The Idaho Supreme Court affirmed a district court ruling Monday that protects property owners from homeowners association attempts to restrict short-term rentals, marking the first time the state's highest court has interpreted a key statute governing rental restrictions.
In *North Henry's Lake Homeowners Association, Inc. v. Norton* (Idaho 2026), the court upheld a summary judgment ruling in favor of four property owners who challenged their homeowners association's attempt to enforce new restrictions on short-term rentals in their subdivision.
The case centered on Idaho Code section 55-3211, which prohibits the addition of any restrictions that limit short-term rentals in a subdivision without the express written consent of the property owner. The central legal question was whether this statute protects a particular property owner or a particular property.
North Henry's Lake Homeowners Association brought suit against Bryan Norton, Henry Virgil LLC, Properties Idaho LLC and C&N Perspectives LLC to enforce an amendment to the subdivision's covenants, conditions, and restrictions that prohibited any property in the subdivision from being leased as a short-term rental. The HOA also sought an injunction to prevent the homeowners from operating short-term rentals on their properties.
The dispute arose when the HOA attempted to implement new restrictions on short-term rentals through amendments to the subdivision's CCRs. The property owners argued that Idaho Code section 55-3211 protected their right to operate short-term rentals without providing express written consent to such restrictions.
The Seventh Judicial District Court of Idaho, Fremont County, initially ruled in favor of the property owners, granting summary judgment and concluding that the restriction on short-term rentals did not apply to their properties. District Judge Joel E. Tingey found that the homeowners were protected under the statute because neither the property owners nor their properties were subject to the new restrictions without their consent.
The homeowners association appealed the district court's decision to the Idaho Supreme Court, arguing that their interpretation of the statute was incorrect and that they had the authority to implement the short-term rental restrictions.
Justice Brody authored the Supreme Court's opinion affirming the lower court's ruling. The court's analysis focused on whether Idaho Code section 55-3211's protections apply to individual property owners or to specific properties within a subdivision.
The case represents the first time an Idaho appellate court has interpreted Idaho Code section 55-3211, making it a precedent-setting decision for property rights and homeowners association authority throughout the state. The ruling clarifies the scope of protections available to property owners who wish to operate short-term rentals despite homeowners association objections.
Short-term rental disputes have become increasingly common across the United States as the popularity of platforms like Airbnb and VRBO has grown. Many homeowners associations have sought to restrict or prohibit short-term rentals, citing concerns about noise, increased traffic, and changes to neighborhood character. Property owners, meanwhile, have argued that such restrictions interfere with their property rights and potential rental income.
Idaho's approach to this issue through section 55-3211 provides statutory protection for property owners, requiring their express written consent before new short-term rental restrictions can be implemented. The Supreme Court's affirmation of the district court ruling strengthens these protections and limits homeowners associations' ability to unilaterally impose such restrictions.
The legal teams involved in the case included Givens Pursley LLP of Boise and Vial Fotheringham LLP of Meridian representing the homeowners association, with Morgan D. Goodin arguing on appeal. Liberty Law Idaho PLLC of Meridian represented the property owners, with Bryan Norton arguing before the Supreme Court.
The implications of this ruling extend beyond the specific parties involved. Other homeowners associations in Idaho will need to carefully consider the requirements of Idaho Code section 55-3211 before attempting to implement new restrictions on short-term rentals. Property owners, meanwhile, can rely on the Supreme Court's interpretation as protection for their rental activities.
The decision also provides clarity for future disputes involving homeowners association authority and property owner rights. By affirming the district court's interpretation of the statute, the Supreme Court has established a framework for analyzing similar conflicts that may arise in other Idaho subdivisions.
Looking ahead, this ruling may influence how homeowners associations approach short-term rental issues and could prompt legislative discussions about the balance between community standards and individual property rights. The decision reinforces Idaho's position as a state that provides strong protections for property owners' rental activities, subject to statutory requirements for consent from affected property owners.