Estate of Kalinski v. Murphy Law Office PLLC

── Estate of Kalinski v. Murphy Law Office PLLC ── Court: Idaho Supreme Court Date: May 05, 2026 Category: General IN THE SUPREME COURT OF THE STATE OF IDAHO Docket No. 52242 THE ESTATE OF LAUREL ANN KALINSKI ) through the Personal Representative ) CRYSTAL MARIE KALINSKI, ) ) Plaintiff-Appellant, ) ) v. ) ) Boise, February 2026 Term MURPHY LAW OFFICE, PLLC, an Idaho ) professional limited liability company; ) Opinion Filed: May 5, 2026 MICHAELINA BRADY MURPHY, a real ) person, ) Melanie Gagnepain, Clerk ) Defendants-Respondents, ) ) and ) ) DOES 1 through 10, ) ) Defendants. ) Appeal from the District Court of the Fourth Judicial District, State of Idaho, Ada County. Cynthia Yee-Wallace, District Judge. The judgment of the district court is affirmed. Smith Horras, P.A., Boise, for Appellants. William L. Smith argued. Duke Evett, PLLC, Boise, for Respondents. Emma C. Nowacki argued. _____________________ MEYER, Justice. This is an appeal from an order granting summary judgment in favor of Murphy Law Office, PLLC, and Michaelina B. Murphy (Murphy) on all claims brought by the Estate of Laurel A. Kalinski, through its personal representative, Crystal M. Proctor, formerly known as Crystal M. Kalinski (the Estate). The Estate alleged causes of action for negligence or legal malpractice, breach of contract, violation of the Idaho Consumer Protection Act (ICPA), and unjust enrichment. On appeal, the Estate challenges only the dismissal of the unjust enrichment and ICPA violation claims. We affirm because unjust enrichment is not a cause of action independent from the Estate’s 1 legal malpractice claim since they were both based on the same alleged misconduct. In addition, the Estate failed to show evidence of unfair or deceptive acts as required by the ICPA. I. FACTUAL AND PROCEDURAL BACKGROUND A. Factual Background. Laurel Kalinski passed away in August 2019, leaving her children, Crystal and Nicholas Kalinski, as her sole heirs. The Estate consisted of only two assets: a Jeep and a house in Nampa, Idaho (the Property), where Crystal shared a home with her mother. Laurel’s final months were shadowed by stage 4 cancer, medical bills, and increasing debt on her car and house. Despite that, Crystal and Nicholas received “significant life insurance proceeds and retirement accounts” outside of the Estate, which were “[j]ust under a half million dollars.” Laurel’s Will named Crystal as the personal representative of the Estate, directed that the Property and the vehicle be sold, the debt on each paid, and the residue used to pay other debts before splitting whatever remained equally between Crystal and Nicholas. To navigate probate, Crystal, as personal representative, initially hired the attorney who drafted Laurel’s Will to advise and represent the Estate. After the Jeep was repossessed by the lienholder, Crystal and Nicholas were referred to Murphy, another attorney, by an accounting firm. On November 14, 2019, Murphy met with them for a consultation. Before meeting with Murphy, Nicholas agreed that Crystal could remain on the Property, refinance it, and pay him half the equity upon the Estate’s settlement. To avoid selling t