Justia Idaho Supreme Court Opinion Summaries

Jared and Katherine Sommer brought a declaratory judgment claim against Misty Valley, LLC, after receiving written notice that the real estate developer planned to use an express easement across the Sommers’ land for access to a recently platted residential subdivision. The Sommers contended the planned use constituted an impermissible expansion of the scope of the easement, and brought a claim to terminate the easement. After a bench trial, the district court limited the use of the easement to the dominant parcel, which only included part of Misty Valley’s planned subdivision, and declined to terminate it. Misty Valley appealed the district court’s judgment, and the Sommers cross-appealed. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Sommer v. Misty Valley, LLC" on Justia Law

Edward and Janice Easterling owned three contiguous parcels of real property in Ammon, Idaho. The Easterlings brought suit against Hal Pacific Properties, L.P. (“HAL”), claiming an easement by necessity over and upon HAL’s property in order to access their three merged parcels. Following cross-motions for summary judgment, a motion for reconsideration, and a short bench trial, the district court largely ruled in the Easterlings’ favor. The district court denied HAL’s affirmative defense that the Easterlings’ claims were barred by the statute of limitations. The district court further held that the Easterlings were entitled to an easement by necessity over and upon the HAL Parcel to allow access to all three of the Easterlings’ merged parcels. The district court placed the easement at the western border of the HAL Parcel and set its width at twenty-six feet. HAL appealed to the Idaho Supreme Court, contending the district court erred by denying its statute of limitations affirmative defense, granting the Easterlings’ claim for an easement by necessity for all three of their parcels, and improperly determining the location and width of the easement. The Supreme Court reversed the district court’s decision at summary judgment rejecting HAL’s statute of limitations defense under Idaho Code section 5-224. Because of this, the Court vacated the district court’s judgment and reversed its decisions that the Northern Parcel was entitled to an easement by necessity over the HAL Parcel; and that the width of the easement was set at twenty-six feet. The Supreme Court further reversed the district court’s decisions setting the location of the easement and granting an easement by necessity as to the Southern and Eastern Parcels over the HAL Parcel. The matte was remanded for further proceedings. View "Easterling v. Hal Pacific Properties, L.P." on Justia Law

Dennis and Sherrilyn Munden (the Mundens) and their limited liability company, Coyote Creek Ranch, LLC, purchased property in Bannock County, Idaho in 2012 (the Upper Property), and acquired adjoining property (the Lower Property) in 2014. The Mundens’ ranch was accessible by a gravel road (the Road) which left a paved public road before crossing the Lower Property. It then traversed a neighbor’s parcel to the Upper Property, before exiting to the north. The Mundens began ranching on the Lower Property in 2013 and started construction of a barn and living quarters on the Upper Property in 2015 after obtaining a three-year building permit. In 2017, the Mundens were informed by the Bannock County Commissioners that, pursuant to a 2006 county ordinance, the Road had been designated by the Commissioners for “snowmobile use only” between December 15 and April 15. All other vehicular use was prohibited during this timeframe. In January 2019, Bannock County passed an ordinance which gave discretion to the Bannock County Public Works Director (the Director) to determine when snowmobile trails would be closed to all but snowmobile use. Subsequently, the Director decided to close the Road for the 2018–19 winter season. The Mundens filed a complaint in district court against Bannock County, bringing several claims involving the Road, and obtained an ex parte temporary restraining order (TRO) to prohibit enforcement of the 2019 ordinance. The County moved to dissolve the TRO, which the district court granted. The district court then awarded attorney fees to the County. The Mundens amended their complaint to add their ranching operation, Coyote Creek Ranch, LLC, as a plaintiff, to which the County responded with an answer and counterclaim, alleging that the Road was a public right-of-way with no winter maintenance that had been designated as a snowmobile trail by the 2006 ordinance. The County then moved to dismiss the amended complaint for failure to state a claim. The district court granted this motion, concluding that because the claims turned on a legal determination of the Road’s status, the Mundens were required by Idaho Code section 40-208(7) to first petition for validation or abandonment proceedings with the Board of County Commissioners before they could bring a lawsuit. The district court accordingly entered a judgment dismissing the plaintiffs’ amended complaint in its entirety. Ultimately, the district court entered a judgment certified under IRCP 54(b)(1) authorizing an immediate appeal, and the Mundens timely appealed. The only error the Idaho Supreme Court found in review of this case was that the district court erred in issuing a writ of execution before there was a final appealable judgment. Judgement was affirmed in all other respects. View "Munden v. Bannock County" on Justia Law

Mike Von Jones (“Jones”) appealed the denial of his motion to set aside a sheriff’s sale and the award of attorney fees to Safaris Unlimited LLC (“Safaris”) under Idaho Code section 12-120(5). A jury found there was an enforceable contract between Jones and Safaris, and that Jones breached the contract. Safaris petitioned for and obtained a writ of execution requiring the sheriff to execute upon Jones’s personal and real property, including a pending lawsuit against Jeremy Sligar and Overtime Garage, LLC. At the sheriff’s sale, Safaris (the only bidder present) bought the lawsuit for $2,500.00 via a credit bid. Although Jones received notice of the sheriff’s sale, neither Jones nor his representative attended. Jones did, however, file a motion to set aside the sheriff’s sale of the Sligar Lawsuit. Then Safaris executed on additional personal property of Jones. The sale returned $8,300.00. While both Jones’s and Safaris’ appeals were pending, Jones tendered a $119,238.04 check to the clerk of the court in an attempt to satisfy the remainder of the amended judgment. The district court granted Safaris’ motion for release of funds and determined that the deposited funds were sufficient to satisfy the amended judgment. However, the district court found that the deposited funds exceeded the amount owed by $2,500.00 because Jones’s tender did not account for Safaris’ credit bid to purchase the Sligar Lawsuit. The district court held that Jones had not demonstrated a gross inadequacy of consideration because he failed to establish the litigation’s approximate value. Similarly, Jones failed to show very slight additional circumstances because he could not point to any procedural irregularities “pertaining to either the notice or conduct of the sale.” After denying Jones’s motion to vacate the sheriff’s sale, the district court ordered the clerk of the court to release the remaining $2,500.00 from the tender back to Jones or his attorneys. Jones timely appealed, arguing: (1) the district court erred by concluding Jones’s monetary tender to the clerk of the court did not preclude Safaris from claiming ownership of Jones’s pending lawsuit; (2) the district court abused its discretion by denying his motion to set aside the sheriff’s sale; and (3) the district court erred in awarding costs and fees pursuant to section 12-120(5) for actions taken after Jones’ tender to the clerk. Finding no reversible error, the Idaho Supreme Court affirmed the district court's orders. View "Safaris Unlimited, LLC v. Jones" on Justia Law

Appellants sued Respondents over alleged self-dealing and other purported breaches of fiduciary duty in the administration of a trust. Respondents argued that proceedings in Idaho were improper under the provisions of Title 15, chapter 7 of the Idaho Code (the “trust code”) because they alleged that the principal place of the Trust’s administration was in Indiana. The district court agreed and dismissed Appellants’ complaint. After review, the Idaho Supreme Court determined the district court erred in granting the motion to dismiss. Judgment was reversed and the matter remanded for further proceedings. View "Allen v. Campbell" on Justia Law

In July 2015, R.N. went boating on Lake Coeur d’Alene with his friends, C.N. and B.L. All three boys were sixteen years old at the time. The boat was owned by C.N.’s father. C.N., B.L., and R.N. obtained about 12 beers from an unknown source and consumed them while boating. Later, the boys stopped at Shooters, a restaurant and bar near the south end of the lake. Respondent Tracy Lynn allegedly provided C.N., B.L., and R.N. with an alcoholic drink known as a “Shooter sinker” (also known as a “derailer”). The boys left the restaurant and drank the derailer on the lake. At some point during the trip, R.N. jumped or fell off the boat into the water and drowned. Appellant-plaintiffs Brandi Jones (R.N.'s mother), and Dasha Drahos (R.N.'s sister) filed a complaint against Lynn, alleging she recklessly and tortiously caused R.N.’s death by providing him with alcohol before he drowned in Lake Coeur d’Alene. Lynn moved for summary judgment, asking the district court to dismiss the case because the Plaintiffs failed to comply with the notice requirements under Idaho’s Dram Shop Act. The district court agreed and granted Lynn’s motion for summary judgment after concluding there was no uniform body of federal maritime dram shop law that would preempt Idaho’s Dram Shop Act. Thus, the Plaintiffs had to comply with the Dram Shop Act’s notice requirements. The Plaintiffs appealed to the Idaho Supreme Court. Finding that the district court correctly applied with the Idaho Dram Shop Act after concluding the Act did not conflict with any uniform federal common law, and that the district court did not err in finding Appellants' claims were barred because they did not comply with the Dram Shop Act, the Supreme Court affirmed the grant of summary judgment. View "Jones v. Lynn" on Justia Law

Peyton Gifford and Mollie Gabaldon (“Parents”) filed a complaint as individuals, guardians ad litem for their son, and putative class representatives, alleging that the West Ada Joint School District #2 (“West Ada”) illegally charged tuition fees for the second half-day of kindergarten instruction. The district court dismissed Parents’ complaint for lack of standing because Parents did not pay the allegedly illegal fees. On appeal, the Idaho Supreme Court held that although the district court properly concluded that Parents lacked standing to pursue a claim based solely on an economic injury, it failed to consider whether Parents had standing to assert a second, discrete injury: loss of educational opportunity for their son. Accordingly, the Court concluded Parents had standing to pursue their educational claims. View "Gifford v. West Ada Joint School District #2" on Justia Law

The issue this appeal presented for the Idaho Supreme Court's review centered on a farm lease between Walker Land & Cattle, LLC, (“Walker”) and Sometimes a Great Notion Land and Cattle Company (“SAGN”). The lease agreement required Walker, as tenant, to obtain insurance coverage on “improvements” to the Ririe Farm, which SAGN, as landlord, contended included the property’s five irrigation pivots. The district court granted summary judgment to SAGN, concluding that under the lease agreement irrigation pivots were improvements and Walker defaulted on the lease by failing to provide insurance on the pivots. On appeal, Walker raised several related issues, primarily contending that genuine issues of material fact barred granting summary judgment. Finding no reversible error, however, the Idaho Supreme Court affirmed the award of summary judgment by the district court. View "Stanger v. Walker Land & Cattle" on Justia Law

Brent Meyer appealed pro se a district court’s judgment granting Adam Walker’s breach of contract claim against him. Walker hired Meyer to assist him with the demolition and remodel of a home he had purchased in Soda Springs, Idaho. Walker alleged that in June 2018, the parties entered into an agreement in which Walker agreed to pay Meyer $18,000 in exchange for Meyer’s labor on the home. This contract was subsequently modified by the parties as Meyer performed work on other areas of the home not covered by the contract and Walker paid Meyer more money than provided in the original contract – roughly $60,000. On October 16, 2018, Walker fired Meyer from the job, alleging the labor was not up to industry standards and did not add value to the home. Walker hired another contractor to fix or redo the work completed by Meyer and his subcontractors. Meyer argued the district court erred in concluding he was not a “construction professional” as defined by Idaho’s Notice and Opportunity to Repair Act (“NORA”), Idaho Code sections 6-2501–04, and claimed the case should have been dismissed because Walker failed to comply with the notice requirement of NORA. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Walker v. Meyer" on Justia Law

Eric Christiansen filed a nine-count complaint against respondents, Michael Moser and Potlatch #1 Financial Credit Union (“P1FCU”), following a decision by the Lewiston Roundup Association (“LRA”) to discontinue contracting with Christiansen to produce motorsport events at the LRA’s facility. The complaint alleged that Moser, a P1FCU employee and LRA member, improperly accessed information from Christiansen’s P1FCU account and shared it with the LRA so that it could recreate his business model and produce motorsport events without him. The district court granted summary judgment in the Respondents’ favor on each of Christiansen’s claims. Christiansen appealed, arguing that the district court erred in granting summary judgment because it failed to rule on Christiansen’s motion to compel discovery, failed to grant Christiansen more time to complete discovery, and failed to conclude that genuine issues of material fact precluded dismissal of four of Christiansen’s claims. The Idaho Supreme Court concluded after review that the district court abused its discretion by failing to decide Christiansen’s motion to compel discovery before considering the Respondents’ motions for summary judgment. Accordingly, judgment was reversed and the matter remanded for further proceedings. View "Christiansen v. Potlatch #1 FCU" on Justia Law