The Idaho Supreme Court reversed a district court ruling in a complex family property dispute involving The Little Nickell Ranch LLC and dozens of family members spanning multiple generations. The court's opinion, filed Jan. 22, 2026, in *Smallwood v. Little* (Idaho 2026), vacated the lower court's judgment and remanded the case for further proceedings.
The case involves Mavanee Smallwood, L. Dale Nickell, Patricia Nickell-Zimmerman, and The Little Nickell Ranch LLC as plaintiffs-appellants against Kenneth Little, Aaron Little, and Courtney Beardall as defendants-respondents. The litigation also includes more than 20 additional parties, including Glen Little, Joy Norstebon, various members of the Coreson family, multiple Nickell family members, and numerous other individuals connected to the ranch property.
According to the Supreme Court opinion, the central legal issue concerns "the validity of limitations on the transfer of real property, otherwise known as 'restraints on alienation,' and the applicable statutory and common law requirements they must satisfy." Justice Moeller authored the opinion for the high court.
The dispute originated in the District Court of the Seventh Judicial District in Teton County, where District Judge Steven W. Boyce had granted summary judgment in favor of the respondents. However, the Idaho Supreme Court found this ruling inappropriate and reversed the decision.
Restraints on alienation are legal mechanisms that limit a property owner's ability to transfer or sell real estate. These restrictions must meet specific statutory and common law requirements to be legally enforceable. The precise nature of the restraints at issue in this case and the court's reasoning for reversing the summary judgment were not detailed in the available court documents.
The case appears to involve inheritance and property rights issues affecting The Little Nickell Ranch LLC, an Idaho limited liability company. The large number of parties suggests the dispute may stem from disagreements over ranch ownership, management, or succession planning among extended family members.
The litigation includes several members of the Smallwood family, including Cameron, Keagan, and Wade Smallwood, as well as numerous Nickell family members such as Alan, Shane, and Lawrence Nickell. Other parties include members of the Coreson family, various individuals with connections to the ranch, and unknown heirs of deceased family members Arlene Nickell, Whitney Little, and Winifred Griggs.
Hyrum Erickson of Rigby, Andrus & Rigby Law PLLC represented the appellants during oral arguments before the Supreme Court. W. Forrest Fischer of Moulton Law Office in Driggs argued for the respondents.
The Supreme Court's decision to vacate the district court's judgment and reverse the summary judgment ruling indicates the high court found material factual disputes or legal errors that prevented resolution of the case at the summary judgment stage. Summary judgment is typically granted when there are no genuine disputes of material fact and one party is entitled to judgment as a matter of law.
By remanding the case, the Supreme Court is sending it back to the district court for further proceedings, which could include additional discovery, motion practice, or trial. The remand suggests the court believes the restraints on alienation issues require more thorough examination of the facts and applicable law.
Property disputes involving multiple family members and generations often arise from inadequate estate planning, unclear property transfer documents, or disagreements over succession plans for family businesses. Ranch properties, in particular, can become sources of complex litigation when multiple heirs have competing interests in valuable agricultural land.
The case demonstrates the importance of clear property transfer mechanisms and properly structured restraints on alienation when family businesses or ranch properties are involved. Such restrictions, while potentially useful for maintaining family control over property, must comply with legal requirements to avoid lengthy litigation.
The Idaho Supreme Court's reversal means the parties will return to district court to continue litigating the validity of the property transfer restrictions. The outcome could have implications for how restraints on alienation are structured and enforced in Idaho property transactions, particularly those involving family-owned agricultural operations.
The case was heard during the Supreme Court's October 2025 term in Boise, with the opinion filed in January 2026. The extended timeline reflects the complex nature of the property rights issues and the multiple parties involved in the litigation.