Bryan D. Smith v. Chris Poulter in His Capacity as Bonneville County Clerk

Summary

The Idaho Supreme Court reversed summary judgment for the county clerk, holding that quasi-judicial immunity does not bar an official-capacity action. It further held that the administrative fee schedule conflicted with the governing court rule and statutory fee limits, determined that Smith was overcharged by $330.67, and directed a refund. The Court also awarded Smith costs on appeal.