Justia Idaho Supreme Court Opinion Summaries

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

This appeal stemmed from a 1983 Ground Lease of property in Pocatello which Quail Ridge Medical Investors, LLC (Quail Ridge) leased from Pocatello Hospital, LLC d/b/a Portneuf Medical Centers, LLC (PMC). Previously, Quail Ridge appealed a declaratory judgment entered by the district court which found 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 at issue. The Supreme Court affirmed the court’s declaratory judgment. While the first appeal was pending, PMC filed a new action seeking payment of the adjusted rents. In the second action, the district court found on summary judgment that Quail Ridge breached the Ground Lease by failing to pay the adjusted rents. Quail Ridge appealed, arguing the breach of contract and breach of guarantee claims are barred under res judicata. Finding no reversible error, the Supreme Court affirmed. View "Pocatello Hospital v. Quail Ridge Medical Investor" on Justia Law

This case centered on a proposed easement over a rough, relatively unimproved, single-vehicle dirt road that travels over property the City of Twin Falls owned in the Snake River Canyon, south of the Snake River. H.F.L.P., LLC owned three parcels in the Snake River Canyon, west of Rock Creek. At trial, H.F.L.P. claimed it had a prescriptive easement and an easement by necessity over the property, but the district court ultimately entered judgment in favor of the City. H.F.L.P. argued on appeal that the district court: (1) did not have subject matter jurisdiction over the case; (2) erred when it held that H.F.L.P. failed to prove a prescriptive easement and an easement by necessity; and (3) erred when it admitted photographic overlays over H.F.L.P.’s objections at trial. Finding no reversible error, the Supreme Court affirmed. View "H.F.L.P. v. City of Twin Falls" on Justia Law

In 2010, plaintiffs Terri Boyd-Davis and Brian Davis filed suit to determine the boundary line between their property and their neighbors, defendants Timothy and Carol Baker. The district court entered a partial judgment quieting title in the disputed property. The Bakers appealed, and Boyd-Davis cross appealed. The district court’s construction of the deeds changed all of the calls in both deeds. The Supreme Court concluded that was not a reasonable construction of the deeds. "It does not matter whether the Clarks intended to give Jean Coleman more land than was reasonably contained within the legal descriptions of her deeds. Changing the calls, particularly the call of the southern boundary of the 1970 deed, takes land that under our recording statutes was deeded to the Bakers. We therefore reverse the partial judgment of the district court." Because the Court reversed the partial judgment, it did not consider the other issue raised by the Bakers on appeal. View "Boyd-Davis v. Baker" on Justia Law

This case consolidated several individual cases dealing with claims for nonpayment against the developer of the Summer Wind at Orchard Hills residential and golf course development in Canyon County. Stanley Consulting, Inc. appealed the district court’s decision as to the priority date for Stanley’s engineer’s lien. Integrated Financial Associates, Inc. (“IFA”) cross-appealed the district court’s decision granting Knife River’s summary judgment motion based on the court’s decision that Knife River had a valid priority lien for paving work it did on roadways and golf cart paths without having to designate the lien between the two projects. After its review of the claims, the Supreme Court concluded the district court erred when it determined an engineer’s priority under Idaho Code section 45-506 for rendering professional services dates back to when the first on-site professional services were rendered. Furthermore, the Court held the district court erred when it granted summary judgment in favor of Knife River on its lien claim priority. Accordingly, the district court’s judgments were vacated and the case is remanded for further proceedings. View "Stanley Consultants v. Integrated Financial Associates" on Justia Law

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