Justia Idaho Supreme Court Opinion Summaries

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

Several neighbors all owning lakefront property objected when others planned on building a dock on the lake and using a portion of what was believed to be a designated common area. Plaintiffs appealed a district court judgment that dismissed their claims that they had the right to use parcels of property designated as common areas in a plat that was void because the persons who recorded the plat did not own all of the real property included in the plat and that awarded the plaintiffs an easement across a parcel of land owned by the cross-appellants. Upon review of the records, the Supreme Court affirmed the district court's judgment except as to the width of the easement. View "Siegwarth v. Opportunity Management Co., Inc." on Justia Law

Utah resident Elham Neilsen wanted to purchase a residence close to the city of Tyler in Smith County, Texas. He contacted Plaintiff-Appellant Holli Telford because he had heard that she knew how to acquire properties through tax or other distress sales and had contacts for obtaining financing for prospective buyers. Mr. Neilsen entered into an agreement with Plaintiff that she would bid on the property and sell it to him after she had obtained the warranty deed. Plaintiff submitted a bid, but did not obtain title to the property because, according to her, it was wrongfully redeemed by the prior owners after she had spent money improving it. She sought specific performance of the alleged contract with Smith County, Texas, or damages for breach of the alleged contract. Defendants moved to dismiss this case for lack of personal jurisdiction. The district court granted the motion and dismissed the case with prejudice as to them and without prejudice as to the other defendants. The Supreme Court affirmed the dismissal for lack of jurisdiction, but vacated the dismissal with prejudice and remanded the for entry of a judgment dismissing the complaint without prejudice. View "Telford v. Smith County" on Justia Law

Appellant Intermountain Real Properties, LLC, appealed a district court's grant of summary judgment to Respondent Draw, LLC. Intermountain initially brought a cause of action, as an assignee of a materialmen's lien, against Draw and other defendants to recover payment on work paving a private drive a property development project. The district court granted summary judgment to Draw on the grounds that Intermountain failed to raise a material issue of fact as to Draw's liability on the contract. Specifically, the district court found that Intermountain's lien as it applied to Draw's property was void, and that Draw should have quiet title to its property. Finding no error or abuse of discretion, the Supreme Court affirmed the district court. View "Intermountain Real Properties, LLC v. Draw, LLC" on Justia Law

In 1997, Plaintiff-Respondent Donald Steuerer needed money and asked his across-the-street neighbor N.E.M. Richards to loan him some. Richards agreed to loan Steuerer $5,000. Steuerer executed and recorded a warranty deed conveying a half interest in his property. Richards paid additional funds Steuerer's benefit, and Steuerer contemporaneously executed a quitclaim deed to the property in favor of Richards. The parties later disputed: (1) how much Richards had paid to or for the benefit of Steuerer and (2) whether the deeds were intended as absolute conveyances or mortgages to secure repayment of the loans. Steuerer filed suit against Richards seeking to quiet title to the property. The district court found: (1) the deeds executed by Steuerer to the Property were intended by the parties to be mortgages to secure loans made by Richards to Steuerer; (2) Steuerer owed Richards $9,285.11 plus prejudgment interest; and (3) upon payment of the monetary award, Richards had to re-convey the property to Steuerer. Richards appealed to the Supreme Court, arguing the district court's judgment was not "sustained by the facts found." Finding no error in the district court's judgment, the Supreme Court affirmed. View "Steuerer v. Richards" on Justia Law