Justia Idaho Supreme Court Opinion Summaries

Dale Piercy appealed the district court’s dismissal of his amended action for declaratory relief, which challenged the validity of a herd district ordinance enacted in 1982 by the Canyon County Commissioners. The district court dismissed Piercy’s claim on the basis that it was barred by a seven-year statute of limitations or, in the alternative, a four-year statute of limitations. Piercy challenged the application of both statutes, and argued that Respondents Jennifer Sutton, Luis Guzman, and Canyon County waived any statute of limitations defense. Upon review, the Supreme Court found no reversible error, and affirmed the district court. View "Guzman v. Piercy" on Justia Law

David and Michelle White, and D.L. White Construction, Inc. appealed the district court’s judgment regarding the scope and location of the Whites’ easement across Dennis and Sherrie Akers’ property and the district court’s award of compensatory and punitive damages for trespass and emotional distress. The Supreme Court affirmed the district court’s judgment locating the easement and awarding damages, but remanded the case for apportionment of attorney fees. View "Akers v. D.L. White Construction, Inc." on Justia Law

The Campbells appealed the grant of summary judgment in favor of their neighbors The Kvammes. The parties disputed whether a fence between their respective properties constituted the true boundary of their land. The district court found that a land survey submitted by the Campbells lacked adequate foundation to be admissible, and therefore awarded the Kvammes summary judgment. On appeal, the Campbells argued that the district court abused its discretion when it disregarded the affidavit of their land surveyor in their motion for reconsideration. The Supreme Court found that because the district court granted summary judgment on two independent grounds. The Campbells challenged only one of those grounds on appeal. By law, an appellant must challenge all grounds to prevail. The Court therefore affirmed the district court's grant of summary judgment. View "Campbell v. Kvamme" on Justia Law

In 2006, the Christensens began construction of a fabric building adjacent to the property line shared with the McVicarses. After its completion, the McVicarses filed a nuisance action alleging that increased noise, traffic, and dust diminished the value of their property and interfered with the enjoyment of their property. After a bench trial, the district court ruled in favor ofMcVicarses, finding the Christensens’ course of conduct unreasonably interfered with the McVicarses’ enjoyment of their property and was therefore a private nuisance. Furthermore, the court found that there was no evidence to support the McVicarses’ claim of public nuisance or the Christensens’ unclean hands defense. The Christensens appealed. Upon careful consideration, the Supreme Court held that the district court erred to the extent that it considered the building’s size and proximity to the McVicarses’ property to constitute a nuisance. Because the building’s size and proximity do not in and of themselves constitute a nuisance, the district court erred in requiring the McVicarses to move the building from its current location. Therefore, the case was remanded for analysis of whether the cumulative effects of the activities on the property constituted a nuisance in fact. View "McVicars v. Christensen" on Justia Law

Borrower Gregory Renshaw refinanced the mortgage on his home in 2007. Borrower did not make the payments due under the promissory note, and in 2010, the trustee under the deed of trust commenced nonjudicial foreclosure proceedings. Borrower filed this action against the mortgage broker, the lender, MERS, and the trustee. Ultimately, summary judgment was granted in favor of MERS and a partial judgment was entered dismissing this action as to it. Borrower appealed. Finding no reversible error, the Supreme Court affirmed. View "Renshaw v. MERS" on Justia Law

Bremer, LLC and KGG Partnership (collectively "Bremer") appealed a district court’s grant of summary judgment to East Greenacres Irrigation District ("EGID") and the district court’s denial of several additional motions. This case arose after EGID looped its pressurized water system to a main water line extension that Bremer constructed to serve Bremer’s land. Bremer claimed the extension was an illegal tax. The district court granted EGID summary judgment on the grounds that Bremer and EGID had an agreement under I.C. 43-330A where Bremer was responsible for constructing water line improvements to serve their land. Bremer argued on appeal that the district court erred because there were genuine issues of material fact regarding: (1) whether the parties reached an agreement under I.C. 43-330A; and (2) whether EGID had authority to require Bremer to pay for the extension. Finding no error, the Supreme Court affirmed the district court in all regards. View "Bremer v. E. Greenacres Irrig Dist" on Justia Law

The issue on appeal in this case stemmed from a district court’s review of a final order from the Director of the Idaho Department of Water Resources. The senior surface water rights holders (Surface Water Coalition) challenged the court’s order affirming the methodology established by the Director for determining material injury caused by the pumping of junior groundwater rights holders (Idaho Groundwater Appropriators). The Coalition also appealed the court’s failure to require the Director to issue a single final order. The Groundwater Appropriators and Intervenor City of Pocatello asserted on cross-appeal that the proper evidentiary standard for determining material injury is a preponderance of the evidence, rather than clear and convincing evidence. Finding no reversible error on appeal or cross-appeal, the Supreme Court affirmed. View "A&B Irrigation v. ID Dpt of Water Resources" on Justia Law

Rob and Becky Vance appealed a district court order that granted partial summary judgment to John and Carole Hoch. The Vances challenged that part of the court's decision holding the Hochs' warranty deed granted them an easement over the "upper road." Alternatively, the Vances argued that the district court erred in finding that the warranty deed was unambiguous. The Vances and Hochs were each conveyed a portion of the original grantor's property, and each received a warranty deed that contained a number of provisions concerning easements. Ultimately, this case centered on the interpretation of those easements. Upon review of the district court record, the Supreme Court concluded the district court did not err in its decision. Accordingly, it affirmed. View "Hoch v. Vance" on Justia Law

Plaintiffs-Appellants Norman and Robin Riley appealed the district court's grant of summary judgment in favor of respondents Spiral Butte Development, LLC and Jim Horkley. Plaintiffs alleged breach of contract against Spiral Butte and sought specific performance of the parties' Lease Option Agreement. Finding no reversible error, the Supreme Court affirmed. View "Riley v. Spiral Butte Development, LLC" on Justia Law

Black Rock Development, Inc. developed a planned unit development consisting of residential homes and a golf course on the shore of Lake Coeur d'Alene. Black Rock Development recorded covenants, conditions, and restrictions (CC&R's) applicable to the development. The CC&R's created the position of "Declarant," named Black Rock Development as the Declarant, stated the rights of the Declarant, defined the time period that the Declarant would be entitled to exercise those rights, and specified the qualifications for a "Successor Declarant." The golf course in the development was developed and owned by The Club at Black Rock, LLC. The Club conveyed its real property to the Washington Trust Bank in lieu of foreclosure. Black Rock Development also assigned to the Bank all of its rights and interests as the Declarant under the CC&R's. The Bank then assigned the real property and the Declarant rights to West Sprague Avenue Holdings, LLC. West Sprague deeded the real property and assigned the Declarant rights to an entity named The Golf Club at Black Rock, LLC, which was a different entity than The Club. Black Rock Development assigned to The Golf Club any Declarant rights that Black Rock Development may still have retained due to any procedural or substantive defect in the prior assignments. Plaintiffs, who are the owners of at least one lot in Black Rock and are members of the Black Rock Homeowner's Association, Inc., filed this action against The Golf Club seeking a declaratory judgment that it was not qualified to be a Successor Declarant and therefore could not exercise Declarant rights. Both sides moved for summary judgment on the issue of whether The Golf Club satisfied the requirements of being a Successor Declarant under the CC&R's. The district court held that it did. It therefore dismissed the complaint and awarded court costs, including attorney fees, against Plaintiffs. Plaintiffs then appealed. Upon review, the Supreme Court concluded The Golf Club did not qualify as a Successor Declarant; it did not take title to Property for the purpose of sale and development. Because The Golf Club did not qualify as a Successor Declarant, it could not exercise the rights or powers of a Declarant. Therefore, the Supreme Court reversed the district court's judgment, including its award of costs and attorney fees to The Golf Club. View "Sky Canyon Properties, LLC v. The Golf Club at Black Rock, LLC" on Justia Law