Gretchen Hyde v. Robert and Rochelle Oxarango

15. Gretchen Hyde v. Robert and Rochelle Oxarango

Citation: 2026 WL 478542 (Idaho Feb. 20, 2026), Docket No. 51625

Relevant Facts

• James and Jan Little gradually transferred assets and control over a family farm and ranching business to their daughter Rochelle Oxarango and her husband Robert over 13 years.

• The business was managed by the David Little Family Limited Partnership; various family members owned shares.

• In April 2015, James assigned 50% of general partnership units to the Oxarangos, making them general partners.

• In 2015, 2017, and 2020, the Oxarangos purchased grazing land near Donnelly, Idaho (the “Roseberry Property”).

• Hyde and Reaney (the Littles’ other daughters and limited partners) filed suit alleging breach of fiduciary duty, usurpation of business opportunity, and seeking expulsion of the Oxarangos as general partners.

• The district court dismissed for failure to state a claim.

Legal Issues

Whether Hyde and Reaney had standing to bring derivative and direct claims; whether the Oxarangos breached fiduciary duties as general partners; whether a “special” family member fiduciary duty exists under Idaho law; and whether the statute of limitations barred the 2015 and 2017 claims.

Positions of the Parties

Hyde reaney: The Oxarangos breached fiduciary duties through loyalty appropriation of partnership opportunities; a heightened “special duty” exists between family members; the Roseberry Property was a partnership opportunity; they suffered personal injury to inheritance rights.

Oxarangos: Hyde and Reaney lacked standing; alleged injuries were not distinct from injury to the partnership; no “special duty” for family members exists; statute of limitations barred earlier claims; derivative pleading requirements were not met.

Decision of the Court

AFFIRMED. The dismissal of all claims was upheld; Oxarangos awarded costs and attorney fees on appeal.

Reasons for the Decision

• For direct claims, Hyde and Reaney could not demonstrate injury distinct from injury to the partnership.

• Idaho law does not recognize a “special family member fiduciary duty” separate from statutory fiduciary duties under the Uniform Limited Partnership Act.

• The 2015 and 2017 claims were barred by the statute of limitations.

• The Roseberry Property acquisition was not shown to be a partnership opportunity; the district court noted it would have been “very unusual” for the partnership.

• Derivative pleading requirements (demand on general partners, specific particularity) were not met.

• The appeal was found frivolous, unreasonable, and without foundation.