Printcraft Press, Inc. v. Sunnyside Park Utilities, Inc.
This case arose from a dispute regarding the sewer system serving Sunnyside Industrial Park, LLC. Sunnyside Park Utilities (SPU) provides water and sewer services to the industrial park and Doyle Beck and Kirk Woolf are, respectively, the Secretary and President of SPU. Printcraft Press, Inc. (Printcraft) is a printing business that occupies a building in the industrial park. In 2004, Printcraft entered a ten-year lease for property in the industrial park. The dispute in this case centered on the failure of Beck, Woolf, and SPU to disclose limitations on the sewage system, including the amount of sewage the system could handle and its lack of suitability to dispose of some chemicals used in the printing business. After Printcraft started using the sewage system, SPU disconnected Printcraft from the system in December 2006. Printcraft sued SPU, Beck, and Woolf (collectively, defendants) for breach of contract, fraudulent nondisclosure, and fraud. At trial, the jury found that the defendants owed Printcraft a duty to disclose the limitations of the system and failed to do so. The trial court denied the defendants' motion for judgment notwithstanding the verdict (JNOV) and entered judgment in favor of Printcraft. Defendants timely appealed and Printcraft cross-appealed. However, in 2009, SPU filed a renewed motion for relief from judgment under Idaho Rule of Civil Procedure 60(b), asserting newly discovered evidence regarding whether Printcraft's damages claim was affected by its subsequent connection to the Idaho Falls city sewer system. The district court found that the newly discovered evidence satisfied the requirements of I.R.C.P. 60(b) and granted a new trial on the issue of damages. On appeal, the defendants argued that they had no duty to disclose, that any failure to disclose did not lead Printcraft to believe any fact that was false, that the refusal to give SPU's requested jury instructions was improper, and that the district court erred in denying their motion for JNOV because there was not sufficient evidence to support the jury's determination of damages. In turn, Printcraft's cross-appeal argued that the district court erred in limiting the potential bases for defendants' duty to disclose, that Printcraft's breach of contract claim was improperly dismissed, that the subsequent Rule 60(b) motion was improperly granted, that the issue of punitive damages should have been submitted to the jury, and that the judge erred in denying Printcraft's request for attorney fees. Upon review, the Supreme Court reversed the district court's grant of SPU's motion under 60(b)(2). The Court affirmed the denial of defendants' motion for JNOV as to the existence and breach of a duty to disclose and as to the amount of damages. The Court found that the district court did not abuse its discretion in excluding the jury instructions. And the Court affirmed the district court's decision to deny Printcraft's request to put the question of punitive damages to the jury. View "Printcraft Press, Inc. v. Sunnyside Park Utilities, Inc." on Justia Law