Justia Idaho Supreme Court Opinion Summaries

In April and June of 2008, Best of the Best Auto Sales, Inc. purchased seven vehicles from Dealers Auto Auction of Idaho and Brasher's Idaho Auto Auction with checks that were returned for insufficient funds. As a result, Dealers and Brasher refused to provide Best of the Best with the titles to the vehicles. Best of the Best then sold the vehicles to Idaho consumers without providing them with titles. Dealers and Brasher filed claims with CNA Surety d/b/a Western Surety Company which acted as a surety for a "$20,000 Vehicle/Vessel Dealer Bond." Best of the Best was the principal. Upon Best of the Best's failure to provide evidence or defenses for Dealers' and Brasher's claims, Western Surety alleged that it lawfully settled those claims in good faith upon the condition that the consumers received their titles, even though they were not based on final judgments. Plaintiff Nick Hestead submitted his claim, which was based on a final judgment. Plaintiff's claim involved fraud and fraudulent representation concerning a separate vehicle that he purchased from Best of the Best that was previously branded a lemon in California. Western Surety responded by asserting that the Dealer Bond was exhausted. Plaintiff contended that the plain meaning of I.C. 49-1610(4) provides that his claim should be given priority because it was submitted thirty days after a final judgment was entered, unlike Dealers' and Brasher's claims. Western Surety asserted that the plain meaning of I.C. 41-1839(3) permits sureties to settle Dealer Bond claims in good faith. Upon review, the Supreme Court found that the payments on the surety bond were lawfully made in good faith pursuant to I.C. 49-1610(1) and I.C. 41-1839(3) because Dealers' and Brasher's claims were undisputed and supported by competent evidence. View "Hestead v. CNA Supply dba Western Surety Co." on Justia Law

In 2003, Appellant Bridge Tower Dental hired Respondent Meridian Computer Center to provide its dental practice with a computer hardware system subject to a warranty contract. In June of 2005, Bridge began experiencing problems with its server. Bridge Tower Dental entrusted its computer server, including both of its hard drives, to Meridian in order to repair or restore the failing hard drive. While attempting to restore the failing hard drive, Respondent mistakenly confused the source and destination locations on the motherboard and inadvertently erased all of Bridge's data, including the practice's patient records, from the working hard drive. Bridge filed suit against Meridian for breach of contract and negligence under the law of bailment. At trial, the district court denied Bridge's request to submit different jury instructions for the separate claims, and instead combined the contract claim with the negligent bailment claim in the final jury instructions. The jury entered a general verdict in favor of Meridian. Bridge filed a Motion for Judgment Notwithstanding the Verdict, or alternatively, a Motion for New Trial, both of which were denied by the district court. The court entered an order awarding attorney's fees and costs to Meridian. Bridge appealed to the Supreme Court, arguing that the district court erred in denying its Motion for Judgment Notwithstanding the Verdict because Meridian failed to prove that it was not negligent in erasing the data contained on the working hard drive, that the court erred in denying the Motion for New Trial because the jury instructions were improper, and that the district court erred in awarding attorney's fees and costs. Upon review, the Supreme Court reversed the district court's denial of Bridge's post-trial motion and vacated the lower court's award of attorney's fees because Meridian was no longer the prevailing party. View "Bridge Tower Dental, P.A. v. Meridian Computer Center, Inc." on Justia Law

Plaintiff-Counterdefendant-Appellant David Oakes, M.D. was employed as a cardiologist by Defendant-Counterclaimant-Respondent Boise Heart Clinic Physicians, PLLC (BHC) from January 2000 until the end of July 2008, when he left to pursue other employment opportunities. While employed by BHC, Plaintiff had an employment agreement that entitled him to half the adjusted gross charges he generated. Because of his complicated arrangements with other service providers, Plaintiff's final payment was not calculated until after his departure. After his employment ended, Plaintiff corresponded with BHC regarding his final payment. Plaintiff never received payment. Instead, he received a series of letters that detailed the evolving computation of his final payment. BHC's last letter to Plaintiff included a demand for repayment. Plaintiff then sued claiming that BHC still owed him money under the employment agreement. In rendering its verdict, the jury was given a choice between three special verdict forms that corresponded with the three possible verdicts: one finding that neither party is entitled to recover from the other; one that finding that BHC owed money to Plaintiff; and one finding that Plaintiff owed money to BHC. The jury returned with a verdict in favor of Plaintiff, and against BHC, that awarded Plaintiff $2,043.92. Ultimately the district court entered a final judgment that awarded Plaintiff $2,043.92 and declared that neither party was the prevailing party for purposes of costs and attorney fees. Plaintiff appealed the "prevailing party" decision to the Supreme Court. e sought. The district court entered a judgment conferring to Oakes the amount awarded by the jury, but found that neither party was the prevailing party for purposes of costs or attorney fees. Upon review, the Supreme Court held that the district court abused its discretion by not finding Plaintiff to be the prevailing party. The case was remanded for a determination of costs and fees. View "Oakes v. Boise Heart Clinic Physicians, PLLC" on Justia Law

This case concerned a commercial lease between Defendants-Appellants-Cross-Appellants Michael Storms and Kathy Burggraf and the Plaitniff-Respondent-Cross-Appellant Watkins Company, LLC’s predecessor in interest, Watkins and Watkins for a restaurant and microbrewery in Idaho Falls, Idaho. Watkins filed a lawsuit seeking to enforce the lease after Storms and Burggraf failed to timely pay the rent. The issues were tried to the district court, which found that Storms and Burggraf had materially breached the lease and that Watkins could regain possession of the property. The district court also found that Storms and Burggraf had been unjustly enriched by failing to pay rent for additional storage space. Further, the district court found that the lease's provision for accelerated rent was a liquidated damages clause and found it be unconscionable. Storms and Burggraf appealed the district court’s decision, arguing that an accord and satisfaction had been reached between the parties and that the court erred in its finding of the rent for the upstairs storage area above the restaurant. Watkins argued on cross-appeal that the district court based its finding regarding the accelerated rent on insufficient evidence. Because of an error in the district court's finding regarding the upstairs storage area, the Supreme Court vacated that part of the court's order but upheld the remaining issues. View "The Watkins Co. LLC v. Storms" on Justia Law

Plaintiffs-Appellants Randolph Farber, Scott Becker, and Critter Clinic (Farber) alleged that the Manager of the Defendant-Respondent State Insurance Fund (SIF or "the Fund") failed to comply with I.C. 72-915, which provides the means by which the SIF Manager may distribute a dividend to policyholders. The district court determined that the gravamen of Farber's claim implicated the statute and held that the three-year statute of limitation provided by I.C. 5-218(1) barred all claims that accrued prior to July 21, 2003. Farber timely appealed. Upon review, the Supreme Court held that the five-year statute of limitation in I.C. 5-216 applied to Farber's claim. Therefore, the Court reversed the trial court's decision and remanded the case for further proceedings. View "Farber v. Idaho State Insurance Fund" on Justia Law

Defendant-Respondent Croft & Reed, Inc. and Plaintiff-Appellant Steel Farms, Inc. had a preexisting landlord-tenant relationship when they entered into a written agreement granting Steel Farms a lease and option (Option A) to purchase a farm in Bonneville County (the Property). The lease had an express four-year term. Steel Farms believed the four-year term was a mistake because the option to purchase the Property did not mature until after the four-year lease term expired. In response to a request from Steel Farms, Croft & Reed’s secretary made a handwritten interlineation on the lease agreement which purported to extend the lease term for an additional year. While Steel Farms was a tenant, it purchased and installed irrigation equipment on the Property, which was attached to the Property’s irrigation system. Steel Farms later granted Walker Land, Inc. an option to purchase the Property (Option B) from Steel Farms. Steel Farms sought to exercise Option A after leasing the Property for four years. Croft & Reed refused. Steel Farms sued, and the parties filed cross motions for summary judgment. The district court granted partial summary judgment in favor of Croft & Reed. Steel Farms appealed the certified judgment. Upon review, the Supreme Court vacated and remanded, finding that the secretary's initialed interlineation was insufficient to amend the lease and option. View "Steel Farms, Inc. v. Croft & Reed, Inc." on Justia Law

Plaintiff-Appellant Vernon was a homeowner in default on his home loan. ReconTrust, the holder of Plaintiff's deed of trust, initiated a nonjudicial foreclosure on the deed. Upon receiving notice of the trustee's sale, Plaintiff sued ReconTrust, Mortgage Electronic Registration Systems, Inc., and Bank of New York Mellon. He alleged that none of the defendants had standing to initiate the foreclosure. Bank of New York moved to dismiss for failure to state a claim on the claims that it complied with the statutory requirements to foreclose, and that standing was not a requirement for nonjudicial foreclosures. The district court granted the motion, and Plaintiff appealed. He argued that before a party may initiate a nonjudicial foreclosure it must affirmatively show it has standing by having an interest to both the deed of trust and the promissory note. Finding that a trustee was not required to prove it had standing before foreclosing on a deed of trust, the Supreme Court affirmed the district court's dismissal of Plaintiff's complaint. View "Trotter v. Bank of New York Mellon" on Justia Law

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