Justia Idaho Supreme Court Opinion Summaries

The issue presented for the Supreme Court's review stems from a quiet title action filed by Appellants Andrew and Kimberly Kirk against Ann Wescott. The Kirks bought a plot of land in Blaine County, referred to as Lot 7 of Block 1 of the Glassford Heights Subdivision (“Lot 7”). After purchasing Lot 7, the Kirks found out that Lot 8 of the subdivision had been granted an easement of access across the southeast corner of Lot 7. Wescott owned Lot 8. In 2012, the Kirks brought this action to quiet title, asking the court to terminate the easement encumbering their property. Both parties moved for summary judgment, asking the court to interpret the deed granting the easement. The district court granted partial summary judgment to Wescott, concluding that the easement was created and none of the events that would trigger its termination had occurred. The Kirks then filed two motions to amend the complaint, both of which the district court denied. After a bench trial, the district court dismissed the Kirks’ action for quiet title. Wescott sought an award of attorney fees, which the district court also denied. On appeal, the Kirks challenged the district court’s grant of partial summary judgment to Wescott and the court’s denial of their motions to amend the complaint. Wescott cross-appealed, challenging the district court’s denial of her motion for attorney fees. Wescott also sought an award of attorney fees on appeal. After review, the Supreme Court concluded the district court erred in its interpretation of the easement on summary judgment. The district court judgment in favor of Wescott was reversed and the case remanded to the district court to enter judgment in favor of the Kirks. Costs were awarded to the Kirks on appeal. View "Kirk v. Wescott" on Justia Law

Donna Simono attended a meeting hosted by Treasure Valley Area of Narcotics Anonymous (“TVNA”) at the Turner House in Mountain Home. When leaving the meeting, she fell down the stairs and injured her ankles. Simono brought a negligence action against Turner House, Larry Rodgers, and Cheryl Baker (collectively “Turner House”). Turner House filed a third-party complaint against TVNA, alleging that TVNA was responsible for maintaining the area where Simono fell. Turner House also sought indemnification for Simono’s claims. The jury returned a verdict finding neither Turner House nor TVNA negligent, and the district court entered judgment dismissing Simono’s complaint and Turner House’s third-party complaint. TVNA filed a motion seeking attorney fees against Turner House under Idaho Code section 12-120(3). The district court denied the motion for fees, concluding that the lawsuit was not based on a commercial transaction. TVNA appealed the district court’s denial of its motion for fees. Both TVNA and Turner House sought attorney fees on appeal. Finding that the district court erred in concluding that TVNA was not entitled to attorney fees, the Supreme Court reversed. Fees and costs on appeal were awarded to TVNA. View "Turner House v. Treasure Valley Area of Narcotics Anonymous" on Justia Law

A wildfire destroyed David and Kristina Parks’ house, which was insured by Safeco Insurance Company (“Safeco”). The Parks purchased an existing house, and Safeco paid the Parks a total of $255,000, the cost of the replacement house less the value of the land. The Parks filed a complaint against Safeco alleging: (1) they were entitled to $440,195.55 under the policy; and (2) Safeco committed bad faith in handling the claim. Safeco filed a Motion for Summary Judgment asserting that the policy was not breached and its conduct did not constitute bad faith. The Parks filed a Cross-Motion for Summary Judgment asserting that Safeco misrepresented the policy. Additionally, the Parks moved to amend their complaint to include a claim for punitive damages. The district court held that: (1) there was no breach of contract because the policy was unambiguous and the Parks received the amount due under the clear language of the policy; (2) Safeco did not commit bad faith in handling the claim because it complied with the terms of the policy and paid the Parks the amount owed; and (3) the Parks had not established a reasonable likelihood of proving facts at trial sufficient to support an award of punitive damages. The Parks appealed, but finding no reversible error, the Idaho Supreme Court affirmed. View "Parks v. Safeco Ins Co of Illinois" on Justia Law

Douglas and Brenda Lawrence (“the Lawrences”) challenged a district court judgment enjoining them from interfering with, impeding, or preventing Spectra Site Communications, Inc. (“Spectra”) from using or maintaining Blossom Mountain Road, which crossed the Lawrences’ property. Spectra leased property owned by Robert and Mark Hall (the “Halls”) located east of the Lawrence property. After a six-day bench trial, the district court held that Spectra had proven that the Halls have an easement implied by prior use and an easement implied by necessity. Accordingly, the district court found that Spectra, as a lessee of the Halls, was entitled to use and maintain Blossom Mountain Road. The district court also awarded Spectra costs and attorney fees. The Lawrences appealed, arguing, inter alia, that the district court erred in finding that the Halls had an easement upon which Spectra’s injunctive relief is based. Finding no reversible error, the Idaho Supreme Court affirmed. View "Spectra Site Communications v. Lawrence" on Justia Law

This appeal arose from a premises liability action brought against Walter Amundson, the owner of a piece of property in Kuna (the “Property”), by David Stiles, a social guest of one of Walter’s tenants. The district court dismissed the case on summary judgment, reasoning that: (1) Amundson had neither a general duty of care nor a duty to warn with respect to Stiles; and (2) although Amundson could be liable for any injury resulting from the negligent repair of the Property, Amundson's repair was not the proximate cause of Stiles’ injury. Finding no reversible error, the Supreme Court affirmed. View "Stiles v. Amundson" on Justia Law

This was the fourth time this case has been up to the Idaho Supreme Court. Following the last remand, the district court conducted a six-day bench trial, after which it entered its Memorandum Decision and Order granting Capstar Radio Operating Company an easement over the disputed road on Douglas and Brenda Lawrence's property. The Lawrences appealed, arguing, among other things, that the district court’s determinations regarding the easement claims were not supported by substantial and competent evidence. Finding no reversible error, the Supreme Court affirmed. View "Capstar Radio v. Lawrence" on Justia Law

In February 2003, Glen and Rachel Knapp entered into a written lease agreement with Lockridge Outdoor Advertising Agency to place a billboard sign on their property in exchange for annual rental payments. The lease was for a period of ten years, beginning May 1, 2003, with a five-year renewal provision after the original term expired. Lockridge assigned the lease to Canyon Outdoor shortly after it was executed. The lease agreement contained a provision that allowed Knapps to sell an easement to Canyon Outdoor for a lump sum. In May 2003, Canyon Outdoor paid a $12,000 lump sum, and the parties signed an easement agreement. Canyon Outdoor completed construction of the sign in May 2003. Neither the lease nor the easement agreement contained a legal description of the property. Neither document was recorded. In 2006, Knapps sold their property to Tiller and issued to Tiller a warranty deed with no restrictions. Tiller had discussions with Knapps about the lease agreement and reviewed the lease document prior to purchasing the property. Tiller also had a title policy issued that, due to the non-recording, did not disclose the easement. Tiller asserted that he was unaware of the easement until May 2013 when Canyon Outdoor faxed him a copy of the easement. Thus, Tiller argued that he was a bona fide purchaser under Idaho Code sections 55-606 and 55-812. Canyon Outdoor argued that Tiller, at minimum, had constructive notice of the easement and therefore did not qualify as a bona fide purchaser. The parties stipulated to have the district court decide the case on cross-motions for summary judgment. Finding that Tiller did not have actual or constructive notice of the easement and that Tiller conducted a reasonable investigation of the property, the district court ruled in favor of Tiller and found that the easement agreement executed by Knapps and Canyon Outdoor was unenforceable against Tiller. Canyon Outdoor appealed. Finding no reversible error, the Supreme Court affirmed. View "Tiller White, LLC v. Canyon Outdoor Media, LLC" on Justia Law

This case arose out of a permit application to obtain a water right filed by the respondents, North Snake Ground Water District, Magic Valley Ground Water District and Southwest Irrigation District (“the Districts”), to appropriate water from Billingsley Creek on real property owned by appellant Rangen, Inc. After the Director of the Idaho Department of Water Resources denied the application in a final order, the Districts petitioned for judicial review. The district court set aside the Director’s final order. Rangen appealed. Rangen historically diverted water from Billingsley Creek. Before the Department ruled on the Districts’ April 2013 application, Rangen filed a competing application on February 3, 2014. Rangen’s application sought to divert 59 cfs from Billingsley Creek for fish propagation, with the same source and point of diversion elements as the Districts had requested. On January 2, 2015, Rangen’s application was approved for 28.1 cfs for fish propagation with a priority date of February 3, 2014. This permit had apparently not been challenged. Department employee James Cefalo presided over a hearing on the Districts’ application and subsequently issued a Preliminary Order Issuing Permit in which he found that the application was made in good faith, did not conflict with the local public interest, and otherwise satisfied the necessary requirements. Therefore, he approved a conditional permit authorizing the Districts to appropriate 12 cfs from Billingsley Creek for mitigation purposes with a priority date of April 3, 2013. Rangen filed a protest of the hearing officer’s preliminary order with the Director. After the parties briefed the issues, the Director subsequently issued a final order overturning the hearing officer’s decision and denying the application. The Director concluded that the Districts’ application was made in bad faith and that the application was not in the local public interest. The Districts petitioned for judicial review, asserting that the Director abused his discretion and exceeded his authority in denying their application. On judicial review, the district court set aside the Director’s final order, concluding that the application was neither made in bad faith nor counter to the local public interest. The district court also rejected Rangen’s arguments that the Districts’ application was incomplete or speculative and that mitigation is not a recognized beneficial use of water under Idaho law. Rangen appealed again. After review of the district court record, the Supreme Court concluded the district court did not err in its judgment and affirmed. View "Rangen, Inc v. North Snake Ground Water Dist." on Justia Law

This case stemmed from a series of cases concerning the scope and location of Marti and Vernon Mortensen’s easement across Dennis and Sherrie Akers’ property. This dispute has made multiple trips to the Idaho Supreme Court. From its last trip, the Supreme Court remanded because the Akers were only entitled to an award of attorney fees under Idaho Code section 6-202 for those fees incurred in prosecuting the trespass claim and not for other theories of recovery. The case was remanded for the “sole purpose” of apportioning the attorney fees the Akers were entitled to recover for prosecuting their trespass claim. On remand, Marti Mortensen argued the Akers had not provided sufficient evidence to allocate attorney fees between the various causes of action. However, the Akers produced seventy pages of billing documentation, and their counsel went through that billing and marked every item that was chargeable to prosecuting the trespass claim, arriving at $55,917.21 in attorney fees. The district court found that this figure was reasonable and awarded fees in that amount. The district court then entered judgment awarding the Akers “apportioned attorney fees jointly and severally against each defendant in the amount of $55,917.21.” Since that time Marti’s former husband, Vernon Mortensen, passed away. Marti appealed. Finding no reversible error in the fee award, the Supreme Court affirmed. View "Akers v. Mortensen" on Justia Law

Charles and Donna Nickerson appeal from the grant of summary judgment in favor of PHH Mortgage and J.P. Morgan Chase Bank. The suit involved an action for judicial foreclosure of a loan by PHH Mortgage against the Nickersons, and third-party claims against J.P. Morgan Chase by the Nickersons. The Nickersons argued they were entitled to relief based on: mistakes by the court; surprise due to the actions and withdrawal of their former counsel; excusable neglect due to their reliance on their former counsel; new evidence showing PHH did not have standing to pursue foreclosure; fraud regarding PHH’s chain of title, the amount of default, and coercion of the Nickersons at closing; and misconduct of the opposing parties regarding the depositions of the Nickersons and the submission of a fraudulent affidavit. The district court denied the Nickersons’ motions, concluding that the Nickersons failed to present admissible evidence to support their claims. Finding no reversible error in the trial court's decision to grant summary judgment in favor of PHH Mortgage, the Supreme Court affirmed. View "PHH Mortgage v. Nickerson" on Justia Law