Monitor Finance v. Wildlife Ridge Estates

Monitor Finance, L.C., and First Capital Funding, L.C., (collectively referred to as the Beneficiaries) were the holders of a deed of trust, which encumbered the real property claimed to be owned in fee simple by Wildlife Ridge Estates, LLC (Wildlife LLC). Prior to this judicial foreclosure action being brought, Wildlife LLC filed suit against the Beneficiaries seeking to quiet title to the real property. In that previous action, Wildlife LLC alleged that the Beneficiaries no longer retained an interest in the property because the debt underlying the promissory note had been paid in full. By stipulation of the parties, that quiet title action was ultimately dismissed with prejudice. Subsequently, the Beneficiaries initiated this action to foreclose the deed of trust based on their contention that the debt created by the promissory note had not been paid and was in default. The Beneficiaries moved the district court for summary judgment, contending that Wildlife LLC’s affirmative defenses and counterclaim were barred by res judicata because the previous quiet title action brought by Wildlife LLC had been dismissed on its merits. The district judge granted the Beneficiaries’ motion and denied Wildlife LLC’s motion to reconsider. In doing so, the district court summarily dismissed Wildlife LLC’s counterclaim and affirmative defenses. The district court ultimately entered summary judgment in favor of the Beneficiaries. Wildlife LLC appealed, claiming, among other things, that the district court misapplied the doctrine of res judicata. The Idaho Supreme Court diagreed, finding Wildlife LLC's affirmative defenses and counterclaim were correctly barred by res judicata. View "Monitor Finance v. Wildlife Ridge Estates" on Justia Law