Justia Idaho Supreme Court Opinion Summaries

In 2010, Duane Mueller filed this action against Carolyn Hill, Kevin Thompson, Philomena Keys, and Northwest Shelter Systems, LLC (a company owned by Kevin Thompson and Philomena Keys), to recover damages for trespass after construction debris landed on his property from his neighbor Kevin Thompson's adjoining property. Kevin Thompson had caused cap rock to be installed on the portion of a driveway that was adjacent to the common boundary, replaced an existing culvert, and added a rock catch basin in order to address the problem of water runoff flowing onto the Mueller property. In an attempt to return the Mueller property to its pre-2008 condition, he also hired a company to remove material that had been dumped onto the Mueller property when building a roadway in 2008. In March 2013, the matter was tried to the district court without a jury, and it awarded Mr. Mueller damages for trespass plus court costs and attorney fees. The Defendants then timely appealed. After review, the Supreme Court affirmed the judgment except for $1,000 of the damages awarded, and remanded the case for the entry of an amended judgment. View "Mueller v. Hill" on Justia Law

The Board of Tax Appeals' (the BTA) denied appellant Jayo Development, Inc.'s application for a business inventory property tax exemption. In 2012, Jayo Development applied for a property tax exemption pursuant to Idaho Code section 63-602W(4), claiming that the property qualified as site improvements held by a land developer. The Ada County Board of Equalization (the BOE) denied the application. Subsequently, the BTA and the district court both affirmed the denial. On appeal, Jayo Development argued: (1) that the plain language of the statute entitled it to the exemption;, (2) that the district court erred in relying on IDAPA 35.01.03.620 in denying Jayo Development the tax exemption; and (3) that the 2013 amendment of Idaho Code section 63-602W(4) clarified the legislature's intent and supports its interpretation of the statute. Finding no reversible error, the Supreme Court affirmed. View "Jayo Development, Inc. v. Ada County Bd. of Equalization" on Justia Law

Thomas and Rebecca Arnold appealed the grant of summary judgment in favor of the City of Stanley. In 2012, the City provided notice to the Arnolds (and other interested parties) of the date and time for three public hearings and a regular city council meeting, all scheduled to take place on August 9, 2012. The first of the three public hearings was noticed to begin at 5:00 p.m. and was for the purpose of receiving public comment on proposed Ordinance 189, the ordinance that the Arnolds alleged affected their property rights. The second and third hearings were noticed to begin at 5:15 p.m. and 5:30 p.m., respectively (and were for the purpose of public comment on matters not at issue here). The regular city council meeting was noticed to begin at 6:00 p.m. The first two meetings were held at their scheduled times. The third meeting began five minutes early, at 5:25 p.m., and concluded at 5:29 p.m. The regular city council meeting, scheduled to begin at 6:00 p.m., commenced at 5:31 p.m. and adjourned at 6:55 p.m. Prior to the start of the 6:00 p.m. meeting, the City did not amend the notices it had provided or otherwise notify the public that the meetings would begin earlier than scheduled. The early start time of the 6:00 p.m. meeting and the City's failure to provide amended notice of the earlier start time were the issues presented in this appeal to the Supreme Court: it was at the 6:00 p.m. meeting that the mayor and city council deliberated toward a decision on Ordinance 189, eventually voting to adopt the ordinance. Although the Arnolds were fully aware of the agenda items to be discussed at the various meetings, at no time from the outset of the first meeting at 5:03 p.m. until the final meeting adjourned at 6:55 p.m. did they attend the meeting; the Arnolds conceded at oral argument that they had no intention of attending the meeting. Following adoption of Ordinance 189, the Arnolds filed an action against the City under Idaho Code section 67-2347(6), seeking to have the ordinance declared null and void because the City held the 6:00 p.m. meeting in violation of Idaho's open meeting law by starting the meeting early and failing to provide notice of the earlier start time. The district court held the Arnolds lacked standing to bring an enforcement action because the plain language of Section 67-2347(6) allows standing for such an action only to one who is actually affected by a violation of the open meeting law, instead of being affected only by a substantive action taken at the meeting. The court granted the City's motion for summary judgment on this basis. The Arnolds appealed. The Supreme Court affirmed the district court: because a plain reading of the statute contradicted the Arnolds' argument, and because they did not even claim to have been actually harmed by the 6:00 p.m. meeting's early start time, the Court found that their appeal was brought without a reasonable basis in fact or law. View "Arnold v. City of Stanley" on Justia Law

HJ Grathol ("Grathol") appealed a district court judgment awarding Grathol $675,000 in just compensation from the Idaho Transportation Department ("ITD"). ITD acted to condemn 16.314 acres to improve U.S. Highway 95. Those 16.314 acres were part of 56.8 acres that Grathol owned in Athol. After a bench trial, the district court held that just compensation would be based on the value of the 56.8 acre parcel. The court also held the property remaining after the condemnation suffered no severance damages. Grathol argued on appeal that the district court applied the wrong law and should have instead based just compensation on a 30 acre parcel. Grathol also argued that the district court ignored Grathol's severance damage evidence and improperly excluded testimony about damages from a proposed frontage road. Furthermore, Grathol appealed the district court's award of costs and discretionary fees to ITD, arguing that condemnors were not entitled to costs and that the court did not find ITD's discretionary costs were necessary and exceptional. Upon review, the Supreme Court found only that the district court erred in its award of attorney fees. The Court affirmed in all other respects, and remanded the case for recalculation. View "Dept of Transportation v. HJ Grathol" on Justia Law

Respondents Alan and Marilyn Golub obtained a judgment against appellants and recorded the judgment. Kirk-Hughes Development, LLC (KHD), owned a parcel of real property in the county and therefore the judgment constituted a lien against its property. KHD claimed to have executed a deed of trust on the property in favor of Kirk-Scott, Ltd. (KS), several years before Golubs acquired their lien. Golubs filed an action for declaratory judgment, seeking a ruling that their judgment lien had priority over KS’ unrecorded deed of trust. The district court granted summary judgment to Golubs, finding that their lien had priority. KHD and the other appellants appealed that decision. After review, the Supreme Court found no reversible error, and affirmed the district court's judgment. View "Golub v. Kirk-Hughes Development" on Justia Law

The issue this case presented for the Supreme Court's review centered on a dispute between two creditors as to whose claim against their debtor's property has priority. Respondents Alan and Marilyn Golub recorded a judgment against their judgment debtor, Kirk-Hughes Development, LLC (KHD), giving Golubs a judgment lien on property owned by KHD in Kootenai County. KHD claimed to have executed a deed of trust on the property in question several years before Golubs acquired their lien. The beneficiary of the deed of trust was another defendant, Kirk-Scott, Ltd. (KS). The district court granted summary judgment to Golubs, finding that Golubs' duly recorded judgment lien had priority over KS' prior, unrecorded deed of trust. KS appealed. Finding not reversible error, the Supreme Court affirmed the district court in all respects. View "Alan Golub v. Kirk-Scott, LTD" on Justia Law

This appeal centered on the attempted foreclosure of two mechanic's liens on property encumbered by deeds of trust. In "ParkWest Homes, LLC v. Barnson," 302 P.3d 18 (2013) (ParkWest II), the Idaho Supreme Court held that an action to foreclose a mechanic's lien on property encumbered by a deed of trust must "name the trustee who holds legal title to the property" within the six-month statutory limitation to lien enforcement. Appellant ACI Northwest Inc. challenged the holding from ParkWest II after the district court determined that ACI lost its mechanic's liens for failing to name the trustees in its foreclosure action against Respondents Monument Heights LLC, Dan Jacobson, Sage Holdings LLC, Steven Lazar, the Mitchell Martin and Karen C. Martin Family Trust dated August 9, 2005, Devon Chapman, HLT Real Estate LLC, Anthony St. Louis, Andrea Stevens, and Lilly Properties Inc. (collectively "the Monuments Heights group"). Due to this determination, the district court granted summary judgment in favor of the Monuments Heights group. ACI appeals to this Court. Finding no reason to disturb the holding in ParkWest II, and finding no reversible error in the trial court's decision in this case, the Supreme Court affirmed. View "ACI Northwest, Inc. v. Monument Heights, LLC" on Justia Law

This case concerned three small, adjacent parcels of land in Bear Lake County which lined up in a north to south direction and are bordered by State Highway 89 on the west and Bear Lake on the east. In 1998, the northern parcel was owned by Peggy and David Everton; the middle parcel was owned by Annette and Sterling Wallentine; and the southern parcel was owned by Jeanne Macvicar. Historically, Macvicar had accessed her property by a driveway that went through the Everton and Wallentine properties. The driveway left State Highway 89 at the northwestern edge of the Everton parcel, traveled along the western edge of the Everton and Wallentine parcels, and terminated at Macvicar's property. in 1998, Macvicar filed a complaint against the Evertons and Wallentines, requesting that the district court declare an easement existed along the western edge of their parcels. In 2000, the parties filed a Stipulation for Settlement. The district court accepted the stipulation and entered its Judgment and Decree of Quiet Title (the 2000 Judgment). The Evertons, the Wallentines, and Macvicar subsequently sold their parcels to the parties to this appeal. Macvicar sold her property to Jim and Maryann Plane, who transferred the property to the Jim and Maryann Plane Family Trust (the Trust). The Planes had actual knowledge of the 2000 Judgment and the Stipulation when they purchased Macvicar's property. Jason and Janae Skinner purchased the parcels owned by the Evertons and Wallentines. This controversy arose after September 27, 2012, when the Idaho Transportation Department (ITD) wrote the Skinners a letter demanding that the Skinners remove their "illegal" driveway. However, the letter also enclosed a permit application for the Skinners to submit which would "allow for the continued use of this currently illegal access." On April 1, 2013, the Trust filed a motion, pursuant to I.R.C.P. 60(b)(4), requesting that the district court void three sentences of the 2000 Judgment. The Trust argued these provisions were void because the district court lacked personal and subject matter jurisdiction to address the State's right-of-way because the State was not a party to the litigation. The effect of eliminating these three sentences would be to expand the width of the easement over the Skinners' parcels from a maximum of five feet to ten feet. On April 18, 2013, the Skinners filed an application with ITD, seeking permission to continue to access the State right-of-way for purposes of a driveway. ITD issued a permit authorizing the Skinners and the Planes to use up to five feet of the State right-of-way. The district court denied the Trust's motion, and the Trust appealed. Finding no reversible error in the district court's decision, the Supreme Court affirmed it. View "Plane Family Trust v. Skinner" on Justia Law

Gordon, Thomas, and Brent Arave appealed a district court’s decision to dismiss their motion to compel International Real Estate Solutions, Inc. to record a satisfaction of judgment. On a motion for reconsideration, the district court concluded that a final default judgment entered against the Araves in Utah for breach of a guaranty and fraud, which was domesticated in Idaho under Idaho Code section 10-1302, had not been satisfied by the foreclosure sale of property not owned by the Araves. The Araves argued on appeal to the Idaho Supreme Court that the judgment against them should have been offset by the value of the property that was foreclosed upon. Finding no reversible error in the district court's decision, the Supreme Court affirmed. View "Int'l Real Estate Solutions, Inc. v. Arave" on Justia Law

The issue this appeal presented for the Supreme Court's review was whether Jeff and Karen Owen's deed should have been reformed to grant an easement across their property for the benefit of Brent and Moura Regan. The Regans ownedof a 50.55-acre parcel of land in Kootenai County. The Owens owned an adjoining 10.7 acre parcel to the east of the Regans. The Owens’ property was acquired by two separate conveyances: they acquired a 10.3-acre parcel from David and Helen Hanna by a warranty deed in 2003 (Owen Parcel); and they acquired a 0.4-acre parcel from Kootenai County by a 2005 deed (Orphan Parcel). The Orphan Parcel adjoined the northern boundary of the Owen parcel. The Owens moved for summary judgment seeking a denial of the Regans’ claim for reformation. The district court granted the Regans’ motion and denied the Owens’ motion, holding that the Regans’ claim for reformation based upon a mutual mistake was not barred by the statute of limitations and that there was a mutual mistake between the Original Grantors and a predecessor-in-interest as to the northern boundary of the parcel that the the predecessor purchased. It also held that the Owens were on inquiry notice of that mistake when they purchased the Owen Parcel and later the Orphan Parcel. Finally, the court held that even if they did not have notice of the mistake, granting the Regans an easement across the Owens’ property would not prejudice them. The Owens appealed. The Supreme Court vacated and remanded for further proceedings: the trial court did not cite any authority holding that a court can relocate the easement to another portion of the Owens’ land merely because it did not believe that doing so would prejudice them. Furthermore, there was no finding by the district court that the alleged prescriptive easement across the Orphan Parcel increased its value. View "Regan v. Owen" on Justia Law