## Facts

- A debt collector obtained a default judgment against Jeff Lecheminant for $803.16.
- After the judgment, Jeff divorced and later married Sandy Lecheminant, who earned wages from her employer.
- The creditor sought to collect the judgment by garnishing Sandy’s wages.
- Sandy and her employer objected, relying on Idaho Code § 11-204, which exempted a “married woman’s” property and compensation from execution for her husband’s debts.
- The magistrate court upheld the exemption, and the district court affirmed on intermediate appeal.
- The creditor appealed, arguing § 11-204 violated equal protection and that community property (including the non-debtor spouse’s wages) could satisfy the debtor-spouse’s premarital debt; it also sought attorney fees under Idaho Code § 12-120(5).

## Issues

1. Whether the creditor had standing to challenge the constitutionality of Idaho Code § 11-204.
2. Whether Idaho Code § 11-204’s gender-specific exemption violated the Equal Protection Clause.
3. Whether, absent a valid exemption, community property (including the non-debtor spouse’s wages) could be used to satisfy a spouse’s antenuptial debt.
4. Whether the creditor could recover attorney fees under Idaho Code § 12-120(5) in enforcing the judgment.

## Decision

- The creditor had standing because § 11-204 directly impaired its ability to collect the judgment through garnishment.
- Idaho Code § 11-204 was unconstitutional under the Equal Protection Clause because it created a sex-based classification not justified by important governmental objectives under modern community-property law.
- With § 11-204 invalidated, the creditor could reach community property, including the non-debtor spouse’s wages, to satisfy the debtor-spouse’s premarital obligation.
- The creditor was entitled to attorney fees and costs under Idaho Code § 12-120(5).
- The court reversed the district court’s affirmance of the exemption and remanded for further proceedings.

## Legal Principles

- A party whose collection efforts are directly blocked by a statutory exemption has standing to challenge that statute’s constitutionality.
- A statute that exempts only married women’s wages or property from execution for their husbands’ debts is a sex-based classification subject to heightened scrutiny and violates equal protection absent an important governmental objective and a substantial relationship between means and ends.
- In Idaho, absent a valid statutory exemption, community property—including a non-debtor spouse’s wages—may be reached to satisfy the other spouse’s antenuptial debts.
- Idaho Code § 12-120(5) authorizes attorney fees in qualifying collection efforts and is not limited to traditional prevailing-party fee awards.

## Conclusion

The court invalidated Idaho Code § 11-204 as an unconstitutional gender-based exemption, permitted garnishment of community wages to satisfy a spouse’s premarital debt, and awarded the creditor attorney fees under Idaho’s collection-fee statute.


Credit Bureau of E. Idaho, Inc. v. Lecheminant, 149 Idaho 467, 235 P.3d 1188 (Idaho 2010)