment was renewed in 1996 (after which Vernon appealed), and again in 2001, 2006, 2011, and 2016. The Idaho Court of Appeals affirmed the 1996 renewal in Smith v. Smith.
The 1999 judgment was renewed in 2004, 2009, and 2014 after statutory changes made child-support judgments renewable retroactively to 1995.
In 2015 Sharon sought collection remedies; Vernon sought declaratory relief asserting the judgments/renewals were void (arguing lack of lien attachment and procedural defects such as failure to record a form of judgment after renewal).
The magistrate found the judgments and renewals valid and held renewal challenges were barred by res judicata; the district court dismissed Vernon’s appeals for lack of jurisdiction and res judicata. The Supreme Court consolidated Vernon’s appeals and affirmed.

Issue	Plaintiff's Argument (Sharon)	Defendant's Argument (Vernon)	Held
Validity of 1991 judgment renewals	Renewals valid; prior appellate resolution forecloses relitigation	Renewals invalid because a lien never attached and Sharon failed to record a judgment form after 1996 renewal	Affirmed — claims barred by res judicata (previous appeal decided same core contention)
Validity of 1999 judgment renewals	Renewals valid (statute amended retroactively to allow renewal of child-support judgments)	1999 judgment nonrenewable under the law at entry; renewals void	Dismissed for lack of jurisdiction — Vernon failed to timely appeal the renewal orders; statute change made renewals permissible retroactively
Attorney fees on appeal	Entitled to fees because Vernon’s appeals were frivolous and barred	Opposed	Granted — awarded Sharon fees under I.C. § 12-121 as appeals were frivolous/unfounded

Smith v. Smith, 131 Idaho 800, 964 P.2d 667 (Ct. App. 1998) (affirming 1996 renewal of the 1991 judgment)
Ticor Title Co. v. Stanion, 144 Idaho 119, 157 P.3d 613 (discussing claim preclusion and breadth of transactional test)
Berkshire Invs., LLC v. Taylor, 153 Idaho 73, 278 P.3d 943 (res judicata bars claims that could have been raised earlier)
Magic Valley Radiology, P.A. v. Kolouch, 123 Idaho 434, 849 P.2d 107 (defining claim preclusion scope)
Diamond v. Farmers Grp., Inc., 119 Idaho 146, 804 P.2d 319 (transactional concept of claim preclusion)
State v. Young, 162 Idaho 856, 406 P.3d 868 (finality of appellate judgments and effect of failure to timely appeal)