Thomas Lunneborg, Plaintiff-Respondent v. My Fun Life, a Delaware Corporation, Edwards E. Edwards and Carrie L…

Summary

The Idaho Supreme Court affirmed a bench-trial judgment for a discharged chief operating officer: $60,000 in severance for termination without cause, trebled to $180,000 under the Idaho Wage Claims Act, plus $160,000 in attorney fees, with the corporate veil of My Fun Life pierced to reach sole shareholder Dan Edwards and, in a matter of first impression, non-shareholder executive Carrie Edwards. The Court adopted an objective good-faith standard for 'good cause' terminations and held the trial court's findings that the stated termination reasons were untrue, unreasonable, and pretextual were supported by substantial and competent evidence. It also clarified that Idaho's abuse-of-discretion test has four parts rather than three, held that stock ownership is not a prerequisite to veil piercing because control is the key factor, and sustained the fee award as a reasoned application of the civil-rule fee factors. Lunneborg received attorney fees and costs on appeal under the commercial-transactions fee statute.