Justia Idaho Supreme Court Opinion Summaries

n 2007, Plaintiff-Respondent Leslie Benz entered into a contract to purchase a townhouse that was to be constructed. The contract required her to make three nonrefundable payments of earnest money, which were to be applied to the purchase price. The property's seller sought a construction loan from Defendant-Appellant D.L. Evans Bank. As security for the loan, the seller executed a deed of trust granting the Bank a lien in the property upon which the townhouse would be constructed. The townhouse was substantially completed when Plaintiff was notified that the seller had filed for bankruptcy. The seller failed to pay construction expenses, and as a result, the closing did not occur as scheduled. Numerous mechanics' and materialmen's liens were filed against the property. Plaintiff negotiated with the seller in an attempt to clear the title and purchase the townhouse. Negotiations broke down, Plaintiff notified the seller that she was rescinding the contract, and demanded the return of the earnest money she paid. When the earnest money was not refunded, Plaintiff sued. The trial court held that Plaintiff's lien which was created in connection with the rescinded contract had priority over a deed of trust that the Bank had in the property. The Supreme Court reversed part of the trial court's judgment that awarded accrued interest from the earnest money, but affirmed the trial court's judgment in favor of Plaintiff. View "Benz v. D.L. Evans Bank" on Justia Law

Patricia Shelton filed suit alleging breach of contract a legal malpractice against her former attorneys Defendants-Appellants R. Bruce Owens, Jeffrey Crandall, and Owens and Crandall, PLLC (Owens). During the pendency of her action, Ms. Shelton passed away. Plaintiff-Appellee Lois Bishop sought to assert Ms. Shelton's claims as her personal representative. Owens unsuccessfully argued that the legal malpractice claim abated upon Ms. Shelton's death, and that her breach of contract claim did not state a claim. Owens appealed. Because Patricia Shelton’s legal malpractice claim sounds in tort and abated upon her death, and her breach of contract claim fails to state a claim, the Supreme Court concluded the district court erred in denying Owens’s motion for summary judgment and in granting Bishop’s motion to substitute as plaintiff. View "Owen v. Bishop" on Justia Law

Appellants Kent Whiteman and Whitehorse Properties, LLC, (Whiteman), brought a second appeal of this case before the Supreme Court. In the original trial, Respondent Damian Farrell sued Whiteman for uncompensated architect services rendered for Whiteman's condominium project from 2003 to 2004. Whiteman counterclaimed arguing that Farrell was not entitled to compensation due to his failure to obtain a license to practice architecture in Idaho. Farrell is a resident of Michigan and was licensed as an architect in the states of Michigan, Texas, and New York when he began working with Whiteman. Farrell did not receive his architect's license in Idaho until 2004. The district court found that an implied in fact contract existed between the parties and awarded Farrell damages in quantum meruit for services rendered, expenses incurred, and attorney's fees and costs. Whiteman appealed and the Supreme Court vacated the district court's damage award and its award of attorney's fees, finding that any damages awarded to Farrell prior to being licensed in Idaho should be based on unjust enrichment, not quantum meruit. On remand, the district court heard new evidence and awarded Farrell damages for reimbursement of out of pocket expenses incurred prior to licensing under unjust enrichment, damages for architectural services rendered after Farrell obtained his license based on quantum meruit, and attorney's fees and costs. Upon re-review, the Supreme Court upheld the district court's award of damaged under unjust enrichment and quantum meruit, and upheld the award of attorney's fees and costs. View "Farrell v. Whiteman " on Justia Law

Plaintiff-Appellant Dr. John Noak was dismissed as the medical director for Prison Health Services, Inc. (PHS). He appealed the district court's grant of summary judgment in favor of the Idaho Department of Correction (IDOC) on claims of breach of an implied covenant of good faith, intentional and negligent infliction of emotional distress, defamation, and intentional interference with contract. A 2004 investigation into how Plaintiff treated a female inmate at an IDOC facility lead to IDOC demanding that PHS replace Plaintiff as medical director. Finding no error in the district court's judgment, the Supreme Court affirmed the grant of summary judgment in favor of IDOC. View "Noak v. Dept. of Corrections" on Justia Law

Plaintiff Minor Miracle Productions, LLC (MMP) was a film company for whom Third-Party Respondent David Richards worked. MMP provided a film location and funding for a film written and directed by Defendant Randy Starkey. After the film was completed, Starkey refused to turn over possession of the film and various pieces of equipment from the film. MMP brought suit against Starkey alleging breach of the duty of loyalty, breach of contract, and conversion. After initially appearing via counsel in the case, Starkey proceeded pro se. When Starkey failed to appear at motion hearings and disregarded the district court’s orders regarding discovery, the court sanctioned Starkey, striking his defenses and precluding him from using any evidence not previously disclosed. MMP then moved for judgment on the pleadings, and the district court granted the motion. The court ordered Starkey to pay Richards over one million dollars in damages and interest for the costs of the film’s production, to return the film and to release the copyrights to the film and its website to Richards, and enjoined Starkey from selling the film and from using any of the equipment related to the film. Starkey timely appealed. Upon review, the Supreme Court affirmed the district court's grant of judgment on the pleadings. View "Minor Miracle Productions, LLC v. Starkey " on Justia Law

Idaho Development, LLC (Idaho Development) advanced $1,100,000.00 to Teton View Golf Estates, LLC (Teton View), a joint venture made up of Idaho Development as a 33.3% owner and Rothchild Properties, LLC as a 66.7% owner. Teton View granted Idaho Development a promissory note secured by a deed of trust that specified a set monthly payment and stated that the entire amount was to be paid off in ninety days. Idaho Development filed an action to foreclose on the deed of trust after Teton View failed to satisfy the promissory note. DePatco, Inc., another lienholder on the property, filed a motion for summary judgment to recharacterize Idaho Development’s advance as a capital contribution, which was granted. Idaho Development appealed, arguing that there was a genuine issue of fact as to whether the entire $1,100,000 advance was intended to be a capital contribution. Idaho Development also appealed a subsequent summary judgment brought by ZBS, LLC, which relied on the recharacterization determination in holding that ZBS’ lien on the property had priority over Idaho Development’s lien. Upon review of the trial court's recharacterization of Idaho Development's lien, the Supreme Court concluded that there was a genuine issue of fact as to whether the entire $1,100,000 was intended to be a capital contribution, the district court therefore improperly granted summary judgment. The case was remanded for further proceedings. View "Idaho Development, LLC v. Teton View Golf Estates, LLC " on Justia Law

In Plaintiff T.J.T., Inc.'s second appeal from a summary judgment in favor of Defendant Ulysses Mori, in which the district court found that the non-competition agreement Mori allegedly breached was unenforceable under California law. This case arose from the execution of a non-competition agreement between TJT and Mori in connection with the sale of Mori’s business, Leg-It Tire Company, Inc., to TJT in 1997. Leg-It owned and operated one production facility in Woodland, California. TJT also operated in the tire and axle recycling business, and it had recycling facilities in Idaho, Oregon, and Washington at the time it purchased Leg-It in 1997. At the time of the sale of Leg-It, Mori was hired as the "Senior Vice President and General Manager of the Leg-it Tire Company Division of [TJT]." In 2000, Mori moved to Idaho and took a new position as Corporate Sales Manager. In 2007, Mori resigned as an employee of TJT and several days later, was hired by West States Recycling, Inc., a competitor to TJT, as a tire and axle salesman. In his employment with West States, Mori facilitated the opening of a warehouse facility in Idaho to support local Idaho customers who purchase tires and axles, and also solicited tire and axle business in Oregon, Washington, California, and Idaho. Because the Supreme Court in its review found that the district court erred in failing to consider whether and to what extent the agreement could be "blue penciled" to make it enforceable, the Court vacated the summary judgment and award of attorney fees and remanded the case for further proceedings. View "T.J.T., Inc. v. Mori " on Justia Law

The issue on appeal in this case stemmed from a 2005 real estate purchase and sales agreement (PSA) entered into between Pines Grazing Association as the seller, and J.C. Investments (owner of Flying Joseph Ranch) as the buyer of the Pines Ranch. Prior to closing, the parties learned that approximately 80 acres of what Pines had previously believed to be a portion of Pines Ranch was omitted from the ranch's legal description. Pines retained attorney Fred Snook to assist with the acquisition of the 80 acres. Mr. Snook determined that the 80 acres had been deeded to Lemhi County and that the County still owned the land. In light of this, the parties entered an addendum to the PSA whereby they would proceed with the original closing on the ranch while giving Pines time to try to acquire the 80 acres from Lemhi County in order to sell the 80 acres to Flying Joseph Ranch. The sale closed before the parties learned that Lemhi County could not sell the 80 acres privately; the land had to be sold at public auction. Pines sent Mr. Snook to the auction to bid on the 80 acres. The parties' agents cut a side deal whereby Pines would be paid not to bid on the 80 acres. Flying Joseph ultimately won the land at auction. Flying Joseph's agent faxed Pines' agent an agreement and release of all claims for the 80 acres. Pines refused to sign, believing that the agreement was not part of the oral agreement not to bid at the auction. Pines subsequently filed suit to enforce the terms of the oral contract. Among the issues brought before the Supreme Court were whether the district court erred in denying Appellant’s motion for JNOV on the grounds that the $20,000.00 offered to refrain from bidding constituted an unauthorized brokerage commission. Upon review, the Supreme Court refused to enforce the oral agreement not to bid at the auction because it was an illegal contract in violation of the Sherman Act. "As such, the parties are left as they are with respect to the oral agreement not to bid, and neither party is entitled to attorney fees on appeal or in the district court with respect to all issues related to the oral agreement not to bid." The Court upheld the jury's finding that Pines did not breach the grazing lease. View "Pines Grazing Association, Inc. v. Flying Joseph Ranch, LLC " on Justia Law

Appellant Two Jinn, Inc. appealed a district court's decision that affirmed a magistrate's denial of its motion to set aside a bond forfeiture. Two Jinn argued that it demonstrated a defense of impossibility of performance based on the deportation of Rosendo Arriago Navarro (Navarro). Two Jinn also argued that the district court abused its discretion in failing to recognize that justice did not require enforcement of the forfeiture in this case under former Idaho Criminal Rule 46(e)(4). Navarro was arrested for driving without privileges. Navarro was released from custody when Two Jinn dba Aladdin Bail Bonds/Anytime Bail Bonds posted his $500 bail. After pleading guilty, Navarro was ordered to appear in court for sentencing. Navarro failed to appear for his sentencing hearing, the bond was ordered forfeited, and a bench warrant was issued for Navarro’s arrest. 175 days after the bond had been forfeited, Two Jinn filed a motion to set aside that forfeiture and exonerate it from its liability on the bond, arguing that Navarro had been deported to Mexico and that it was, therefore, entitled to relief under the contract law doctrine of impossibility of performance. Upon review, the Supreme Court concluded that the magistrate court did not abuse its discretion in denying Two Jinn’s requested bond exoneration. Therefore, the Court affirmed the district court decision upholding the magistrate court decision. View "Idaho v. Two Jinn, Inc." on Justia Law

Petitioner Virginia Beaudoin appealed a district court's dismissal of her motion for summary judgment on a breach of fiduciary duty claim against Defendant Davidson Trust Company. The claim stemmed from Davidson Trust’s mistaken distribution of trust funds to Beaudoin when Beaudoin’s two children were, in fact, the designated beneficiaries. Because the Supreme Court found that Davidson Trust owed Petitioner no fiduciary duty at the time of the alleged breach, the Court affirmed the district court's decision dismissing Petitioner's claim. View "Beaudoin v. Davidson Trust Co. " on Justia Law