A Custer County judge dismissed a defamation lawsuit filed by Idaho businessman and federal official Michael Boren on Friday, ruling that the case had sat dormant too long under state court rules and that Boren’s legal team had no valid excuse for the delay.

The Ruling

Judge Darren Simpson ordered the dismissal after finding that the case had gone without activity for more than 90 days, the threshold required under Idaho civil procedure rules to trigger a dismissal for inactivity. Boren’s attorney had argued that his client’s presidential nomination and subsequent Senate confirmation should count as an extenuating circumstance, but Judge Simpson rejected that reasoning outright.

“The justifications asserted by Boren or Boren’s attorney show nothing more than pure neglect of the case,” Simpson wrote in his ruling. The judge did leave open the possibility that the lawsuit could be refiled.

Background on the Dispute

Boren, a Boise entrepreneur who founded the financial software firm Clearwater Analytics, filed the defamation suit in 2022 against several individuals who had publicly opposed his efforts to build a private airstrip and obtain a helicopter landing permit on irrigated pasture near Stanley. The land sits partially within the Sawtooth National Recreation Area along the Salmon River, a location that drew scrutiny from neighbors and outdoor recreation advocates.

The defendants named in the suit include former Blaine County Commissioners Dick Fosbury and Sarah Michael, former Sawtooth Search and Rescue Commander Gary Gadwa, and filmmaker Jon Conti. Fosbury died in 2023. Boren’s ranch is located partially within the protected Sawtooth corridor, and critics had spoken out against his permit application in public forums and other settings.

President Trump appointed Boren as Under Secretary for Natural Resources and Environment at the U.S. Department of Agriculture on January 17, 2025. The Senate confirmed him later that year.

A Long-Running Legal Fight

The case has had a complicated procedural history. A previous judge dismissed it once before, and Boren appealed in 2023. Judge Simpson took over the matter last September and heard oral arguments in early June before issuing Friday’s ruling.

The litigation has also attracted attention as a potential example of a strategic lawsuit against public participation — a so-called SLAPP suit. Attorneys from the Foundation for Individual Rights and Expression argued on behalf of the defendants that the case fit that description, and a prior judge had written in 2023 that the lawsuit “appears to be a SLAPP suit.”

Idaho lawmakers passed an anti-SLAPP statute during last year’s legislative session, which is designed to give defendants in such cases an earlier mechanism to seek dismissal. That law took effect as the Boren litigation was still pending before Judge Simpson.

Defendants React

Gary Gadwa, the former search and rescue commander named as a defendant, welcomed the outcome. “I’m grateful to see the court dismiss this attack on my constitutional right to express my opinion about matters affecting my community,” he said.

The case drew sustained interest in part because it pitted a well-connected Idaho business figure — now a sitting federal official — against local government veterans and community advocates who had raised environmental and land-use concerns about development near a federally protected recreation area.

What’s Next

Judge Simpson’s ruling does not permanently bar Boren from pursuing the defamation claims, as the dismissal was based on procedural grounds rather than the merits of the underlying allegations. Whether Boren’s legal team chooses to refile remains to be seen. Any renewed effort would face fresh scrutiny under Idaho’s new anti-SLAPP law, which gives defendants stronger tools to challenge lawsuits they argue are designed to suppress public commentary.

The ruling adds to a growing body of post-session legal developments stemming from Idaho’s record-setting 2026 legislative session, which produced a range of new statutes now facing early tests in state courts.