Justia Idaho Supreme Court Opinion Summaries

Plaintiff Advanced Medical Diagnostics entered into a contract for services with Defendant Imaging Center of Idaho, LLC. Defendant stopped making payments and Plaintiff sued for damages for breach of contract. The matter was tried to a jury and the jury returned a special verdict finding that Plaintiff had proved its claim but was not entitled to damages because Defendant proved its affirmative defense. The trial court determined that Defendant was the prevailing party, and was awarded costs and attorney fees. Plaintiff appealed that award to the Supreme Court. After its review, the Supreme Court found no error in the trial court's decision and affirmed. View "Adv Medical Diagnostics v. Imaging Center of Idaho" on Justia Law

The issue before the Supreme Court in this case concerned the grant of summary judgment dismissing an action to enforce an oral agreement to guaranty the debt of another on the ground that the agreement was barred by the statute of frauds. Sunshine Secretarial Services subleased office space from Accelerated Paving, Inc., and at times provided it with secretarial services. Accelerated Paving owed Plaintiff-Appellant Mickelsen Construction, Inc. money ($34,980.00) for providing asphalt to an Accelerated jobsite. Mickelsen threatened to file a materialmen’s lien against the real property on which the work was being done, and Accelerated's vice president asked that it not do so because that would delay the receipt of payment for the construction job. The vice president offered to pay the debt with an American Express credit card, but Mickelsen responded that it did not accept American Express credit cards. There was disagreement as to what happened next: Accelerate's vice president said there was not enough credit on the card to fund the payment, but when Accelerated received payment for the project it would pay down the balance so that there was enough credit to pay Mickelsen with the card. Mickelsen agreed not to file the lien if Accelerated could find someone to guaranty the payment by the credit card. Defendant-Respondent Lesa Horrocks of Sunshine agreed to do so and gave Mickelsen a check in the amount owed, drawn on Sunshine's account. Sunshine had a credit card machine that was capable of transacting with several credit cards including American Express credit cards. They told her that American Express had approved the transaction and asked her to use Sunshine credit card machine to run the transaction. It appeared to her that the transaction had been approved by American Express. issued the check. Several days later, Accelerated informed her that American Express had not approved the transaction. Accelerated then filed for bankruptcy. Mickelsen then sued Ms. Horrocks and Sunshine alleging that they had agreed to guaranty the credit card payment and so issued the check. The Defendants filed a motion for summary judgment, arguing that the alleged guaranty was barred by the statute of limitations in Idaho Code section 9-505. In response, Mickelsen argued that the check was a sufficient writing under the statute of frauds and, if not, that the transaction was governed by Idaho Code section 9-506 and therefore exempt from the statute of frauds. The district court held that the check was an insufficient writing and that section 9-506 did not apply because the Defendants did not receive any direct benefit. The court granted the motion for summary judgment and entered a judgment dismissing this action. Mickelsen then appealed. Finding no error with the district court's decision, the Supreme Court affirmed. View "Mickelsen Const v. Horrocks" on Justia Law

Glenn Mosell was a commercial real estate broker in investment sales and a land developer who owned about 290 acres of property in Canyon County. He planned to develop this property and other land that he had an option to purchase into a destination resort which would include, among other things, resort-based residences; a state-of-the-art winery; a luxury 4-star boutique hotel; a world class day spa; a gourmet restaurant; an event and business conference center; polo fields; an equestrian center; a sporting and athletic club; and an amphitheater for music events and concerts. He contacted restaurateur John Berryhill to see if he would be interested in building the restaurant in the development. Berryhill was the owner and president of Berryhill & Company, which operated a restaurant and catering business. Berryhill agreed to participate in the proposed development, but not to build the restaurant. In 2007, Berryhill & Company signed a lease of space in downtown Boise in order to move his restaurant from a strip mall to that space. Mosell and Berryhill both signed a personal guaranty of Berryhill & Company's obligations under the lease. Berryhill & Company then began making tenant improvements to the leased property. Mosell Equities paid Berryhill & Company by check. The word "loan" was written on the memo line of the check. Over the next ten months, Mosell Equities issued nine additional checks to Berryhill & Company, each had the word "loan" written on the memo line except for two. The restaurant opened in August 2007. Because of the economic downturn, Mosell decided not to proceed with the polo project and did not launch the intended sales effort in 2008. Later that year, Mosell Equities stopped paying the rent on additional space, and Mosell and Berryhill ended their relationship. In 2009, Mosell Equities filed suit against Berryhill & Company on multiple claims: (1) breach of an express contract; (2) breach of an implied contract; (3) unjust enrichment; (4) conversion; (5) fraud; and (6) piercing the corporate veil. The case was tried to a jury, and the verdict was in favor of Berryhill. Mosell moved for judgment notwithstanding the verdict citing insufficient evidence, and the district court granted that motion. Upon review, the Supreme Court concluded that the district court erred in concluding that there was insufficient evidence to support the verdict, and that the district court erred in granting the motion for a judgment notwithstanding the verdict. The case was remanded for further proceedings. View "Mosell Equities v. Berryhill & Co." on Justia Law

Plaintiff-Appellant Gary Duspiva, a well driller, filed suit against Defendants-Appellees Clyde and John Fillmore to recover money that he claimed was owed to him for well drilling services. The Fillmores counterclaimed, alleging Duspiva violated the Idaho Consumer Protection Act (ICPA). The matter proceeded to trial. The district court found that Duspiva's conduct violated the ICPA and granted judgment in favor of the Fillmores. Duspiva appealed to the Supreme Court. Finding no error or abuse of discretion, the Supreme Court affirmed the trial court's decision. View "Duspiva v. Fillmore" on Justia Law

The issue before the Supreme Court in this case arose from a commercial lease dispute. Boise Mode, LLC leased space in its building to Donahoe Pace & Partners, Ltd. (DPP). Timothy Pace executed a personal guarantee for the lease. During the term of the lease, Boise Mode remodeled part of the building for another tenant. After raising concerns to Boise Mode about the adverse effects of the construction to its business, DPP eventually stopped paying rent and vacated the premises prior to the end of the lease. Boise Mode then brought an action against DPP, alleging breach of contract, and against Pace for breaching the guarantee. DPP counterclaimed, alleging that the disruption caused by the construction constituted breach of contract and constructive eviction. After Boise Mode moved for summary judgment on all claims and counterclaims, DPP requested a continuance to complete discovery. The district court denied DPP's motion and ultimately granted Boise Mode's motion for summary judgment. DPP appealed the grant of summary judgment as well as the district court's denial of its request for a continuance. Upon review, and finding no error, the Supreme Court affirmed. View "Boise Mode, LLC v. Donahoe Pace" on Justia Law

The issue before the Supreme Court in this case concerned an order granting summary judgment in an action to foreclose a mechanic’s lien by ParkWest Homes, LLC against Julie Barnson and Mortgage Electronic Services, Inc. (MERS). In "ParkWest Homes, LLC v. Barnson," (238 P.3d 203 (2010)) the Court held that ParkWest’s lien on the property in question was valid. After that, property encumbered by ParkWest's lien was conveyed to Residential Funding Real Estate Holdings, LLC via a trustee's sale. Residential intervened in this action and sought summary judgment. The district court dismissed MERS from the action and granted Residential summary judgment. It ruled that Residential took the property free and clear of ParkWest’s lien on the property, because neither Residential nor its predecessors-in-interest were named in this action. ParkWest appealed the district court’s grant of summary judgment. Upon review, the Supreme Court held that ParkWest's lien was lost as to Residential, because it failed to name any holders of legal title in its action to enforce the lien. The district court was therefore affirmed. View "ParkWest Homes v. Barnson" on Justia Law

The United States District Court for the District of Idaho certified a question of law to the State Supreme Court: whether a legal malpractice claim that is transferred to an assignee in a commercial transaction (along with other business assets and liabilities) is assignable under law. The issue stemmed from St. Luke's Magic Valley Regional Medical Center's purchase of Magic Valley Medical Center. Thomas Luciani and his law firm Stamper, Rubens, Stocker & Smith, P.S. represented Magic Valley in defending a wrongful termination and False Claims Act action brought by former hospital employees. After the sale of the medical center closed, Magic Valley no longer existed. The operation and management of the center was taken over by St. Luke's. St. Luke's then sued its former lawyer and law firm. The District Court noted that the assignability of a legal malpractice claim in the factual context presented had not yet been squarely addressed by the Idaho Supreme Court. Upon review, the Idaho Supreme Court answered the district court's question in the affirmative: although legal malpractice claims are generally not assignable in Idaho, where the legal malpractice claim is transferred to an assignee in a commercial transaction, along with other business assets and liabilities, such a claim is assignable. View "In re: St. Lukes Magic Valley RMC v. Luciani, et al." on Justia Law

Appellants Hobson Fabricating Corp. (Hobson) and SE/Z Construction, LLC (SE/Z) appealed a district court decision in their case against the State of Idaho, Department of Administration, Division of Public Works (DPW) regarding costs and attorney fees. Prior to the district court's decision, the parties had settled all of their claims but for costs and attorney fees. The district court declared that all parties had prevailed in part and were to bear their own costs and fees. Hobson and SE/Z appealed the decision, arguing that the district court abused its discretion and should have found that they were the overall prevailing party. Upon review, the Supreme Court affirmed the district court's order that the Contractors and DPW bear their own costs and fees and its order that Hobson pay the individual defendants' costs. View "Hobson Fabricating Corp v. SE/Z Construction" on Justia Law

Two real estate developers, a husband and wife, operated through various entities including a corporation and an LLC. In 2002, the corporation borrowed money from a lender; the developers, in their individual capacities, guaranteed this loan and all future advances. The corporation promptly repaid this loan. In 2005, the LLC twice borrowed money from the same lender. The lender originally insisted on a personal guaranty for these loans, but, in order to secure the developer's business, stated that no personal guaranty would be required. In 2006–07, the corporation again borrowed money from the lender in six separate loans. The corporation defaulted on these six loans, and, after the lender foreclosed on the real estate that served as collateral for the loans, the lender sued the developers for the deficiency. The district court granted the lender's motion for summary judgment, holding that the developers' affirmative defenses (1) were barred by the statute of frauds, (2) failed for lack of consideration, and (3) raised no genuine issues of material fact. The developers timely appealed to the Supreme Court. Upon review, the Court held that the developers' affirmative defenses were neither barred by the statute of frauds nor failed for lack of consideration. However, because none of those defenses raised a genuine issue of material fact, the Court affirmed. View "Washington Federal Savings v. Engelen" on Justia Law

Randy and Trudi Poole filed an action against Darin Davis, dba Darin Davis Construction (Davis), alleging breach of contract, breach of warranty, and fraud. Davis counterclaimed for breach of contract, unjust enrichment, and promissory estoppel. The jury found that the Pooles had prevailed only on the fraud claim and that Davis had not proved any of his counterclaims. The district court entered judgment in favor of the Pooles for damages on the fraud claim. The Pooles moved for attorney fees and costs, claiming that as the prevailing party in a dispute over a commercial transaction, they were entitled to fees pursuant to Idaho Code 12-120(3). The court determined that there was no prevailing party and denied the motion. The Pooles timely appealed, asking the Supreme Court to reverse the decision of the district court and find, as a matter of law, that the Pooles were the prevailing party and are entitled to attorney fees. Finding no error, the Supreme Court affirmed. View "Poole v. Davis" on Justia Law