The Idaho Supreme Court vacated a district court judgment Tuesday in a construction contract dispute that raised questions about contractor registration requirements under Idaho law. The court ordered the case remanded to reinstate the original findings of fact, conclusions of law, and amended judgment in Ward v. Bishop Construction, LLC.
Joel Ward sued Bishop Construction, LLC, and its sole member, Ren Bishop, for breach of contract and unjust enrichment after Bishop failed to pay Ward for construction services. Ward claimed Bishop hired him to perform work on projects located in Idaho, Montana, and Wyoming but failed to compensate him for his services.
Following a bench trial in the District Court of the Seventh Judicial District of Idaho, Bonneville County, the trial court initially found in Ward's favor on the breach of contract claim. District Judge Dane H. Watkins Jr. awarded Ward damages in the claimed amount of $12,443.54. The court held that because Ward received full recovery on his breach of contract claim, he could not also recover on his equitable claim for unjust enrichment.
The case took a turn after Ward filed a memorandum seeking attorney fees and costs. Bishop then filed a motion to disallow fees and costs, raising for the first time in the litigation that the contract was illegal because Ward was not registered as a contractor as required by the Idaho Contractor Registration Act (ICRA).
The Idaho Contractor Registration Act, codified in Idaho Code sections 54-5201 to 54-5219, governs contractor registration requirements in the state. The statute requires certain contractors to register with the state before performing construction work. The law is designed to protect consumers and ensure that contractors meet minimum qualifications and standards.
Bishop's argument that Ward lacked proper contractor registration under ICRA came late in the proceedings, raised only after the trial court had already ruled in Ward's favor and Ward sought to recover attorney fees and costs. This timing appears to have been significant to the litigation's progression.
The district court apparently reconsidered its original judgment after Bishop raised the contractor registration issue. However, the specific details of how the district court handled Bishop's motion and what led to the modification of the original judgment are not fully detailed in the available court records.
The Idaho Supreme Court's decision to vacate the district court's judgment and remand the case suggests the high court found error in how the lower court handled the contractor registration issue or the procedural aspects of Bishop's late-raised defense.
The case was argued before the Idaho Supreme Court during the September 2025 term, with Chief Justice Bevan authoring the opinion filed December 31, 2025. McConnell Wagner Sykes & Stacey PLLC of Boise represented Bishop Construction and Ren Bishop, with Chad M. Nicholson submitting arguments on their behalf. Holden Kidwell Hahn & Crapo, PLLC of Idaho Falls represented Ward, with Nathaniel H. Wadsworth handling the arguments.
The remand order to reinstate the original findings of fact, conclusions of law, and amended judgment suggests the Idaho Supreme Court determined the district court's initial ruling was correct and that Bishop's contractor registration challenge should not have altered the outcome. This could indicate that either Ward's registration status was not relevant to the contract at issue, or that Bishop waived the right to raise the registration defense by failing to assert it earlier in the proceedings.
Contractor registration disputes often arise in construction litigation when parties seek to avoid contractual obligations by challenging the other party's compliance with state licensing requirements. Courts must balance enforcement of registration statutes with principles of contract law and fairness, particularly when registration issues are raised late in litigation.
The multi-state nature of Ward's work - spanning Idaho, Montana, and Wyoming - may have complicated the registration analysis. Different states have varying contractor registration requirements, and determining which state's laws apply to specific projects can affect the validity of contracts and the ability to recover payment.
The Idaho Supreme Court's decision to remand rather than resolve the registration issue directly suggests the case may return to the district court for further proceedings consistent with the high court's ruling. Ward appears positioned to recover his original judgment of $12,443.54, though additional proceedings may be necessary to finalize the outcome.
The case highlights the importance of timely raising statutory defenses in construction litigation and demonstrates how procedural considerations can affect the outcome of contractor registration disputes under Idaho law.