Justia Idaho Supreme Court Opinion Summaries

The holders of the second priority mortgage, Ray and Susan Montierth brought a foreclosure action against the holders of the first priority mortgage, Hendrik Dorssers and Justice Prevails, LLC, (collectively “Dorssers”), and a variety of other parties with an interest in the real property. In their pleadings, Dorssers asserted that their priority interest as the holder of the first priority mortgage still prevailed over all other encumbrances. In Dorssers view, a payment made by the debtor—years after the statute of limitations had run on the mortgage—revived the previously stale claim to foreclose their first priority mortgage and reinitiated the statute of limitations under Idaho Code section 5-238. However, on summary judgment the district court concluded that Idaho Code section 5-238 only applied when the payment was made prior to the lapse of the statute of limitations. Accordingly, the district court granted summary judgment to the Montierths after finding that no payment had been made by the obligor prior to the lapse of the statute of limitations and concluding that Dorssers’ mortgage was unenforceable as a matter of law. The district court subsequently denied Dorssers’ motion for reconsideration and objection to the proposed judgment. Thereafter, the district court entered a judgment and decree of foreclosure in favor of the Montierths, which specifically stated: “[t]hat the [Montierths’] lien interest is superior in time to all other parties’ liens, except the mortgage of Hendrik Dorssers and Justice Prevails, LLC, which is time barred and therefor [sic], unenforceable.” On appeal, Dorssers argue the district court erred: (1) in concluding that the partial payments did not extend the statute of limitations for enforcement of the first priority mortgage under Idaho Code section 5-238; (2) in the alternative, in concluding that a junior lien holder could quiet title to a senior lien holder; and (3) in issuing an order to quash the lis pendens they recorded after the appeal was filed. The Idaho Supreme Court reversed, finding the district court erred in its determinations: (1) to revive the statute of limitations the payment must have been made prior to the lapse of the statute of limitations; (2) the “transfer of money” was not a payment in recognition of the debt as a matter of law; and (3) the payment was not made by an obligor as a matter of law. In addition, the Court found the district court erred in striking the lis pendens. The matter was remanded for further proceedings. View "Montierth v. Dorssers" on Justia Law

The issue this appeal raised concerned a default judgment awarded to Scott and Natalie Pinkham against appellants David Plate, Rebeccah Jensen, and their company, Three Peaks Homes, LLC. When Appellants’ attorney withdrew in the middle of the case, Appellants failed to timely designate new counsel as required by Idaho Rule of Civil Procedure 11.3. Accordingly, a default was entered by the district court. Later, the district court, using a form prepared by the Pinkhams’ attorney, awarded the Pinkhams a default judgment of almost $650,000 without: (1) the amount of damages being specified in the Pinkhams’ complaint; or (2) the presentation of any proof of the amount of damages the Pinkhams were claiming. Appellants later retained an attorney and attempted to set aside the default and the default judgment, asserting that both had been improperly entered. The district court denied both requests. Appellants appealed the district court’s denial of their motion to set aside the entry of default and default judgment against them. Finding that Appellants established a right to relief because the district court erred in awarding damages without any proof, the Idaho Supreme Court reversed in this respect. The Court found the district court did not err in denying the motion to set aside the entry of a default judgment, but vacated the default judgment and remanded for a determination as to the proper amount of damages based on the proof submitted. View "Pinkham v. Plate, et al." on Justia Law

In December 2019, Paul Hanks slipped and fell on a patch of ice after exiting a vehicle in the passenger unloading zone at the Boise Airport. Hanks sued defendants the City of Boise, Republic Parking System, LLC, and United Components, Inc. for negligence. Hanks argued that Defendants had a duty to maintain the airport facilities in a safe condition and that Defendants failed in that duty by not keeping the passenger unloading zone free of ice. Respondents the City of Boise and Republic Parking System, LLC moved for summary judgment, arguing they had met all legal duties owed to Hanks. The district court agreed and granted summary judgment. Finding that the district court did not err in its grant of summary judgment, the Idaho Supreme Court affirmed the district court. View "Hanks v. City of Boise" on Justia Law

Moranda Morley lost one of her two jobs due to the economic impact of the COVID-19 pandemic in March 2020. Morley applied for and received state unemployment compensation benefits and federal pandemic unemployment assistance through the Idaho Department of Labor. However, it was later determined that Morley was ineligible for benefits because she was still employed full-time at her other job. Morley appealed that determination to the Appeals Bureau of the Idaho Department of Labor, which affirmed her ineligibility. Morley then appealed to the Idaho Industrial Commission (“the Commission”), which dismissed Morley’s initial appeal and later denied her request for reconsideration, finding both to be untimely. Morley then appealed to the Idaho Supreme Court, but her notice of appeal was timely only as to the denial of her request for reconsideration. Thereafter, the Supreme Court issued an order dismissing the appeal as to the issues that were determined to be untimely. What remains was a limited review of whether the Commission properly denied her request for reconsideration. Finding no reversible error, the Supreme Court affirmed the Commission’s denial of reconsideration. View "Morley v. IDOL" on Justia Law

Respondent D.L. Evans Bank obtained a default judgment against Appellant Henry Dean in 2010. Pursuant to Idaho Code section 10-1111(1), D.L. Evans obtained orders renewing the 2010 Judgment in 2015 and 2019. In 2020, D.L. Evans filed this lawsuit, alleging a single claim for action on the 2010 Judgment and seeking a new judgment for the amount that Dean owed on the 2010 Judgment plus accrued interest, attorney fees, and costs. The district court concluded that D.L. Evans properly renewed the 2010 Judgment in 2015 and 2019, and that each renewal restarted the applicable six-year statute of limitations on D.L. Evans’ claim for an action on a judgment. Dean argued the district court erred because the limitation period on D.L. Evans’ claim began to run when the judgment was first issued in 2010. Dean also argued the district court erred in denying his motion to dismiss for lack of personal jurisdiction and denying his Idaho Rule of Civil Procedure 60(b)(4) motion to set aside the 2010 Judgment as void. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "D.L. Evans Bank v. Dean" on Justia Law

Facing foreclosure, Ralph and Paula Isom entered into a deed in lieu of foreclosure agreement with Farms, LLC (“Farms”). The Isoms then leased the real property (a farm and various houses) back from Farms, subsequently defaulted on their obligations under the lease agreement, and filed a Chapter 11 bankruptcy, which was later converted to a Chapter 7. During the Isoms’ bankruptcy, Farms also acquired several third-party claims against the Isoms from other independent creditors of the Isoms. The bankruptcy court denied the Isoms a discharge, and after the bankruptcy case closed, Farms sued the Isoms personally, alleging three counts of breach of contract. Following a one-day bench trial, the district court awarded Farms a judgment of $1,281,501.68 as to Count III—related to Farms’ purchase of the third-party claims—but concluded that Farms’ remaining two claims related to the lease were barred by the applicable statute of limitations. The Isoms appealed, arguing the district court erred in determining the applicable statute of limitations as to Count III. Farms cross-appealed, arguing the district court erred in applying the statutes of limitation as to Counts I and II. After review, the Idaho Supreme Court affirmed the district court’s judgment as to Count III but reversed and vacated the judgment on Counts I and II. View "Farms, LLC v. Isom" on Justia Law

This appeal was the second time before the Idaho Supreme Court. It involved the existence of a prescriptive easement and the presumption of permissive use. Shelley and Roger Cook owned a parcel of land which was originally owned by Shelley’s grandfather, John Harker Sr. The property stayed in the Harker family ever since. The Cooks filed suit against Jay and Shelli Van Orden alleging they had a prescriptive easement across the Van Ordens’ land (the “Van Orden Property”) via a road the parties call “Tower Road.” Tower Road connected the Cooks’ property to a county road and had been used by the Cooks and their predecessors in interest since the Cook Property was homesteaded in 1908. The district court initially entered judgment in favor of the Van Ordens after it determined the Cooks had failed to prove the necessary element of adverse use for a prescriptive easement. The Cooks appealed, and the Supreme Court reversed the district court’s decision, finding it was necessary for the district court to determine the statutory period of adverse use because “there were potentially periods of adverse use” that could satisfy “either the five-year or twenty-year period for establishing a prescriptive easement. On remand, the district court determined that the use of Tower Road by the Harkers was presumptively permissive prior to 1910 and that “nothing in the evidence [implies] that Harkers’ or Cooks’ permissive use of Tower Road . . . ever changed into an adverse use.” Nevertheless, the district court identified a statutory period from 1962 to 2006, and granted the Cooks’ prescriptive easement claim by concluding the period of statutory use was sufficiently adverse due to the common belief of the Harkers/Cooks and the Thompsons—the Van Ordens’ predecessors in interest—that the Harkers/Cooks had a right to use Tower Road. The Van Ordens appealed to the Supreme Court, contending the district court erred in granting the Cooks a prescriptive easement. The Supreme Court reversed, finding that the record supported the district court's conclusion that the Harkers’/Cooks’ permissive use of Tower Road never changed into an adverse use, and the district court erred in granting the Cooks a prescriptive easement. View "Cook v. Van Orden" on Justia Law

Plaintiffs Kiki Leslie Tidwell (“Tidwell”) and the Madison Jean Tidwell Trust opposed an affordable housing project on land dedicated to Blaine County, Idaho for public use. Plaintiffs contended the Final Plat contemplated the land be held for open space and recreational use, but Blaine County contracted with ARCH Community Housing Trust (“ARCH”) and Blaine County Housing Authority (“BCHA”) to donate a parcel ("Parcel C") to BCHA to construct community housing. Plaintiffs filed a complaint against the County, ARCH, and BCHA (collectively “the County”) seeking declaratory relief, injunctive relief, and damages to Tidwell under 42 U.S.C. 1983. The district court ultimately dismissed Tidwell’s section 1983 claim, but the district court allowed Plaintiffs to pursue the remaining claims, despite the County’s contention that Plaintiffs lacked standing to bring the complaint. Following a series of unsuccessful dispositive motions seeking summary and partial summary judgment on both sides, the case proceeded to court trial, where Plaintiffs prevailed on both claims for declaratory and injunctive relief. The district court denied Tidwell’s request for attorney fees. The County appealed, and Tidwell cross-appealed the dismissal of her section 1983 claim and both Plaintiffs appealed the district court’s denial of attorney fees. On appeal, the County again raised its standing argument, contending Plaintiffs had no particularized interest in the parcel and suffered no particularized injury. If Plaintiffs had standing, the County claimed the district court erred by concluding the Final Plat was ambiguous and by permitting extrinsic evidence, including testimony of what the parties intended to construct on the parcel when the land was transferred. The Plaintiffs cross-appealed, with Tidwell alleging the district court erred in dismissing her procedural and substantive due process claims brought under 42 U.S.C. 1983. Both Plaintiffs also contended the district court abused its discretion in denying their claim for attorney fees. The Idaho Supreme Court vacated the district court's judgment because Plaintiffs lacked standing to assert their claims. Costs, but not attorney fees, were awarded on appeal to the County. View "Tidwell, et al. v. Blaine County, et al." on Justia Law

Kyle and Ashley Fickenwirth and Amy Lanning (“Lanning”) owned adjoining properties at the center of this dispute. The Fickenwirths owned a gravel driveway that ran along the backside of Lanning’s property. Lanning had previously maintained a decorative split-rail fence on her property. Until recently, there was a relatively small strip of grassy land between the Fickenwirths’ driveway and the split-rail fence in Lanning’s backyard. This dispute arose when Lanning removed the split-rail fence and erected a new fence running directly along the western side of the Fickenwirths’ driveway that more closely adhered to the boundaries described in the deed. The Fickenwirths brought suit to quiet title to the strip of land between the split-rail fence on Lanning’s property and their driveway based on the theories of adverse possession or, alternatively, boundary by agreement. The district court concluded that the Fickenwirths had failed to prove their claims regarding adverse possession and boundary by agreement at the location of the split-rail fence. However, the district court found that the Fickenwirths had proved a claim of boundary by agreement at the location of the new fence, near the side of the driveway, but leaving a small strip of grass between the driveway and the fence. Lanning appealed this determination, claiming there was never an agreement that the boundary line was at the location of the new fence. After review and finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Fickenwirth v. Lanning" on Justia Law

The Idaho Department of Health and Welfare’s (“the Department”) cited Grace at Fairview Lakes, LLC (“Grace”), a residential assisted living and memory care facility, for failing to provide a safe living environment for residents and for inadequate training in relation to COVID-19 infection control measures. Grace requested administrative review of the enforcement action, which was affirmed by a Department administrator. Grace then filed an administrative appeal challenging the action, which was affirmed by a hearing officer. Grace then filed a petition for judicial review to the district court. The district court denied all the relief sought by Grace. On appeal to the Idaho Supreme Court, Grace argued the district court erred because the hearing officer’s decision was not supported by substantial evidence in the record as a whole. The Supreme Court found no error in the district court’s decision because there was substantial evidence in the record to support the hearing officer’s order. View "Grace at Fairview Lakes, LLC v. IDHW" on Justia Law