According to this guide Active Record Querying
You can specify conditions on includes for eager loading like this
Person.includes(:notes).where("notes.important", true)
It recommends to use joins anyway.
A workaround for this would be to create another association like this
class Person < ActiveRecord::Base
has_many :important_notes, :class_name => 'Note',
:conditions => ['important = ?', true]
end
You would then be able to do this
Person.find(:all, include: :important_notes)