The Idaho Supreme Court recently issued a significant ruling affecting property rights along the shores of Priest Lake. The court reversed a lower court's decision that had favored Steven and Susan Coffey over Stephan and Amy Byrd and the McCray Living Trust regarding ownership of waterfront property. The ruling, filed on September 4, 2026, clarifies the standards of proof required in property disputes and emphasizes the importance of accurately interpreting property deeds.
The case involves a long-standing dispute over littoral rights, which are the rights of property owners whose land borders a body of water. The Byrds and the Trust argued that their deeds granted them rights to the land up to the ordinary high water mark (OHWM) of Priest Lake. In contrast, the Coffeys claimed ownership of the strip of land that lies between the Byrds' property and the lake.
Background
The dispute traces back to the original ownership of the land by William and Mary Taylor, who purchased it from the Diamond Match Company in 1951. The Taylors later divided the property into several parcels. The Byrds and the Trust hold two of these parcels, while the Coffeys own a parcel that includes the remaining land adjacent to the lake.
In 2021, the Byrds and the Trust applied for an encroachment permit to build a dock extending into Priest Lake. The Idaho Department of Lands denied their application, stating they had not proven their littoral rights. This decision led to a series of legal battles, culminating in a quiet title action where both parties sought a declaratory judgment regarding their ownership of the property.
The Ruling
The Idaho Supreme Court ruled that the lower court had erred in applying a clear and convincing evidence standard to the Byrds' and the Trust's claims. Instead, the court should have applied a preponderance of the evidence standard, which is typically used in civil cases. The Supreme Court stated, "The district court erred when it applied a clear and convincing evidence standard to the parties’ competing declaratory judgment claims."
The court found that the lower court had incorrectly determined that the deeds were ambiguous and had ruled in favor of the Coffeys based on this misapplication of the burden of proof. The Supreme Court emphasized that the ambiguity in the deeds needed to be resolved before determining ownership and littoral rights.
Impact
This ruling has significant implications for property owners along Priest Lake and potentially other waterfront properties in Idaho. It clarifies the legal standards for proving ownership and littoral rights, which can affect how property disputes are resolved in the future. The decision reinforces the necessity for courts to carefully interpret property deeds and to apply the correct burden of proof when adjudicating such disputes.
Furthermore, this case highlights the importance of clear language in property deeds. Property owners may need to review their deeds and consider seeking legal advice to ensure their rights are adequately protected. The ruling may also encourage more property owners to pursue quiet title actions when faced with disputes over property boundaries.
What's Next
The case has been remanded to the lower court for further proceedings consistent with the Supreme Court's opinion. It remains to be seen how the lower court will address the ambiguities in the deeds and what the final outcome will be regarding the ownership of the disputed property. The Byrds and the Trust may also consider their options for appealing any future decisions that do not align with the Supreme Court's ruling.