Justia Idaho Supreme Court Opinion Summaries

Roger and Barbara Stephens owned a parcel of real property consisting of about 270 acres on the west side of the highway and another parcel consisting of about 83 acres on the east side of the highway. They hired a realtor to sell the parcel on the west side of the highway. The realtor asked Northern Title Company of Idaho, Inc., to begin the initial title work for a sale of the property, including preparing a legal description for the sale of the parcel on the west side of the highway. Stephen Cummings noticed a "For Sale" sign on the Stephenses' property. Cummings negotiated to purchase the Stephens' property. He was faxed a copy of the commitment for title insurance issued in connection with the transaction. The legal description in the document included the Stephenses' property on both sides of the highway and two additional parcels they did not own. Based upon the legal description in those documents, Cummings believed that the property being sold included both parcels of the Stephenses' property. Northern Title discovered that the legal description it had prepared for use in the real estate contract and its title commitment for that transaction erroneously included the Stephenses' real property located east of the highway and two parcels of land they did not own. The legal description consisted of five paragraphs, each describing a separate parcel of real property. In an effort to correct that error, Northern Title created a revised legal description by inserting between the first and second paragraphs the words, "Except all of that portion of the following described land lying easterly of U.S. Highway 30." That change excluded the two parcels of property not owned by the Stephenses, but it did not exclude their land lying east of the highway because it was described in the first paragraph. On the date of closing, Northern Title recorded a warranty deed (Original Deed) granting to Cummings the real property described in the revised legal description, which was attached to the deed as Exhibit A. The legal description included the Stephenses' property on the east side of the highway. Mr. Stephens went to the county courthouse to pay the real estate taxes on the 83 acres of land east of the highway and was informed that he no longer owned that property. Cummings filed this action against Mr. Stephens over the erroneous deed. Stephens answered, denying Cummings's claims, and filed a third-party claim against Northern Title. He later dropped his third-party claim in exchange for Northern Title agreeing to indemnify him from any losses. Stephens then filed a motion for summary judgment, contending that there was a mutual mistake or a unilateral mistake in the legal description of the real property being sold. The district court held that there was a genuine issue of fact regarding mutual mistake, but it granted the motion on the ground that the undisputed evidence showed a unilateral mistake. One of the realtors had filed an affidavit stating that prior to the sale he had told Mr. Cummings that only the land west of the highway was being sold, and Mr. Cummings did not deny that fact. Cummings successfully moved for reconsideration, with the district court finding that there was a genuine issue of material fact as to what Cummings had been told about what property he was purchasing. Cummings then amended his complaint, adding Northern Title as a defendant and alleging that by recording the Correction Deed, Stephens and Northern Title breached the warranties of title in the Original Deed, converted the 83 acres lying east of the highway, and slandered Cummings's title to the real property. The district court granted Stephens's motion for involuntary dismissal as to all of the claims against him. And in its written findings of fact and conclusions of law, the district court denied all of Cummings's claims against Northern Title except one. It found that Northern Title acted negligently as a title and abstract company, and it awarded Cummings damages in the sum of $50,000, which was the sum he had paid to obtain an assignment of its contract to purchase the Stephenses' property. The court awarded Mr. Stephens costs and attorney fees against Cummings, and it awarded Mr. Cummings costs and attorney fees against Northern Title. Mr. Cummings appealed and Northern Title cross-appealed. The Supreme Court affirmed the dismissal of Cummings' claims against Stephens, and reversed claims against Northern Title on the ground that it assumed the duty of being an abstractor of title. View "Cummings v. Stephens" on Justia Law

This appeal stemmed from a fraud, breach of contract, and breach of warranty action brought by April Beguesse, Inc. (ABI) against defendants Kenneth Rammell, the estate of Christa Beguesse, and Christa Beguesse, Inc. (CBI), and a breach of contract counterclaim brought by CBI against ABI. The parties went to trial and the jury returned a verdict in favor of ABI on all claims. Defendants moved for a judgment notwithstanding the verdict (JNOV) or in the alternative a new trial. The district court granted Defendants’ motion for JNOV on the finding of fraud by Christa’s estate and dismissed that claim. The district court also granted Defendants a new trial on the issue of damages unless ABI accepted a remittitur for damages assessed against CBI only. The district court denied Defendants’ motion on the remaining claims of breach of contract, breach of warranty, and fraud. ABI accepted the remittitur. Defendants appealed the district court’s denial of their motion. Defendants also sought reversal of the district court’s judgment or in the alternative a new trial on their counterclaim. Finding no reversible error, the Supreme Court affirmed. View "April Beguesse, Inc. v. Rammell" on Justia Law

In January 2007, the Bank of Idaho made two construction loans to developers who planned to construct a fourplex on each of two adjoining lots in Idaho Falls. The bank loaned one sum of money to build a fourplex on Lot 1 and another sum for a fourplex on Lot 2. The bank secured a separate policy of title insurance for each lot that was issued by the predecessor of First American Title Insurance Company. Each policy included an endorsement that the parties understood would insure against loss or damage that the bank might sustain by reason of a multifamily residence not being constructed on the lot. After discussion with representatives of the city, the developers changed their original plans and built both fourplexes on Lot 2 and built a parking lot with storm water retention and landscaping on Lot 1. The developers later defaulted on their loans, and the bank foreclosed on both deeds of trust. At the foreclosure sale, the bank acquired each lot by making a full credit bid on all amounts due and owing on the note secured by the deed of trust. In 2010, the bank submitted a claim under the title policy issue with respect to Lot 1 to recover under the endorsement. The insurance company rejected the claim and the bank filed suit to recover under the policy. The district court granted the insurance company’s motion for summary judgment and dismissed this action. The bank then appealed. The Supreme Court concluded after its review that the district court erred in holding that the title insurance company had no liability under the policy. The endorsement provided that "[t]he Company hereby insures the owner of the indebtedness secured by the insured mortgage against loss or damage which the insured shall sustain by reason of the failure of [a multifamily residence to be built on Lot 1]." The endorsement insured against "loss or damage" that the bank argued was the failure of the multifamily residence to be constructed on the lot. It did not define what constituted "loss or damage." Subsections of the pertinent indemnity clause stated limits on the insurance company's liability, but it did not define loss or damage. Accordingly, the district court was reversed and the case remanded for further proceedings. View "Bank of Idaho v. First American Title" on Justia Law

Saint Alphonsus Diversified Care, Inc. (and others) formed a general partnership named MRI Associates. The parties executed a written partnership agreement (effective April 1985). The primary purpose of the partnership was to acquire and operate diagnostic and therapeutic devices, equipment, and accessories, beginning with a magnetic resonance imaging (MRI) scanner. MRI Associates and others formed two limited partnerships. One was named "MRI Limited Partnership," and it owned and operated an MRI scanner located on the hospital campus of Saint Alphonsus; the other limited partnership was named "MRI Mobile Limited Partnership," and it owned and operated mobile MRI scanners. For decades, a group of radiologists known as Gem State Radiologists had interpreted medical images pursuant to a contract that gave them the exclusive right to serve the radiological needs of patients of Saint Alphonsus. After the formation of MRI Associates, they interpreted MRI scans performed at MRI Center. In 1998, the Radiologists began planning to construct and operate an outpatient facility in Boise that was located away from the hospital. There were negotiations among the Radiologists, Saint Alphonsus, and MRI Associates to have one medical imaging entity, but those negotiations were unsuccessful. There was evidence that Saint Alphonsus was negotiating against MRI Associates with the Radiologists. In 1999, the Radiologists formed Intermountain Medical Imaging, LLC, (“IMI”), and a month later opened their facility. In 1998, Saint Alphonsus began negotiating with the Radiologists to partner with them in the imaging center. In 2001, Saint Alphonsus became a member of IMI. In 2002, IMI opened another facility in Meridian. In 2004, Saint Alphonsus gave notice to MRI Associates that it would dissociate from the partnership effective on April 1, 2004. Under the partnership agreement, Saint Alphonsus could not compete with MRI Associates for a period of one year. Saint Alphonsus then filed suit seeking to recover the value of its partnership interest from MRI Associates, and MRI Associates responded by filing a multi-count counterclaim and claims against third parties. The third-party claims were ultimately dismissed. The jury found Saint Alphonsus liable on all causes of action, and MRI Associates was awarded a judgment in the sum of $36.3 million. That judgment was vacated on appeal, and the case was remanded for further proceedings. The case was again tried to a jury. The district court submitted four claims for relief to the jury: breach of contract, intentional interference with a prospective economic advantage, breach of fiduciary duty, and civil conspiracy. The jury found in favor of the MRI Entities on each of the claims. Saint Alphonsus appealed, and the MRI Entities cross-appealed. Finding no reversible error, the Supreme Court affirmed the district court's judgment. View "St. Alphonsus Diversified Care, Inc. v. MRI Associates, LLP" on Justia Law

Appellant Charles DeGroot and DeGroot Farms, LLC appealed the district court's grant of summary judgment on its claims against Standley Trenching, Inc. d/b/a Standley & Co., relating to the construction and installation of a manure handling system at the DeGroot dairy. Beltman Construction, Inc., d/b/a Beltman Weldling and Construction, was the general contractor for the project. Beltman subcontracted with Standley for the installation of the manure handling equipment. J. Houle & Fils, Inc. manufactured the manure handling equipment installed at the DeGroot dairy. Because of maintenance problems with the manure handling equipment, DeGroot initiated litigation against Standley and Houle. DeGroot then initiated litigation against Beltman. Beltman brought a third party complaint against Standley. Standley counterclaimed against DeGroot for amounts due for parts and services. The district court granted Standley summary judgment on its counterclaim, granted Standley summary judgment on DeGroot's claims, and granted Standley summary judgment on Beltman's third party complaint. DeGroot appealed. Finding no reversible error, the Supreme Court affirmed. View "DeGroot v. Standley Trenching, Inc." on Justia Law

This appeal stemmed from the failure of Tamarack Resort, which was owned, developed, and operated by Tamarack Resort, LLC. The Resort was slated as a year-round community, complete with cross-country and downhill skiing, a championship golf course, hotel and conference facilities, retail shopping, restaurants, and lounges. Tamarack planned to offer a panoply of real estate options, including custom homes, condominiums, townhomes, chalets, and cottages. Construction at the Resort began in 2003. Housing units were built and sold, hotel facilities were developed, and by 2006, the ski areas, golf course, retail shops, and restaurants were up and running. In 2004, Tamarack hired Teufel Nursery as its landscape developer. Teufel provided landscaping services at the Resort from 2004 until early 2008. This appeal centered the priority of liens as between Teufel Nursery's mechanics lien and Credit Suisse's mortgages. The district court held that while Teufel had a valid and enforceable lien, it was inferior to Credit Suisse’s mortgages. On appeal, Teufel argues that such holding was in error and that the district court also erred in calculating Teufel's lien amount, interest, and attorney fees. Finding no error, the Supreme Court affirmed. View "Credit Suisse v. Teufel Nursery" on Justia Law

Appellant Edged in Stone, Inc. (EIS) sought damages for breach of contract, breach of warranty, breach of implied covenant of good faith and fair dealing, negligence and unjust enrichment when a skid loader it purchased experienced mechanical problems. The district court dismissed all of EIS's claims except breach of contract and unjust enrichment. Later, the district court entered a judgment in favor of Northwest Power Systems, LLC (NWPS), dismissing EIS's remaining claims and awarded NWPS attorney's fees and costs. EIS appealed to the Supreme Court, arguing arguing that the district court erred in granting summary judgment to NWPS. After careful consideration of the trial court record, the Supreme Court found no reversible error and affirmed that court's grant of summary judgment. View "Edged In Stone v. NW Power Systems" on Justia Law

Medical Recovery Services, LLC (MRS), a licensed collection agency, appeals from the district court’s order affirming default judgments entered by the magistrate court. Each Respondent’s account indebtedness was assigned to MRS. MRS filed suit to recover payment from each Respondent and also sought $350 in attorney fees from each, based on a contractual provision. None of the Respondents answered the complaints filed by MRS, so MRS filed for default judgments to be entered in each case. The magistrate court entered default judgments as to all Respondents but granted attorney fees in amounts less than the $350 that MRS was requesting under the contracts. MRS asserted that the magistrate erred in awarding attorney fees in the amount of the principal owed by the Respondents for medical services, as opposed to $350, which was the minimum amount that each Respondent contracted to pay. Finding no reversible error, the Supreme Court affirmed the district court. View "Medical Recovery Services v. Strawn" on Justia Law

The issue on appeal before the Supreme Court in this case was a trial court's order denying a motion to compel nonparties to a contract to arbitrate pursuant to an arbitration clause in the contract. Finding no reversible error, the Supreme Court affirmed. View "Clearwater REI v. Boling" on Justia Law

Appellant appealed the grant of a summary judgment that dismissed his claim seeking to enforce a vendee’s lien in real property. Because the appellant only addressed on appeal one of two possible grounds upon which the district court granted summary judgment, the Supreme Court affirmed the district court. View "Cuevas v. Barraza" on Justia Law