Justia Idaho Supreme Court Opinion Summaries

Margaret Butcher and her former husband purchased property in 2005 with a loan secured by the property from Home Federal Bank. Butcher received the property in their divorce in 2009, and she subsequently defaulted on the loan. Wells Fargo Bank, the indorsee of the loan, foreclosed on the property. At the foreclosure sale, Federal Home Loan Mortgage Corporation (FHLMC) purchased the property with a credit bid. FHLMC then filed a post-foreclosure eviction complaint for ejectment and restitution of the property. The magistrate court granted FHLMC's motion for summary judgment and entered a final judgment in favor of FHLMC. Butcher appealed. The district court affirmed the magistrate court's decision. Butcher appealed again, but finding no reversible error, the Supreme Court affirmed too. View "Federal Home Loan Mortgage Corp. v. Butcher" on Justia Law

In 2005, Herbert and Julie Thomas opened a $2,000,000.00 home equity line of credit (the HELOC) with U.S. Bank. To secure the obligation, the Thomases executed a deed of trust in favor of U.S. Bank to their property in Sun Valley. A few months later, the Thomases approached Citimortgage, Inc. seeking refinancing. Blaine County Title Associates (BCT) issued a Commitment for Title Insurance under which Stewart Title Guarantee Company agreed to issue a policy to CitiMortgage so long as all prior deeds of trust, including the U.S. Bank Deed of Trust, were released so that CitiMortgage would be in first lien position with regard to the Thomas Property. To that end, BCT contacted the local branch of U.S. Bank in Ketchum to determine the HELOC payoff amount. In response, U.S. Bank faxed BCT a screen shot of an account inquiry reflecting the balance owed on the HELOC. The Thomases closed with Citimortgage a few weeks later, and the Citimortgage loan was secured by a deed of trust on their property. The Citimortgage deed of trust was recorded days later. This appeal arose from a lien priority dispute between U.S. Bank and CitiMortgage. The district court concluded that U.S. Bank lost its first priority position on the Thomas property after finding that CitiMortgage delivered a demand for reconveyance and U.S. Bank failed to release its deed of trust as required by Idaho Code section 45-1514. U.S. Bank appealed, contending that the district court misallocated the burden of proof, that testimony offered by CitiMortgage was inadmissible, and that CitiMortgage failed to prove delivery of the demand for reconveyance. CitiMortgage cross-appealed the district court's decision that CitiMortgage was not entitled to attorney fees and costs. Upon review, the Supreme Court concluded the district court misallocated the burden of proof, that the district court did not err in admitting Citimortgage's proffered testimony, and that it could not determine whether the district court's findings of fact were supported by substantial and competent evidence because the court failed to evaluate certain evidence. As such, the Supreme Court vacated the district court judgment and remanded the case for further proceedings. View "U.S. Bank National Association N.D. v. Citimortgage, Inc." on Justia Law

Spirit Ridge Mineral Springs, LLC appealed a judgment entered in favor of Franklin County dismissing Spirit Ridge's complaint which had requested abatement of a private nuisance and for an injunction against a gun range operated by Franklin County adjacent to its property. In a bench trial, the district court ruled that Spirit Ridge had failed to demonstrate that there was an ongoing and continuing nuisance at the time of the trial. Spirit Ridge appealed. The Supreme Court affirmed: the district court record reflected a lack evidence to show that a nuisance existed after 2008. View "Spirit Ridge Mineral Springs v. Franklin County" on Justia Law

This appeal stemmed from the sale of dairy cattle that were subject to Appellant Farmers National Bank’s (FNB) perfected security interest and Respondent J&M Cattle Company’s (J&M) agister’s lien. The net sale proceeds received from the sale of the dairy cattle were insufficient to satisfy both FNB’s perfected security interest and J&M’s agister’s lien. J&M filed an action for declaratory relief to resolve FNB’s and J&M’s competing interests. Although FNB’s perfected security interest had a priority date that predates J&M’s lien, the district court determined that J&M’s lien had priority over FNB’s perfected security interest. The district court entered a final judgment in favor of J&M, and FNB appealed. Finding no reversible error, the Supreme Court affirmed the district court's decision. View "J&M Cattle Co v. Farmers National Bank" on Justia Law

At the center of this appeal was ABC Agra, LLC's action seeking a declaratory judgment against Critical Access Group, Inc. ("CAG") regarding the enforceability of a real property use restriction. Because there were no existing or proposed uses that implicated the restriction, the district court determined that the claim was not ripe and granted CAG's 12(b)(6) motion to dismiss. Finding no reversible error, the Supreme Court affirmed this dismissal. View "ABC Agra v. Critical Access Group" on Justia Law

This appeal stemmed from a 1983 Ground Lease of over four acres of property in Pocatello which Quail Ridge Medical Investors, LLC leased from Pocatello Hospital, LLC (d/b/a/ Portneuf Medical Centers, LLC (PMC)). Quail Ridge appealed a declaratory judgment which held that PMC was entitled to an adjustment in the annual rent owed by Quail Ridge from $9,562.50 annually to $148,500 annually, and that Quail Ridge was obligated to pay PMC $416,812.50 in rent for the period of 2010 to 2012. Finding no reversible error, the Supreme Court affirmed. View "Pocatello Hospital v. Quail Ridge Medical Investor" on Justia Law

Richard Giesler and Idaho Trust Deeds, LLC appealed a district court's judgment declaring the rights and obligations on a contract. This case arose out of several oral and written agreements between Giesler and Gregory Hull that related to purchasing and subdividing property. After a bench trial, the court found that Hull sold the property to Giesler, but the parties had a later oral contract where Hull promised to pay off Giesler's loans in exchange for half of the subdivision's net profits. The court held that neither party materially breached the contract and ordered Hull to timely pay Giesler's loans and Giesler to complete the subdivision within certain deadlines. On appeal, Giesler argued Hull failed to prove damages and the district court's remedies were erroneous. Upon review, the Supreme Court affirmed the district court in part, vacated in part, and remanded the case for further proceedings. The Supreme Court found that substantial and competent evidence supported the district court's findings of fact, but that the district court erred in its remedies. The Court vacated the portions of the district court's decision regarding: (1) the conversion payment of half the irrigation equipment's value; (2) the deadlines for completing Parcels 2 and 3; and (3) the provisions that order consequences to encourage performance under the contract. View "Hull v. Giesler" on Justia Law

DAFCO LLC sought recovery against Stewart Title Guaranty Co. on a lender's title insurance policy and against AmeriTitle, Inc., the closing agent for the lending transaction, claiming that it sustained injury as a result of a defective deed of trust. The district court granted summary judgment in favor of Stewart and AmeriTitle, resulting in this appeal by DAFCO. Finding no reversible error, the Supreme Court affirmed. View "DAFCO v. Stewart Title Guaranty Co" on Justia Law

Northwest Farm Credit Services recovered a deficiency judgment against the Appellants following the foreclosure of two mortgages on property located in Valley County. Lake Cascade Airpark, LLC, Donald Miller, and Candace Miller appealed the judgment, contending that the reasonable value of their foreclosed property was substantially more than the value determined by the district court. Finding no reversible error, the Supreme Court affirmed. View "NW Farm Credit Svcs v. Lake Cascade Airpark" on Justia Law

In 2006, Richard Myers owned the property at issue in this case. At the time, the property was subject to a deed of trust in favor of First Horizon Home Loans. Myers enlisted Michael Horn and his company, Frontier Development Group (FDG) to build a residence on the property, which First Horizon financed. However, in April of 2007, Myers filed for bankruptcy, and First Horizon rescinded the construction loan and instructed FDG to halt construction when the project was only fifty percent complete. The structure was left exposed to the elements for fourteen months. Following Myers' bankruptcy, foreclosure proceedings were initiated, and Myers hired Kathleen Horn (Michael Horn's wife), of Windermere Real Estate/Teton Valley to list the property for sale. The Caravellas, who were Ohio residents, looking for property in the Teton Valley, contacted their real estate agent who put them in touch with Kathleen Horn who provided them with information on the stalled Myers project. Kathleen Horn eventually put the Caravellas in touch with Michael Horn. The Caravellas traveled to Idaho, met with Kathleen Horn, and spent two days inspecting the property. The Caravellas testified that Kathleen Horn minimized issues with the house, telling them that it was "in good shape,""structurally sound,"and a "great house."The Caravellas chose not to have a professional inspection performed and closed on May 5, 2008. After closing, the Caravellas and Michael Horn agreed that Horn would complete construction on the house in accordance with Myers' original plans. In reaching this agreement, the Caravellas testified that they believed they were dealing with Horn as an individual. The total contract price for the first phase of work that the Caravellas authorized was $88,500. However, the Caravellas paid FDG $138,097.24 for the first phase before refusing to pay any more. Much of the money that the Caravellas paid to FDG was for unauthorized work or work that was completed in a nonconforming or substandard manner. The Caravellas hired a second builder to complete the first phase and to remedy the substandard work. FDG initiated this action by filing a complaint to foreclose on a lien for construction services and building materials provided to, but not paid for by, the Caravellas. The Caravellas filed an amended counterclaim alleging that FDG and Horn: (1) breached the parties' contract; (2) breached the duty of good faith and fair dealing; (3) violated the Idaho Consumer Protection Act; (4) breached the implied warranty of habitability; (5) committed slander of title; (6) committed fraud and misrepresentation; (7) engaged in a civil conspiracy; and (8) acted negligently. The district court held that FDG's lien was defective and dismissed it. The district court also held that FDG breached its contract with the Caravellas by: (1) failing to complete agreed upon work in conformity with the plans and in a workmanlike manner; (2) charging the Caravellas for unauthorized and defective work; and (3) substantially overbilling the Caravellas for work and materials that were not authorized and never provided. As to the Caravellas' fraud counterclaim, the district court concluded that the Caravellas failed to establish all nine elements of fraud and dismissed the claim. The district court also concluded that Horn was not personally liable. The district court awarded the Caravellas $113,775.45 in attorney fees, $5,484.83 in costs as a matter of right, and $200.00 in discretionary costs. The Caravellas timely appealed. Upon review, the Supreme Court concluded the district court erred by applying the incorrect evidentiary standard to the Caravellas' fraud counterclaim, but that error was harmless. The Court affirmed that portion of the district court's judgment dismissing the Caravellas' fraud claim, and reversed that portion of the judgment dismissing the Caravellas' claims against Michael Horn personally. In all other respects, the Supreme Court affirmed the district court's decision. View "Frontier Development Grp v. Caravella" on Justia Law