Justia Idaho Supreme Court Opinion Summaries

American West Enterprises appealed a district court's grant of summary judgement to Case New Holland, Inc. (CNH) in its effort to recover the cost of a remanufactured tractor engine CNH sold to a local seller that American West purchased. The district court dismissed American West's claim of implied warranty because there was no privity between American West and CNH. The district court also rejected American West's claims that it was an intended third party beneficiary of a contract between CNH and Pioneer and that Pioneer was an agent of CNH. American West appeals. The district court denied CNH's request for attorney fees and costs below. CNH cross-appealed. Finding no error, the Supreme Court affirmed all but the denial of attorney fees. The case was remanded to the district court for finding costs and fees in favor of CNH. View "American West Ent. v. CNH, LLC." on Justia Law

This appeal involves the transfer of the experience rating account for unemployment tax purposes from one employer to another pursuant to Idaho Code section 72-1351A(1)(a). After an investigation, the Department of Labor determined that the experience rating account of Diamond Z Trailer, Inc. (Diamond Z), which ceased operating in the spring of 2010, was transferred to Rule Steel Tanks, Inc. (Rule Steel), which hired the majority of the employees who were laid off by Diamond Z and which commenced marketing and manufacturing the same product that was manufactured by Diamond Z. Rule Steel appealed that determination. Finding no reversible error, the Supreme Court affirmed. View "Rule Steel Tanks, Inc. v. Dept of Labor" on Justia Law

BV Beverage Company, LLC appealed the dismissal of its petition regarding the expiration of its liquor license. Idaho Alcohol Beverage Control (ABC) contended that BV Beverage's interest in its license expired by operation of law when BV Beverage's lessee failed to timely renew. BV Beverage argued that the agency’s procedures deprived it of adequate procedural due process. The district court dismissed BV Beverage's petition because there was no agency action to review; even if there was agency action, the action did not violate procedural due process because BV Beverage had actual knowledge of the expiration date of the liquor license. Finding no reversible error, the Supreme Court affirmed. View "BV Beverage Company v. Idaho Alcohol Beverage Control." on Justia Law

Monsanto, through a wholly owned subsidiary, owns a quartzite mine near Soda Springs. Monsanto and Washington Group International, Inc. (WGI) contracted with each other for WGI to operate the mine. This agreement was memorialized in an agreement set to expire at the end of 2002. A by-product of WGI's operations was silica sand. Silicon International Ore, LLC (SIO) contacted Monsanto about acquiring the sand. SIO presented Monsanto with a proposed contract, but that contract was never executed. However, Monsanto and WGI executed an Addendum to the agreement that authorized WGI to construct and operate a processing facility for silica sand at the quartzite mine and to pay Monsanto royalties for silica that was sold by WGI to a third party. SIO and WGI executed a Master Agreement, under which WGI agreed to provide silica sand to SIO; SIO agreed to pay for the construction of the processing facility for the silica sand; SIO agreed to pay WGI to dry, screen, and bag the silica sand; SIO agreed to pay WGI an additional amount for processed sand; and WGI agreed to load the bagged silica sand onto SIO trucks. Shortly before the First Quarzite Agreement was set to expire, Monsanto and WGI executed a second Quarzite Agreement and addendum. The Second Addendum was almost identical to the First, but provided that WGI would pay Monsanto different amounts for sand based on several considerations and that the "[t]itle to the silica sand sold by SIO shall pass directly from [Monsanto] to SIO upon processing . . . subject to payment." WGI notified SIO that it would no longer be providing SIO with silica sand after the end of the year. After discussions with SIO, SIO was permitted to continue processing and bagging sand through April 29, 2008. SIO dismantled its operations in the quarry and removed its building and equipment. The following year, SIO sued Monsanto and WGI for damages for violating and interfering with an alleged verbal agreement to continue processing silica sand. SIO alleged that it and Monsanto entered into a verbal agreement separate and apart from the Master Agreement for the sale of silica sand. SIO asserted breach of the alleged verbal agreement, breach of the implied covenant of good faith and fair dealing, equitable estoppel, and quasi-estoppel. Monsanto denied SIO's claims and asserted the statute of frauds as an affirmative defense. Against WGI, SIO claimed that WGI breached the covenant of good faith and fair dealing implied into the Master Agreement, and SIO alleged that WGI tortiously interfered with the alleged verbal agreement between SIO and Monsanto. Monsanto and WGI moved to dismiss, which were ultimately granted by the trial court. Finding no reversible error, the Supreme Court affirmed. View "Silicon Int'l v. Monsanto Co." on Justia Law

Black Rock Development, Inc. developed a planned unit development consisting of residential homes and a golf course on the shore of Lake Coeur d'Alene. Black Rock Development recorded covenants, conditions, and restrictions (CC&R's) applicable to the development. The CC&R's created the position of "Declarant," named Black Rock Development as the Declarant, stated the rights of the Declarant, defined the time period that the Declarant would be entitled to exercise those rights, and specified the qualifications for a "Successor Declarant." The golf course in the development was developed and owned by The Club at Black Rock, LLC. The Club conveyed its real property to the Washington Trust Bank in lieu of foreclosure. Black Rock Development also assigned to the Bank all of its rights and interests as the Declarant under the CC&R's. The Bank then assigned the real property and the Declarant rights to West Sprague Avenue Holdings, LLC. West Sprague deeded the real property and assigned the Declarant rights to an entity named The Golf Club at Black Rock, LLC, which was a different entity than The Club. Black Rock Development assigned to The Golf Club any Declarant rights that Black Rock Development may still have retained due to any procedural or substantive defect in the prior assignments. Plaintiffs, who are the owners of at least one lot in Black Rock and are members of the Black Rock Homeowner's Association, Inc., filed this action against The Golf Club seeking a declaratory judgment that it was not qualified to be a Successor Declarant and therefore could not exercise Declarant rights. Both sides moved for summary judgment on the issue of whether The Golf Club satisfied the requirements of being a Successor Declarant under the CC&R's. The district court held that it did. It therefore dismissed the complaint and awarded court costs, including attorney fees, against Plaintiffs. Plaintiffs then appealed. Upon review, the Supreme Court concluded The Golf Club did not qualify as a Successor Declarant; it did not take title to Property for the purpose of sale and development. Because The Golf Club did not qualify as a Successor Declarant, it could not exercise the rights or powers of a Declarant. Therefore, the Supreme Court reversed the district court's judgment, including its award of costs and attorney fees to The Golf Club. View "Sky Canyon Properties, LLC v. The Golf Club at Black Rock, LLC" on Justia Law

Judgment creditor PAL I, LLC levied and executed upon collateral in which KeyBank had a perfected security interest. PAL argued that because KeyBank did not file a third-party claim to the collateral in accordance with I.C. 11-203, it waived its interest in the collateral. The district court held that a perfected security interest survives a creditor's failure to comply with the statute, that KeyBank's security interest extended to the proceeds PAL realized from the sheriff's sale of the collateral, and that KeyBank was entitled to judgment against PAL in that amount. PAL appealed to the Supreme Court. Finding no error, the Supreme Court affirmed. View "Keybank Nat'l Assoc v. Pal I, LLC" on Justia Law

At the heart of this appeal was a mechanic's lien filed against the Black Rock North Development in Coeur d?Alene, Idaho, and an uncompleted golf course community development. American Bank (the Bank) was the lender to BRN Development, Inc. (BRN). BRN hired Wadsworth Golf Construction Company of the Southwest (Wadsworth) to construct a golf course. BRN failed to pay Wadsworth for a portion of the work it performed, and Wadsworth filed a mechanic's lien against the property. BRN defaulted on the loan, and the Bank initiated foreclosure proceedings. Wadsworth's claim of lien was subordinate to the Bank's mortgage interest in the property. In order to proceed with a foreclosure sale, the Bank posted a lien release bond in order to secure the district court's order releasing Wadsworth's lien. The Bank was the successful bidder at the foreclosure sale. The district court ruled that priority of the parties? claims against the property was irrelevant once the property was replaced by the lien release bond as security for Wadsworth's claim and the Bank (by way of the bond) was responsible for payment of Wadsworth's lien claim. The Bank appeals that decision, arguing that Wadsworth should have been prevented from recovering against the lien release bond because its interest would have been extinguished if it had attempted to foreclose its mechanic's lien and the bond merely served as substitute security in place of the property. Wadsworth cross-appealed, arguing the district court erred in holding that Wadsworth waived its right to file a lien for the unpaid retainage on the contract. Upon review, the Supreme Court reversed the district court allowing Wadsworth to recover against the lien release bond and vacated the district court's judgment in favor of Wadsworth. View "Americn Bank v. Wadsworth Golf" on Justia Law

The underlying dispute in this matter centered on the sale and demolition of a bridge across the Ohio River between West Virginia and Ohio. Advanced Explosives Demolition, Inc. (AED) entered a contract to sell the bridge to KDC Investments, LLC (KDC) for $25,000. AED alleged that it also entered into another contract in which KDC hired it to perform explosive demolition work prior to removal of the bridge. After the bridge sale was complete, KDC terminated its relationship with AED and hired another demolition contractor. AED brought an action for fraud and breach of contract against KDC and asked the district court to rescind the sales contract. The district court denied the request for rescission and granted summary judgment in favor of KDC on the fraud and breach of contract claims, holding that AED had provided no evidence of fraud and concluding that the demolition contract was illegal because AED did not have the necessary West Virginia contractor's license when it entered into the contract. AED appealed the district court's denial of its request. The Supreme Court held that AED waived the issue of whether the district court abused its discretion in striking certain affidavits presented at trial. However, the Court affirmed the district court's grant of summary judgment in favor of KDC and the district court's order quieting title to a Toll Bridge in KDC. View "AED, Inc v. KDC Investments" on Justia Law

This appeal stemmed from Native Wholesale Supply Company's (NWS) cigarette sales to Warpath, Inc. NWS is an Indian retailer organized under the tribal laws of the Sac and Fox Nation. It operates on the Seneca reservation in New York. Warpath is an Idaho corporation that operates on the Coeur d'Alene reservation. The State of Idaho brought suit against NWS for acting as a cigarette wholesaler without a permit and for selling cigarettes that are unlawful for sale in Idaho. The district court enjoined NWS from selling wholesale cigarettes in Idaho without a wholesale permit and assessed civil penalties in the amount of $214,200. NWS appealed that decision, arguing the State did not have subject matter jurisdiction or personal jurisdiction. Upon review, the Supreme Court affirmed in part, reversed in part, and remanded to the district court for further proceedings. The Court found that NWS's sales to Warpath were exempt from Idaho taxation, and NWS was not required to obtain a wholesale permit. Furthermore, the State had subject matter over NWS's importation of non-compliant cigarettes into the State of Idaho, and that the State could validly exercise personal jurisdiction over NWS. View "Idaho Tax Commission v. Native Wholesale Supply" on Justia Law

Albar, Inc. owned a convenience store, gas station and marina on the Pen Orielle River. In 2003, one of its three underground storage tanks leaked gasoline into the surrounding soil. The tanks were insured through the State's Petroleum Storage Tank Fund. Albar ultimately entered into a consent agreement with the State Department of Environmental Quality to remediate the property and any impacted adjacent properties. In 2005, Albar put the businesses up for sale. Albar made a disclosure regarding the 2003 leak, but that statement would later be found false. JLZ Enterprises was interested in purchasing the property, and relied on the false disclosure. In 2007, JLZ Enterprises sued Albar to recover damages for fraud and breach of contract; to rescind the contract; and to recover damages for negligence against the real estate agent and the broker. The matter was tried to the district court. After hearing the evidence, the court declined to rescind the real estate contract, but found that Albar had breached the contract. The court entered a judgment forclosing the deed of trust on the property and ordering its sale. Albar appealed the grant of JLZ's motion to disallow its costs and attorney fees. Upon review, the Supreme Court found that the district court's decision finding Albar breached the contract was supported by substantial and competent evidence, and that it was not an error for the court to disallow Albar's costs and fees. View "Echo Vanderwal v. Albar" on Justia Law