Justia Idaho Supreme Court Opinion Summaries

The case concerns a challenge to the rezoning of 145 acres of farmland in Canyon County, Idaho for light industrial use. The property owners, the Judith A. Gross Trust and Douglas Gross, sought the rezoning to facilitate future industrial development. The Canyon County Development Services Department and Planning and Zoning Commission recommended approval, and the Canyon County Board of County Commissioners ultimately approved the rezoning with conditions, including restrictions on certain uses. Three local businessmen and their agricultural business objected, arguing the rezoning would harm their agribusiness interests by reducing available farmland and impacting crop isolation.After the Board declined to reconsider its approval, the petitioners filed for judicial review in the District Court of the Third Judicial District of Idaho, Canyon County. They claimed standing as “affected persons” under the Local Land Use Planning Act (LLUPA), asserting concrete adverse impacts on their businesses. The district court dismissed the petition, holding that the petitioners failed to establish “constitutional” standing under the traditional three-part test—injury in fact, causation, and redressability—and declined to consider whether the petitioners met LLUPA’s “affected person” standard.The Supreme Court of the State of Idaho reviewed the district court’s decision. It held that the applicable standing inquiry for judicial review under LLUPA is the “affected person” standard set forth in Idaho Code section 67-6521, rather than the traditional federal three-part test. The Court clarified that Idaho’s standing doctrine is a “self-imposed constraint” and subject to legislative definition. The Supreme Court reversed the district court’s denial of the petition for review and remanded for consideration of standing under the LLUPA standard. Attorney fees were denied, but costs were awarded to the petitioners. View "Crookham v. County of Canyon" on Justia Law

A homeowners association in Fremont County, Idaho sought to enforce an amendment to its covenants, conditions, and restrictions (CCRs) prohibiting short-term rentals (less than thirty days) in a subdivision. The amendment was adopted in 2016 by a majority vote of property owners; however, the owners of one particular property at that time, C&L Lee, L.C., expressly voted against the restriction and did not provide written consent. After the amendment, the property was transferred multiple times, with each new deed referencing the CCRs, but none of the subsequent owners ever gave express written consent to the short-term rental restriction. In 2022, the HOA discovered the property was being advertised as a short-term rental and brought suit against the current owners, seeking injunctive and declaratory relief.The District Court of the Seventh Judicial District reviewed cross-motions for summary judgment, focusing on the interpretation of Idaho Code section 55-3211. The district court found the statute unambiguously protected properties from newly added rental restrictions unless the property owner at the time of the restriction’s adoption expressly agreed in writing. Because no owner of the property, either at the time of the amendment or thereafter, had provided written consent, the court concluded the restriction did not encumber the property and could not be enforced against the current owners.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Supreme Court held that Idaho Code section 55-3211 prohibits a homeowners association from adding or enforcing rental restrictions unless the property owner at the time of the amendment consents in writing. The restriction did not bind the property or successors because consent was never given. Consequently, summary judgment for the homeowners was affirmed, and neither party was awarded attorney fees. Costs on appeal were awarded to the homeowners. View "North Henry's Lake v. Norton" on Justia Law

The case concerns a dispute between neighboring property owners in Fremont County, Idaho, regarding roadway access rights along Bootjack Drive and Whitetail Lane near Henry’s Lake. Edward and Barbara Stasiewicz, who own an 80-acre landlocked parcel, along with other plaintiffs, sought to establish express, implied, and prescriptive easements over land owned by Henry’s Lake Village, LLC (HLV) and other defendants. The controversy intensified after the Stasiewiczes’ predecessors obtained deeds that included easements, followed by a default judgment in a quiet title action initiated by HLV against the predecessors, which purported to extinguish any easement rights. Subsequently, HLV granted the Stasiewiczes restrictive access easements over Bootjack Drive and Whitetail Lane.The Seventh Judicial District Court of Fremont County initially granted HLV’s motion to dismiss the Stasiewiczes’ express and prescriptive easement claims as moot due to the granted easements, but allowed the implied easement claim to proceed, requesting briefing on res judicata. After supplemental briefing, the district court denied motions to strike evidence, found the Stasiewiczes’ claims precluded by res judicata due to the prior quiet title judgment, and dismissed all remaining claims as moot, concluding the Stasiewiczes had already received the relief they sought.The Supreme Court of the State of Idaho reviewed the appeal. It held that the district court erred by raising the affirmative defense of res judicata sua sponte, as such defenses must be raised by parties, not the court. The Supreme Court also found the district court incorrectly dismissed the Stasiewiczes’ claims as moot, especially regarding Bootjack Drive, since the restrictive terms of the granted easements did not fully resolve the controversy. The Supreme Court vacated the district court’s judgment, reversed the dismissal of the Stasiewiczes’ claims, and remanded the case for further proceedings. View "Stasiewicz v. South Henry's Lake" on Justia Law

A group of cities holding junior ground water rights in the Eastern Snake Plain Aquifer sought judicial review of a final order issued by the Director of the Idaho Department of Water Resources. This order updated the methodology used to assess whether pumping by junior ground water users caused material injury to senior surface water rights holders who divert water from the Snake River. The Director’s Fifth Amended Final Order revised technical aspects of the model and data, and after a hearing on objections by the cities, the Director affirmed the methodology with modifications and issued a Sixth Methodology Order, which expressly superseded all prior methodology orders.The cities filed a petition for judicial review in the Snake River Basin Adjudication district court, challenging the Director’s Post-Hearing Order regarding the Fifth Methodology Order. The district court affirmed the Director’s findings and conclusions, upholding the methodology and the application of the clear and convincing evidence standard, and found that the Director did not prejudice the cities’ substantial rights. The district court’s judgment specifically affirmed the Post-Hearing Order but did not address the operative Sixth Methodology Order.On appeal, the Supreme Court of the State of Idaho reviewed whether the cities had properly invoked its jurisdiction. The Court held that the cities failed to challenge the currently operative Sixth Methodology Order in district court, and therefore, under Idaho law, the Court lacked jurisdiction to consider the appeal or award the requested relief. As a result, the appeal was dismissed for lack of jurisdiction. The Court awarded attorney fees and costs to the Idaho Department of Water Resources but denied attorney fees to the intervening Surface Water Coalition, granting them costs only. View "City of Idaho Falls v. IDWR" on Justia Law

Joel Ward performed construction work for Bishop Construction, LLC and its sole member, Ren Bishop, in Idaho, Montana, and Wyoming, with an agreed hourly wage and travel compensation. Despite keeping detailed records of his hours, Ward was not paid for work completed between 2017 and 2019, leading him to pursue payment through legal action. The dispute centered on whether Ward should be classified as an employee or an independent contractor and whether he was required to register as a contractor under Idaho law.The case was first heard in the District Court of the Seventh Judicial District of Idaho, Bonneville County. After a bench trial, and based on the parties’ stipulation that Ward was an independent contractor, the court dismissed his wage claims, leaving only breach of contract and unjust enrichment claims. The district court initially awarded Ward full damages for breach of contract. However, after Bishop raised the issue of contractor registration under the Idaho Contractor Registration Act (ICRA) in post-trial motions, the court amended its findings, limited contract damages to out-of-state work, awarded unjust enrichment damages for Idaho work, and granted costs and attorney fees.On appeal, the Supreme Court of the State of Idaho reviewed whether Ward was required to register as a contractor under ICRA and whether the contract was illegal. The Court held that Bishop failed to meet his burden to prove Ward was required to register under ICRA, as the record did not establish Ward’s status as a contractor for those purposes. The Supreme Court vacated the district court’s amended judgment and remanded with instructions to reinstate its original findings and amended judgment, including the previously awarded attorney fees and costs. The Court also awarded Ward attorney fees and costs on appeal as the prevailing party. View "Ward v. Bishop Construction" on Justia Law

Two couples entered into a written agreement for the sale and purchase of a condominium in Idaho, using a standard real estate contract form. The property was identified by its street address, unit number, and condominium name. After agreeing to terms and signing the contract, the sellers informed the buyers that they no longer wished to sell. The buyers, who had already paid earnest money, secured financing, and prepared for closing, sought to enforce the agreement. The sellers refused to proceed, claiming the contract was unenforceable due to an inadequate property description under the statute of frauds and asserting the parties had mutually rescinded the agreement.The case was first heard in the District Court of the First Judicial District, Bonner County. The court denied both parties’ motions for summary judgment on the statute of frauds and specific performance, finding factual disputes. After a bench trial, the district court ruled that the property description in the contract was sufficient to satisfy the statute of frauds. At a subsequent jury trial, the jury found that the contract was valid, had not been rescinded or abandoned, and that the sellers breached it, awarding the buyers damages. The district court, however, granted the sellers’ motion for partial summary judgment, finding the remedy of specific performance unavailable because the buyers had not tendered the full purchase price at closing.On appeal, the Supreme Court of the State of Idaho affirmed that the contract’s property description satisfied statutory requirements and thus dismissed the sellers’ statute of frauds defense. The court held that the district court erred in denying specific performance solely for failure to tender the full purchase price, especially since the sellers’ conduct prevented completion. The Idaho Supreme Court reversed the denial of specific performance and remanded for the district court to consider equitable factors. The court also affirmed the award of attorney fees to the buyers and awarded them costs and fees on appeal. View "McLaughlin v. Moore" on Justia Law

The dispute arose over whether certain parcels of land owned by Vintage II, LLC and Christine Holding in Teton County, Idaho, were subject to covenants, conditions, and restrictions (CC&Rs) or other limitations associated with the adjacent Teton Saddleback Vistas Subdivision. The plaintiffs sought to quiet title, arguing their properties were not encumbered by three recorded CC&R instruments. The defendant homeowners association claimed the properties were subject to restrictions, including those set forth in a recorded Master Plan referenced in the plaintiffs’ deeds.The District Court of the Seventh Judicial District reviewed the case after a bench trial. It found that the CC&Rs did not encumber the subject properties due to deficiencies in their recording and description. However, the court concluded that the Master Plan, referenced in the plaintiffs’ deeds, did impose restrictions such as lot numbers, sizes, and open area requirements, and thus encumbered the properties. The court denied the plaintiffs’ request to quiet title, holding that the Master Plan created enforceable restrictions and a common law dedication of open space.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision to admit the Master Plan into evidence, finding it relevant because it was referenced in the deeds and material to the quiet title action. However, the Supreme Court reversed the district court’s conclusions that the Master Plan created restrictive covenants or a common law dedication. The Court held that the Master Plan did not clearly express any binding restrictions or dedication, and thus could not encumber the properties. The amended judgment was vacated, and the case was remanded for entry of judgment in favor of the appellant, Vintage II, LLC. The Court awarded costs to Vintage as the prevailing party. View "Vintage II, LLC v. Teton Saddleback" on Justia Law

A couple purchased a home from another couple, relying on representations made in a property condition disclosure form as required by Idaho law. After moving in, the buyers discovered significant defects in the home, including unpermitted additions and structural problems that were not disclosed. The buyers hired experts who confirmed that the attic and kitchen additions were structurally unsound and that required permits had not been obtained. The buyers filed suit three years after the sale, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, violation of the Idaho Property Condition Disclosure Act, and fraud.The case proceeded in the District Court of the Third Judicial District, Canyon County. A jury found in favor of the buyers on all claims except the implied covenant of good faith and fair dealing, awarding $63,024 in damages. After trial, the district court granted a directed verdict for the sellers on the Disclosure Act claim, finding it barred by a three-year statute of limitations, but denied the sellers’ motions on the fraud and contract claims. The court also denied the buyers’ request for attorney fees, reasoning they were not the prevailing party.On appeal, the Supreme Court of the State of Idaho affirmed the district court’s denial of the sellers’ motions for directed verdict and judgment notwithstanding the verdict on the fraud claim, holding that the buyers’ fraud claim was not time-barred because they did not discover the fraud until after closing, and that substantial evidence supported the jury’s verdict. The Supreme Court reversed the district court’s dismissal of the Disclosure Act claim, holding that the claim accrued at closing, not upon delivery of the disclosure form, and thus was timely. The Court also held that the buyers were entitled to attorney fees under the purchase agreement and remanded for a determination of the amount. The buyers were awarded attorney fees and costs on appeal. View "VanRenselaar v. Batres" on Justia Law

The case involves a dispute between the owners and operators of a tourist attraction, Bear World, and the Idaho Transportation Department (ITD) over the closure of an intersection on Highway 20 in Madison County, Idaho. Bear Crest Limited LLC owns parcels of land leased to Yellowstone Bear World Inc., and Michael Ferguson is associated with both entities. In 1973, the original landowners (the Gideons) conveyed land to ITD’s predecessor for highway expansion, reserving “Access to the County Road Connection.” In 2016, as part of a highway upgrade to controlled-access status, ITD closed the intersection nearest Bear World, requiring visitors to use a more circuitous route, increasing travel distance by about five miles.After the intersection closure, the plaintiffs sued ITD for breach of contract and inverse condemnation, arguing that the closure violated the reserved access right in the Gideon deed and constituted a taking of property without just compensation. Both parties moved for summary judgment. The District Court of the Seventh Judicial District, Madison County, granted summary judgment to ITD, finding that the deed did not guarantee access to Highway 20, only to a county road, and that the closure did not amount to a compensable taking since alternative access remained.On appeal, the Supreme Court of the State of Idaho reversed in part, vacated the district court’s judgment, and remanded. The Court held that Bear Crest Limited had standing and that the Gideon deed unambiguously reserved access to the specific Highway 20 connection, not merely to a county road. The Court found that ITD’s closure of the intersection breached the deed and substantially impaired Bear Crest’s access rights, constituting a taking under Idaho law. The Court directed entry of partial summary judgment for Bear Crest on both claims, reserving damages and other issues for further proceedings. View "Bear Crest Limited LLC v. State of idaho" on Justia Law

Aaron Powers owned a lot within a subdivision governed by covenants, codes, and restrictions (CC&Rs), as well as an adjacent parcel he intended to develop. The adjacent parcel lacked access to a public or private road, so Powers sought to construct a road across a sixty-foot strip of his lot to provide access. After the homeowners association (HOA) denied permission, Powers obtained a boundary line adjustment and amended plat from Teton County, effectively moving the strip into the adjacent parcel. Carl Jordan, a subdivision homeowner and HOA board member, filed suit seeking declaratory and injunctive relief to prevent the road’s construction, arguing that the CC&Rs still applied to the strip and prohibited the road.The District Court of the Seventh Judicial District, Teton County, granted summary judgment for Jordan, declaring that the CC&Rs continued to apply to the strip, that Powers violated the CC&Rs by splitting the lot, and that the CC&Rs categorically prohibited construction of the road. The court issued a permanent injunction against Powers and awarded attorney fees and costs to Jordan. Powers moved for reconsideration, which was denied, and he appealed.The Supreme Court of the State of Idaho affirmed in part and reversed in part. The Court held that the CC&Rs continued to apply to the sixty-foot strip despite the boundary adjustment and that Powers was required to obtain approval from the HOA’s Design Committee before constructing the road, which he had not done. However, the Court reversed the lower court’s declaration that the CC&Rs categorically prohibited road construction and that the boundary adjustment constituted a prohibited lot split, finding those issues either unsupported or moot. The permanent injunction and the award of attorney fees and costs were vacated, and the case was remanded for further proceedings. Neither party was awarded attorney fees on appeal. View "Jordan v. Powers" on Justia Law