Justia Idaho Supreme Court Opinion Summaries

A group of residents and an association challenged actions taken by the Harris Ranch Community Infrastructure District No. 1 (CID) in Boise, Idaho. The dispute arose after the CID’s board adopted resolutions in 2021 authorizing payments to a developer for infrastructure projects—such as roadways, sidewalks, and stormwater facilities—and issued a general obligation bond to finance those payments. The residents objected to the projects, arguing they primarily benefited the developer, imposed higher property taxes on homeowners, and allegedly violated the Idaho Community Infrastructure District Act (CID Act) as well as state and federal constitutional provisions. Previously, the District Court of the Fourth Judicial District reviewed the matter after the residents filed a petition challenging the board’s decisions. The district court ruled in favor of the CID and the developer, concluding most of the residents’ claims were either time-barred under the CID Act’s statute of limitations or had been waived because they were not preserved before the CID board. The court also found that the remaining claims failed on their merits, holding that the challenged projects qualified as “community infrastructure,” the stormwater facilities satisfied ownership requirements, and the CID was not the alter ego of the City of Boise. On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Supreme Court clarified that, given the lack of formal administrative proceedings under the CID Act, the preservation doctrine did not apply to bar the residents’ arguments. Nonetheless, the Supreme Court held that any challenge to the CID’s original formation and the 2010 bond election was time-barred. The court further held that the roadways and stormwater facilities qualified as community infrastructure, the CID’s actions did not violate constitutional requirements regarding taxation or lending of credit, and the CID was not the alter ego of the city. The Supreme Court awarded costs on appeal to the CID and the developer but denied attorney fees to all parties. View "Doyle v. The Harris Ranch Community Infrastructure District No. 1" on Justia Law

Morgan Lohman purchased a 25.8-acre property, knowing that a homeowners’ association, Cave Bay Community Services, Inc., held a permanent easement on 7.31 acres and had an option agreement with the sellers, the Drehers, to purchase the easement land for one dollar once the Drehers’ loans were paid off. Despite concerns about the effect of this option on the value and use of his property, Lohman proceeded with the purchase. After the sale, the Drehers paid off their loans, and Cave Bay exercised its option to buy the easement property for one dollar, which Lohman refused to honor.Cave Bay filed suit against Lohman in the District Court of the First Judicial District of Idaho, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and seeking specific performance of the option agreement. Cave Bay moved for summary judgment only as to the specific performance “claim.” The district court granted summary judgment to Cave Bay on that basis, struck much of Lohman’s opposing declaration, and awarded Cave Bay attorney fees and costs. The court did not address the merits of the underlying breach of contract claim. After the parties dismissed the remaining claims, Lohman appealed.The Supreme Court of the State of Idaho reviewed the case and held that specific performance is a remedy, not a stand-alone cause of action. The court concluded that the district court erred by granting summary judgment on specific performance without first determining liability on the underlying breach of contract claim. The Supreme Court vacated the district court’s amended judgment, reversed the summary judgment ruling, and remanded the case for further proceedings. The court also vacated the award of attorney fees and costs, but awarded appellate costs to Lohman. No attorney fees were awarded on appeal as there was no prevailing party at this stage. View "Cave Bay Community Services v. Lohman" on Justia Law

The dispute centers on two neighboring property owners at Priest Lake, Idaho, whose properties are subject to several easements, and who have a history of disagreements concerning the use of a shared beach, lake access, and parking. The parties previously reached a court-mediated settlement agreement addressing these issues, which included a provision for future mediation and arbitration of disputes. Disagreements soon arose, particularly over the construction of a patio by one owner, leading the parties to arbitration as provided by their agreement. The arbitrator, after considering substantial evidence and briefing, ruled in favor of one party on all contested issues, including the patio’s location and construction, the use of easements, and parking arrangements.Prior to this appeal, the District Court of the First Judicial District, Bonner County, reviewed a motion to vacate the arbitration award. The moving party argued that the arbitrator exceeded his authority and was biased, primarily because the award was unfavorable and allegedly altered the terms of the court-approved settlement agreement. After considering the arguments, the district court denied the motion, finding that the arbitrator had acted within the scope of his authority and that no evidence of bias was presented.Upon review, the Supreme Court of the State of Idaho affirmed the district court’s decision. The court held that under Idaho’s Uniform Arbitration Act, judicial review of arbitration awards is extremely limited and does not allow for overturning an award simply due to alleged errors in law or fact, or because the outcome was unfavorable. The court found no evidence that the arbitrator exceeded his authority or acted with bias. Additionally, the court awarded attorney fees on appeal to the prevailing party under Idaho Code section 12-121, concluding the appeal was frivolous and without foundation. The district court’s denial of the motion to vacate was affirmed. View "Khalsa v. Ridnour" on Justia Law

A nonprofit organization, operating a camp for children with cancer, owned several buildings situated on land owned by a married couple. The couple, both involved in the nonprofit’s leadership, decided to sell the ranch property that included the camp’s buildings. During negotiations, the couple represented to the nonprofit’s board that appraisals did not specify values for the nonprofit's buildings and that the nonprofit’s share of sale proceeds should be calculated by square footage. Relying on these representations, the nonprofit accepted a portion of the sale proceeds. Subsequently, the nonprofit discovered that the appraisals had, in fact, assigned higher specific values to its buildings, resulting in a claim for damages against the couple for misrepresentation, breach of fiduciary duty, and unjust enrichment.The District Court of the Seventh Judicial District granted partial summary judgment to the couple on certain claims, but, after a bench trial, found in favor of the nonprofit on claims for constructive fraud, breach of fiduciary duty, and unjust enrichment. The court calculated the nonprofit’s damages but reduced the award by 50%, applying comparative negligence and the doctrine of avoidable consequences. The court denied attorney fees and prejudgment interest to both parties. Both sides appealed.The Supreme Court of the State of Idaho held that the doctrine of election of remedies did not bar the nonprofit’s appeal, as seeking satisfaction of a judgment is not inconsistent with seeking a greater award on appeal. The Court ruled that it was reversible error for the district court to reduce damages based on comparative negligence or a duty to mitigate, as those doctrines did not apply to the equitable and fiduciary claims at issue. The Court affirmed the district court’s rejection of the couple’s affirmative defenses of superseding intervening cause and unclean hands, as well as the finding that the wife breached her fiduciary duty. The denial of prejudgment interest and attorney fees was affirmed, but the nonprofit was awarded costs on appeal. The case was remanded for entry of judgment in the nonprofit’s favor for the full damages amount and reconsideration of prevailing party status. View "Camp Magical Moments, Cancer Camp for Kids, Inc. v. Walsh" on Justia Law

Several descendants and heirs of Edith Little each own separate parcels of real property in Teton County, Idaho, which were divided and conveyed to Edith’s three children after dissolution of a family partnership in 1993. The deeds for these parcels included restrictive language limiting the owners’ ability to sell, trade, convey, or encumber the properties during their lifetimes or the lifetimes of their living heirs, except that conveyances were allowed only to their siblings, nephews, and nieces—not to their own spouses, children, or grandchildren. Despite the restrictions, over the years, owners conveyed their parcels to spouses and lineal descendants.Plaintiffs, who are current owners of two of the parcels, brought suit in the Seventh Judicial District Court of Teton County seeking to quiet title and obtain a declaratory judgment that the deed restrictions were unreasonable restraints on alienation and void as against public policy. The defendants, also family members, argued the restrictions were enforceable. The district court granted summary judgment for the defendants, concluding the Idaho statutes had abrogated the common law rule against unreasonable restraints on alienation and upholding the restrictions.On appeal, the Supreme Court of the State of Idaho reviewed the district court’s decision de novo. The Idaho Supreme Court held that the common law rule against unreasonable restraints on alienation remains in effect in Idaho and was not abrogated by Idaho Code sections 55-111 or 55-111A. The Court further determined that the restrictions in these deeds are unreasonable because they do not effectively preserve the properties within the immediate family and unduly hinder the owners’ ability to use or benefit from their land. The Supreme Court vacated the district court’s judgment, reversed its summary judgment order, and remanded the case for further proceedings. Costs were awarded to the plaintiffs as the prevailing party. View "Smallwood v. Little" on Justia Law

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