The Idaho Supreme Court has reversed a district court's decision in a complex estate dispute between a widower and his deceased wife's children from a previous marriage, highlighting ongoing jurisdictional questions under Idaho's Trust and Estate Dispute Resolution Act.
In *Nelson v. Wylie*, decided Jan. 6, 2026, the Idaho Supreme Court vacated the district court's judgment, reversed orders denying leave to amend pleadings and awarding attorney fees to respondents, and remanded the case to the trial court for further proceedings.
The dispute centers on the estate of Glenna Mae Wylie-Nelson, who died leaving behind her husband Larry T. Nelson and three children from her previous marriage: Leslie H. Wylie, Terese L. Wylie, and Shanelle R. Wylie. The three children serve as co-personal representatives of their mother's estate.
According to court documents, Glenna Mae's Last Will and Testament granted her husband Larry a life estate in the family home and two lots where the couple lived together. Under the will's terms, if Larry dies or sells the property, the remainder interest would pass to Leslie, Glenna Mae's son from her previous marriage. The property was characterized as Glenna Mae's separate property.
The case originated in the District Court of the First Judicial District in Bonner County, with District Judge Susie D. Jensen presiding. The lower court's judgment favored the deceased's children, but the Idaho Supreme Court found reversible error in the district court's handling of the matter.
Writing for the court, Justice Moeller addressed whether the Trust and Estate Dispute Resolution Act, codified at Idaho Code Sections 15-8-101 to -305, provides district courts with subject matter jurisdiction to address legal issues associated with ongoing probate actions. TEDRA was designed to streamline dispute resolution in trust and estate matters, but questions remain about its scope and application.
The reversal suggests the district court may have overstepped its jurisdictional bounds or improperly applied TEDRA provisions in denying Larry Nelson's requests to amend his pleadings. The Supreme Court's decision to reverse the attorney fee award indicates the lower court may have inappropriately shifted litigation costs to the appellant.
Multiple law firms represented the parties in this high-stakes family dispute. Riverside NW Law Group PLLC of Spokane, Washington, represented appellant Larry Nelson, with attorney Brennan J. Schreibman arguing the case before the Supreme Court. Lake City Law Group PLLC of Sandpoint represented respondents Terese L. Wylie and Shanelle R. Wylie, with attorney Zachary W. Jones handling oral arguments. Leslie H. Wylie was separately represented by Finney Finney & Finney PA of Sandpoint, with attorney John A. Finney arguing on his behalf.
The case illustrates the complex legal issues that can arise when blended families face estate disputes. Life estates, which grant one party the right to use property during their lifetime while preserving future ownership rights for another party, often generate litigation when family relationships are strained.
The Supreme Court's decision to remand rather than enter final judgment suggests the case involves factual disputes or legal issues requiring further development at the trial court level. The reversal of the attorney fee award may encourage more estate litigation by reducing the financial risks for unsuccessful parties.
Estate practitioners will likely scrutinize this decision for guidance on TEDRA's jurisdictional limits and proper procedural handling of estate disputes. The ruling may clarify when probate courts should defer to TEDRA procedures versus exercising traditional probate jurisdiction.
The family dispute appears to involve significant property interests, given the involvement of multiple law firms and the Supreme Court's willingness to hear the appeal. Life estates in residential property can involve substantial financial stakes, particularly in Idaho's competitive real estate market.
For Larry Nelson, the reversal represents a significant procedural victory that allows him to pursue his claims with amended pleadings and without bearing the respondents' attorney fees. The three Wylie siblings must now defend their mother's estate plan under different procedural circumstances.
The remand order suggests this estate dispute is far from resolved. The district court will need to address the case anew, considering whatever amended pleadings Larry Nelson may file and applying proper jurisdictional principles under TEDRA.
This decision adds to Idaho case law interpreting TEDRA's scope and application, providing guidance for future estate disputes involving similar jurisdictional questions. The outcome may influence how Idaho courts handle competing claims between surviving spouses and children from previous marriages in blended family situations.
