Justia Idaho Supreme Court Opinion Summaries

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

In 2009, Joseph Pierce filed this action against Steven McMullen and Highland Financial, LLC, seeking damages for various violations of the Idaho Consumer Protection Act and for breach of contract, all based upon an alleged scam in which defendants represented that they could protect Pierce from losing his equity in real property that was facing foreclosure. He alleged that the defendants obtained title to his real property pursuant to a promise to assume the loans secured by the property, to market and sell the property, and to pay him at least $50,000 or more from the sale proceeds, depending upon the sale price. He claimed that he deeded the property to defendants, they failed to make the payments on the loans, and that the property was sold at a foreclosure sale. The complaint also alleged that Highland Financial was the alter ego of McMullen. Only McMullen appeared in the action, but he did not deny the allegations of wrongdoing in the complaint. When McMullen failed to appear at the trial, the district court ordered that he was in default, that Pierce prevailed on his complaint, and that he could present evidence of his damages. Pierce did so, but the district court later dismissed the action on the ground that Mr. Pierce had failed to prove liability. Finding that decision was made in error, the Supreme Court reversed the district court's decision and remanded the case for further proceedings. View "Pierce v. McMullen" on Justia Law

Camp Easton Forever, Inc., (“CEF”) and Daniel and Matthew Edwards appealed the district court’s grant of summary judgment to Inland Northwest Council Endowment Properties, LLC, and Inland Northwest Council of the Boy Scouts of America (collectively “INWC”). CEF and the Edwardses filed an action to declare the parties’ rights to property INWC owned on Lake Coeur d’Alene that had been used as a Boy Scout camp since 1929. The district court held CEF and the Edwardses lacked standing because CEF lacked a legally recognizable interest and the Edwardses were not certified as class representatives. The district court also held no trust existed because all prior agreements merged into an unambiguous deed. Upon review, the Supreme Court affirmed the district court’s grant of summary judgment to INWC on grounds that the deed was an unambiguous fee simple transfer. View "Camp Easton Forever, Inc v. Inland NW Council Boy Scouts of Amierica" on Justia Law

The issue this case presented for the Supreme Court's review centered on the reformation of a deed to real property. Appellant Augusta Greenheart challenged a district court decision that determined a warranty deed conveying a portion of land "with their appurtenances" did not transfer a water right to Greenheart as the purchaser of the property. The district court ordered the warranty deed reformed due to mutual mistake, and grounds of quasi-estoppel and waiver, and granted the sellers of the property, respondents Jay and Christine Brown, full water rights to the property. The district court entered a judgment reforming the deed accordingly and awarded attorney fees to the Browns as prevailing parties. Finding no reversible error, the Supreme Court affirmed the district court's judgment. View "Brown v. Greenheart" on Justia Law

In August 2006, Nagel Beverage Company approached the Youth Ranch and the Idaho Youth Ranch Foundation, Inc., about the sale of the real property. Nagel was looking to sell the property as part of a 1031 exchange and offered it to the Youth Ranch for $1,136,000 below the appraised value as a noncash donation. The Youth Ranch wanted to purchase the property and began to explore financing options with Key Bank. The Ada County Board of Equalization (the BOE) denied an application for a property tax exemption that the Youth Ranch and Idaho Youth Ranch Nagel Center, LLC asked for resulting from the donation. The Idaho Board of Tax Appeals affirmed that decision. The Youth Ranch and the LLC appealed. Ruling on the parties' cross-motions for summary judgment, the district court held that the property was not exempt from taxation. Finding no reversible error, the Supreme Court affirmed. View "Idaho Youth Ranch v. Ada County Bd of Equalization" on Justia Law

Roger and Barbara Stephens owned a parcel of real property consisting of about 270 acres on the west side of the highway and another parcel consisting of about 83 acres on the east side of the highway. They hired a realtor to sell the parcel on the west side of the highway. The realtor asked Northern Title Company of Idaho, Inc., to begin the initial title work for a sale of the property, including preparing a legal description for the sale of the parcel on the west side of the highway. Stephen Cummings noticed a "For Sale" sign on the Stephenses' property. Cummings negotiated to purchase the Stephens' property. He was faxed a copy of the commitment for title insurance issued in connection with the transaction. The legal description in the document included the Stephenses' property on both sides of the highway and two additional parcels they did not own. Based upon the legal description in those documents, Cummings believed that the property being sold included both parcels of the Stephenses' property. Northern Title discovered that the legal description it had prepared for use in the real estate contract and its title commitment for that transaction erroneously included the Stephenses' real property located east of the highway and two parcels of land they did not own. The legal description consisted of five paragraphs, each describing a separate parcel of real property. In an effort to correct that error, Northern Title created a revised legal description by inserting between the first and second paragraphs the words, "Except all of that portion of the following described land lying easterly of U.S. Highway 30." That change excluded the two parcels of property not owned by the Stephenses, but it did not exclude their land lying east of the highway because it was described in the first paragraph. On the date of closing, Northern Title recorded a warranty deed (Original Deed) granting to Cummings the real property described in the revised legal description, which was attached to the deed as Exhibit A. The legal description included the Stephenses' property on the east side of the highway. Mr. Stephens went to the county courthouse to pay the real estate taxes on the 83 acres of land east of the highway and was informed that he no longer owned that property. Cummings filed this action against Mr. Stephens over the erroneous deed. Stephens answered, denying Cummings's claims, and filed a third-party claim against Northern Title. He later dropped his third-party claim in exchange for Northern Title agreeing to indemnify him from any losses. Stephens then filed a motion for summary judgment, contending that there was a mutual mistake or a unilateral mistake in the legal description of the real property being sold. The district court held that there was a genuine issue of fact regarding mutual mistake, but it granted the motion on the ground that the undisputed evidence showed a unilateral mistake. One of the realtors had filed an affidavit stating that prior to the sale he had told Mr. Cummings that only the land west of the highway was being sold, and Mr. Cummings did not deny that fact. Cummings successfully moved for reconsideration, with the district court finding that there was a genuine issue of material fact as to what Cummings had been told about what property he was purchasing. Cummings then amended his complaint, adding Northern Title as a defendant and alleging that by recording the Correction Deed, Stephens and Northern Title breached the warranties of title in the Original Deed, converted the 83 acres lying east of the highway, and slandered Cummings's title to the real property. The district court granted Stephens's motion for involuntary dismissal as to all of the claims against him. And in its written findings of fact and conclusions of law, the district court denied all of Cummings's claims against Northern Title except one. It found that Northern Title acted negligently as a title and abstract company, and it awarded Cummings damages in the sum of $50,000, which was the sum he had paid to obtain an assignment of its contract to purchase the Stephenses' property. The court awarded Mr. Stephens costs and attorney fees against Cummings, and it awarded Mr. Cummings costs and attorney fees against Northern Title. Mr. Cummings appealed and Northern Title cross-appealed. The Supreme Court affirmed the dismissal of Cummings' claims against Stephens, and reversed claims against Northern Title on the ground that it assumed the duty of being an abstractor of title. View "Cummings v. Stephens" on Justia Law

The issue this case presented to the Supreme Court stemmed from a district court decision affirming the approval of a subdivision by the Board of County Commissioners of Clearwater County. In approving the subdivision, the Board approved three variances granted by the Clearwater County Planning and Zoning Commission with respect to the road providing access to the subdivision. A portion of the access road crossed over land owned by Edward and Donilee Shinn, who opposed the variances and petitioned the district court for judicial review. Upon review, the Supreme Court found that the Board erred when it failed to make the approval of the variance application expressly contingent upon judicial resolution of the access issue. The Court remanded the case back to the district court to determine whether the Shinns' substantial rights were prejudiced by the Board's decision. View "Shinn v. Bd of Co Comm Clearwater Co" on Justia Law