Justia Idaho Supreme Court Opinion Summaries

Jonathon Frantz appealed a district court’s award of attorney fees entered against him and his clients, jointly and severally, as a sanction for frivolous conduct. This appeal arose from an easement dispute among family members. The land at issue was split into multiple parcels: the Tracy Parcel, the Mathis/Roll Parcel, and the Osborn Parcel. Plaintiffs Brook Tracy and Travis Mathis owned the Tracy Parcel; Plaintiffs Gailord “Cowboy” Mathis, Brook Tracy, Laura Roll, and Rebecca Stafford owned the Mathis/Roll Parcel; and David and Naomi Osborn owned the Osborn Parcel. In 2018, Plaintiffs filed a complaint against the Osborns. Frantz was Plaintiffs’ attorney. Plaintiffs claimed that more than thirty years ago they “constructed/placed a home” on the Tracy Parcel, “constructed/placed a cabin” on the Mathis/Roll Parcel, and “created a driveway” through the Osborn Parcel to access their respective properties. Plaintiffs also claimed that for more than thirty years they had openly and continuously used the driveway over the Osborn Parcel for access to the nearest public right-of-way, Highland Drive, which was the only reasonable way to reach their respective properties. Based on this use, Plaintiffs claimed that they had an easement by necessity, an easement by implication, or a prescriptive easement across the Osborn Parcel along the existing driveway. Accordingly, Plaintiffs sought a judgment from the district court declaring their rights in the driveway. The trial court denied a preliminary injunction for two reasons: (1) “the allegations in the complaint and the motion contain[ed] gross exaggerations, if not falsehoods” and “the credibility of all of the plaintiffs” was questionable; and (2) Plaintiffs could not establish entitlement to the relief demanded because they came to the hearing unprepared to support the easement theories they advanced with any competent evidence. The Osborns moved for attorney fees, leaving it to the trial court's discretion to award Rule 11 sanctions "if the [c]ourt determines that this motion was pursued frivolously." On appeal, Frantz contended the district court abused its discretion in awarding attorney fees against him personally because it: (1) failed to follow the procedural requirements set out in Idaho Code section 12-123; and (2) erroneously found that he engaged in frivolous conduct. After review, the Idaho Supreme Court concluded this matter did not present a justiciable controversy because the judgment was satisfied and Frantz did not preserve his right to appeal pursuant to Idaho Code section 10-1115. Accordingly, the Court dismissed Frantz’s appeal because the issues before the Court were moot. View "Frantz v. Osborn" on Justia Law

Jonathon Gregory appealed a district court’s award of summary judgment in favor of Richard and Eileen Stallings (collectively, “the Stallings”) in a breach-of-contract action stemming from the parties’ oral agreement to develop real property in Rexburg, Idaho. The property was sold in December 2012. Gregory, believing the Stallings wrongfully withheld a portion of the proceeds, filed a complaint in September 2017. The district court granted the Stallings’ subsequent motion for summary judgment, concluding that Gregory’s cause of action was barred by Idaho Code section 5-217’s four-year statute of limitations. After review, the Idaho Supreme Court determined the district court properly granted summary judgment to the Stallings because Gregory's cause of action was indeed barred by the statute of limitations in Idaho Code 5-217. Further, Gregory’s equitable-estoppel claim failed because he could not show that he pursued his claim in a reasonable amount of time. View "Gregory v. Stallings" on Justia Law

The Lola L. Cazier Revocable Trust (“Trust”) brought a quiet title action against Charles Drake Cazier (“Drake”) and Land Renewal Management, Inc. (“LRM”) pursuant to Idaho Code section 6-401. Drake answered separately from LRM and asserted a counterclaim against the Trust. The Trust moved to dismiss Drake’s counterclaim under Idaho Rule of Civil Procedure 12(b)(6), then filed a motion for summary judgment against both defendants. LRM also filed a motion under I.R.C.P. 12(b)(6) to dismiss the Trust’s cause of action against it. The district court granted summary judgment to the Trust and dismissed Drake’s counterclaim, awarding attorney fees against both defendants in the process. Drake and LRM appealed, arguing the district court erroneously dismissed Drake’s counterclaim and failed to properly dismiss LRM from the case. Drake and LRM also appealed the district court’s award of fees and costs, arguing several evidentiary errors and that the district court abused its discretion in awarding attorney fees. After review, the Idaho Supreme Court affirmed the district court’s grant of summary judgment for the Trust and affirmed the district court’s evidentiary rulings. View "Cazier Revocable Trust v. Cazier" on Justia Law

Victor Bliss appealed the grant of summary judgment in favor of the Minidoka Irrigation District (“MID”). Bliss filed a complaint against MID in April 2017, alleging: (1) breach of contract; (2) breach of fiduciary duty; (3) trespass; (4) declaratory relief; and (5) wrongful prosecution/infliction of extreme emotional distress. The complaint encompassed multiple events stemming from his decades-long relationship with MID. The district court granted MID’s motion for summary judgment on all claims, dismissing Bliss’s complaint for lack of notice under the Idaho Tort Claims Act, lack of standing, and failure to produce evidence. Bliss timely appealed, but finding no reversible error, the Idaho Supreme Court affirmed summary judgment. View "Bliss v. Minidoka Irrigation District" on Justia Law

Appellant Sean Mocabee and Respondent Lindsey Wilson lived together, but were not married. In 2013, after receiving a large inheritance, Wilson fully funded the purchase of a home in Kootenai County, Idaho. Per Wilson’s instruction to the title company, Mocabee’s name was included on the deed. In 2017, Wilson and Mocabee split. Shortly thereafter, Wilson filed a complaint against Mocabee for quiet title, unlawful detainer and partition of the home. Mocabee answered and counterclaimed, seeking partition and for the district court to declare Mocabee owned a fifty percent interest in the home. Mocabee also moved for summary judgment arguing the statute of limitations barred Wilson’s quiet title action. The district court granted Mocabee’s motion for summary judgment as to the quiet title action. Then case then proceeded to trial on the partition action. Mocabee filed a motion in limine asking the district court to exclude evidence demonstrating Wilson did not intend to give Mocabee a fifty percent ownership interest in the home. The district court denied the motion. After a bench trial, the district court concluded Wilson had a one hundred percent ownership interest in the home because she had contributed one hundred percent of the purchase price and the evidence did not establish Wilson intended to give Mocabee any ownership interest. As a result, the district court held that a partitioning of the home was unnecessary. Mocabee timely appealed, arguing the district court erred in: (1) using partition statutes to deprive him of any interest in the home; (2) denying Mocabee’s motion in limine; and (3) concluding Mocabee did not own a fifty percent ownership interest in the home by way of a gift from Wilson. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgment. View "Wilson v. Mocabee" on Justia Law

The Lorenzen Revocable Trust (“Lorenzen”) and David and Cynthia Pearson owned neighboring properties near Hayden Lake in Kootenai County, Idaho. The properties shared a common driveway. The properties were originally part of a 1,400 acre estate. Over the years, parcels were carved off the estate and frequently replatted. Two of those parcels included a cabin owned by Lorenzen and the “Red Barn” property owned by the Pearsons. The Pearsons purchased the Red Barn property in 2013 via quitclaim deed. Although the easement language was not in the Pearsons’ deed, the easements originally granted and reserved in a 1976 deed were recorded with the county and listed as exceptions from coverage in Pearsons’ title insurance policy. From 2013 onward, disputes over the shared driveway began. The disputes culminated in 2016 when Pearsons installed an electronic gate to control access to the shared driveway. In October 2016, Phyllis Lorenzen filed a complaint seeking a declaratory judgment to define the rights concerning the parties’ easement and access rights, as well as listing other causes of action. Four days later, Lorenzen filed a motion for a preliminary injunction against Pearsons, seeking to enjoin them “from blocking or otherwise interfering with access” via the shared driveway. The district court granted the motion for a preliminary injunction, ordering Pearsons to provide an access code or remote control to the gate and restraining both parties “from blocking or otherwise interfering with access” to their respective properties via the shared driveway. The next month, Phyllis Lorenzen passed away. Pearsons later filed an answer and counterclaim, arguing that Phyllis Lorenzen’s death “ended the express easement” from the 1976 quitclaim deed. They also filed a motion to dissolve the court’s prior preliminary injunction. The district court denied Pearsons’ motions, and the case proceeded to trial with the injunction remaining in effect. In 2018 following a jury trial, the district court issued a decision finding that the easement language in the quitclaim deeds was ambiguous; both parties had express easements granted to them as well as their heirs, successors and assigns. The district court then denied Pearsons’ motion to reconsider from the bench. Pearsons argued on appeal that the district court erred in establishing a legal description of the easement from the Plaintiff’s land survey. They argued this matter required another hearing to present evidence to establish an accurate metes-and-bounds description. The Idaho Supreme Court affirmed, finding Pearsons failed to provide an alternative metes-and-bounds survey for the district court to consider despite having had months to do so. "Only after their counsel was repeatedly unavailable to the court when it tried to request information or schedule such a hearing, did the district court accept and utilize the only legal description admitted as evidence. Pearsons cannot complain over the results of their inaction now, especially when they failed to object to the admittance of the land survey as evidence at trial." View "Lorenzen v. Pearson" on Justia Law

Nampa Highway District No. 1 (NHD) brought this action seeking to quiet title to a thirty-three-foot-wide strip of land constituting the south half of West Orchard Avenue in Canyon County, Idaho. NHD claimed that a 1941 deed conveyed the land to NHD. Appellants (defendants-below) argued that because the deed was not recorded until 1989, it did not affect their interests pursuant to the “Shelter Rule,” which protected a purchaser with notice if their predecessor in interest was an innocent purchaser. The district court granted summary judgment in NHD’s favor. After review, the Idaho Supreme Court reversed, finding the district court erred in granting summary judgment when there was a genuine issue of material fact as to what a reasonable investigation by Appellants' predecessors in interest would have revealed. The Supreme Court vacated the district court's declaration that NHD was the fee simple titleholder of the right-of-way, and the matter was remanded for further proceedings. View "Nampa Hwy Dist #1 v. Knight" on Justia Law

Nine-year-old girl Shaeley Noel was seriously injured while playing on playground equipment owned by the City of Rigby (City) and located in the City’s South Park. Shaeley and her parents (collectively the Noels) filed suit in district court alleging willful and wanton conduct by the City in the construction and/or maintenance of its playground equipment. The City claimed the park was closed for winter at the time Shaeley was injured. A jury rendered a verdict in favor of the City when it found that the City did not owe a duty to Shaeley. The Noels filed a motion for a new trial, which the district court granted. The City appealed the district court’s decision to grant a new trial, as well as the district court’s decisions to deny the City’s motion for a directed verdict and the City’s motion to exclude the Noels’ expert witness. The Noels cross-appealed, arguing the trial court erred by: (1) rejecting of evidence of Shaeley’s unadjusted medical bills; (2) preventing the Noels’ expert witness from testifying regarding the City’s purported willful and wanton conduct; (3) allowing a jury instruction regarding comparative negligence; and (4) admitting of evidence regarding the seasonal closure of the park. The Idaho Supreme Court affirmed the district court decisions with regard to: (1) the City’s motion for a directed verdict; (2) the Noels’ motion for a new trial; (3) the Noels’ expert testifying; (4) the jury instruction; and (5) admission of evidence of the park closure. Additionally, the Court reversed the district court with respect to: (1) the Noels introducing Shaeley’s unadjusted medical bills; and (2) preclusion of the Noels’ expert from testifying that the City engaged in willful and wanton conduct. As a result, the matter was remanded for a new trial. View "Noel v. City of Rigby" on Justia Law

The Board of County Commissioners for Bonner County, Idaho (“Board”) granted Stejer’s, Inc.’s request for three variances (“the Variances”) from applicable lot setbacks required by the Bonner County Revised Code. Neighboring land owners, Frank Hungate and Thomas Hungate, as trustees of the Hungate Trust, the A&E Family L.L.C., Anne Ashburn, Eleanor Jones, Frank Hungate, and John Hungate (collectively “the Hungates”) appealed the Board’s decision. The district court held that the Board erred in approving the Variances, but ultimately affirmed the Board’s decision after it determined that the Hungates failed to show that their substantial rights were prejudiced. The Hungates appealed to the Idaho Supreme Court. Finding no reversible error, the Supreme Court affirmed. View "Hungate v. Bonner County" on Justia Law

This appeal stemmed from a dispute between neighbors over the validity of an easement. In 1997, the Fitzpatricks bought two adjacent lots. In 2016, while they still owned both lots, they recorded an easement that granted the owners of the first lot (themselves) the right to maintain, repair, and improve a portion of the second lot. They then sold the second lot to the Kents. Two years later, the Kents allegedly made certain modifications to the easement area that the Fitzpatricks opposed. The Fitzpatricks claimed that the easement precluded the Kents from making the modifications, but the Kents asserted that the easement was unenforceable. The Fitzpatricks and Kents filed cross-complaints in district court, each seeking to quiet title to the easement area. The district court granted the Kents’ motion for summary judgment after concluding that the easement was invalid under the merger doctrine. The district court granted costs to the Kents but denied them attorney fees under Idaho Code section 12-121. The Fitzpatricks appealed the district court’s summary judgment decision and the Kents cross-appealed the district court’s denial of their request for attorney fees. Finding no reversible error, the Idaho Supreme Court affirmed the district court's decisions. View "Fitzpatrick v. Kent" on Justia Law