Justia Idaho Supreme Court Opinion Summaries

This appeal arose from a dispute in district court over two liens on real property: a deed of trust and a mortgage. Appellants (Insight, LLC and several other companies) are assignees of a mortgage secured by 160 acres of real property owned by Summitt, Inc., which included an 18-acre parcel Summitt purchased from Respondents Patrick and Monica Gunter. The Respondents held a deed of trust on the 18-acre parcel. Summitt defaulted on its obligations to both Insight and the Gunters. Insight filed suit naming Summitt's principals and the Gunters as defendants. The Gunters denied that their deed of trust was junior to the Insight-Summitt mortgage. The district court denied Insight's motion for summary judgment because there was an issue as to who was the initial encumbrancer. After trial, the district court found that the closing of the Gunter-Summitt deed of trust was separate and independent from the Insight-Summitt mortgage. Furthermore, the court found that the Gunters' deed of trust effectively encumbered the Gunter property at the time the transaction between Summitt and the Gunters closed. However, it found that the Insight mortgage on the combined 160-acre parcel did not create an encumbrance on the Gunter property until the Gunter-Summitt transaction closed. On appeal, Insight argued that the mortgage had priority as a matter of law because it was a purchase money mortgage that was first recorded. Upon review, the Supreme Court concluded that the district court's finding that Insight had notice of the Gunters' deed of trust was clearly erroneous. Further, the Insight-Summitt mortgage was a purchase money mortgage , and that the court erred in concluding the deed of trust took priority. Accordingly, the Supreme Court vacated the district court's judgment in this case and remanded the case for further proceedings. View "Insight LLC v. Gunter" on Justia Law

The issue before the Supreme Court in this case arose from a commercial lease dispute. Boise Mode, LLC leased space in its building to Donahoe Pace & Partners, Ltd. (DPP). Timothy Pace executed a personal guarantee for the lease. During the term of the lease, Boise Mode remodeled part of the building for another tenant. After raising concerns to Boise Mode about the adverse effects of the construction to its business, DPP eventually stopped paying rent and vacated the premises prior to the end of the lease. Boise Mode then brought an action against DPP, alleging breach of contract, and against Pace for breaching the guarantee. DPP counterclaimed, alleging that the disruption caused by the construction constituted breach of contract and constructive eviction. After Boise Mode moved for summary judgment on all claims and counterclaims, DPP requested a continuance to complete discovery. The district court denied DPP's motion and ultimately granted Boise Mode's motion for summary judgment. DPP appealed the grant of summary judgment as well as the district court's denial of its request for a continuance. Upon review, and finding no error, the Supreme Court affirmed. View "Boise Mode, LLC v. Donahoe Pace" on Justia Law

The issue before the Supreme Court in this case concerned an order granting summary judgment in an action to foreclose a mechanic’s lien by ParkWest Homes, LLC against Julie Barnson and Mortgage Electronic Services, Inc. (MERS). In "ParkWest Homes, LLC v. Barnson," (238 P.3d 203 (2010)) the Court held that ParkWest’s lien on the property in question was valid. After that, property encumbered by ParkWest's lien was conveyed to Residential Funding Real Estate Holdings, LLC via a trustee's sale. Residential intervened in this action and sought summary judgment. The district court dismissed MERS from the action and granted Residential summary judgment. It ruled that Residential took the property free and clear of ParkWest’s lien on the property, because neither Residential nor its predecessors-in-interest were named in this action. ParkWest appealed the district court’s grant of summary judgment. Upon review, the Supreme Court held that ParkWest's lien was lost as to Residential, because it failed to name any holders of legal title in its action to enforce the lien. The district court was therefore affirmed. View "ParkWest Homes v. Barnson" on Justia Law

Appellant Camas County appealed an injunction granted by the district court against the enforcement of Camas County Ordinances 150 and 153, and Resolutions 96 and 103 (2007 zoning amendments). Plaintiff-Respondent George Martin opposed the zoning amendments at a public hearing of the Camas County Board of Commissioners. In late 2008 while this case was still being adjudicated, Martin filed a complaint for declaratory judgment against 2008 zoning amendments. Camas County removed the case to the federal district court, which ultimately granted Martin's requested relief to the 2007 amendments. The federal district court then remanded the case to the state district court. Martin was granted attorney fees and costs as a result of the federal district court's order; the court held that Camas County acted without a reasonable basis in fact or law. Camas County appealed, maintaining that the district court abused its discretion in ordering the injunction and should have awarded the County attorney fees. Upon review, the Supreme Court found that the 2007 and 2008 zoning amendments were practically identical. Both cases involved the same property owned by Martin in Camas County. Thus, the facts between this case and the underlying case "Martin I" (concerning the 2007 amendments) were nearly identical. . . . as such, Martin properly conceded that the district court's injunction against the 2007 zoning amendments should have been reversed. Martin also properly conceded that his award of attorney fees by the district court also should have been reversed. The County was not entitled to a fee award. View "Martin v. Smith" on Justia Law

A builder sued a homebuyer in a Utah state district court for failing to pay some charges for his home's construction; the homebuyer counterclaimed, alleging that the construction was defective. Shortly before the Utah state court rendered a judgment, the homebuyer sued the builder in an Idaho state district court, seeking to void the builder's allegedly fraudulent transfer of a ranch and appurtenant water shares in Franklin County, Idaho. The homebuyer also filed and recorded the Utah judgment in Franklin County, creating a lien on all of the builder's currently owned and after-acquired real property located there. The builder reversed the transfer, and therefore the ranch became subject to the lien. However, the homebuyer continued to prosecute the fraudulent-transfer action, and did not request a writ of execution. A few months later, the builder declared bankruptcy. In a settlement agreement, the bankruptcy trustee agreed to lift the automatic stay on the homebuyer's fraudulent-transfer action, and also abandoned the ranch from the bankruptcy estate. The homebuyer's judgment lien was not discharged in the builder's bankruptcy, but apparently all in personam causes of action were discharged. The fraudulent-transfer action was repeatedly delayed, and after five years from the entry of the Utah judgment, the homebuyer's lien expired. The homeowner had never attempted to renew the judgment, and had never requested a writ of execution from the Idaho district court. The builder then moved for summary judgment; the homebuyer filed a cross-motion for summary judgment, arguing that he was entitled to a writ of execution. The Idaho district court granted the builder's motion for summary judgment, denied the homebuyer's motion for summary judgment. Upon review, the Supreme Court concluded that the district court properly granted summary judgment in favor of the builder because no relief could be granted based on the expired lien, and because there was no timely request of a writ of execution for the Utah judgment. View "Grazer v. Jones" on Justia Law

Appellants Raoel and Janet Clark and Jerry and Betty Peterson appealed the district court's grant of summary judgment in favor of Buku Properties, LLC. Buku filed suit against the Clarks and the Petersons to recover earnest money deposits after two codependent land sale contracts failed to close. At the time the parties entered into the land sale contracts, the properties were zoned "R-1," which allowed for a minimum density of one acre lots. However, after the contracts were executed, but prior to closing, the Jefferson County Planning and Zoning Commission began discussions to change the R-1 designation of the properties to R-5, which mandated a five acre minimum density. While conducting its due diligence, Buku discovered the County’s plan to change the zoning designation of the properties. Aware of the potential re-zoning, Buku sent Appellants proposed addenda to the land sale contracts seeking to extend the review period and closing date due to concerns about zoning and financing. The bank financing Buku’s purchase of the properties sent Buku a letter stating that Buku’s loan was only “conditionally approved,” and that, if the property were re-zoned R-5, the property value would be decreased. The bank stated that in order to fund the loan it “must receive verification from Jefferson County that this property will remain zoned R-1 Residential.” Buku sent Appellants’ counsel a letter demanding that all of the earnest money, except for a non-refundable amount from the Peterson contract, be returned. When none of the earnest money was returned, Buku brought suit alleging: (1) return of earnest money under contract; (2) conversion; and, (3) unjust enrichment. Additionally, Buku requested prejudgment interest on the earnest money and attorney fees. Appellants filed a counterclaim with their answer, asserting seven claims: (1) specific performance; (2) breach of contract; (3) unjust enrichment; (4) estoppel; (5) promissory estoppel/unjust enrichment; (6) Consumer Protection Act violations; and, (7) attorney fees. Upon review, the Supreme Court found no error in the district court's judgment, and affirmed its decision to grant summary judgment in favor of Buku. View "Buku Properties v. Clark" on Justia Law

At issue in this case was the definition of the width of an easement for an irrigation pipeline. Dalton Gardens Irrigation District (the District) owned pipeline and intended to replace an existing four-inch pipe with a ten-inch pipe. A portion of the pipeline crosses Diane Ruddy-Lamarca's property. The parties agreed that an easement of some kind existed in favor of the District. However, they disagreed regarding the nature and width of that easement. The district court held that the District had an express easement and an easement by prescription that were identical in location and sixteen feet wide. The District appealed, claiming that the district court erred by restricting the easement to sixteen feet in width and requiring it to make every effort to preserve trees and a drain field on Ruddy-Lamarca's property. Upon review of the district court order, and finding no error in its decision, the Supreme Court affirmed. View "Ruddy-Lamarca v. Dalton Gardens" on Justia Law

Ida-Therm, LLC appealed the grant of summary judgment in favor of Bedrock Geothermal, LLC, which held that a reservation of "all the oil, gas, and minerals, in, on, or under the surface of [deeded] lands," in a 1946 warranty deed included the geothermal resources underlying the property. The district court determined that the Deed's mineral reservation severed the mineral estate from the surface estate, and that geothermal resources were included in the scope of the mineral estate. Because the Supreme Court found that the term "mineral" was ambiguous with respect to the deed in question, and because ambiguous grants in deeds are construed against the grantor, the Court construed the grant in favor of Ida-Therm and reversed the district court. View "Ida-Therm v. Bedrock Geothermal" on Justia Law

Kootenai County (the County) and Panhandle Health District No. 1 (the District) filed an action against Peggy Harriman-Sayler and Terry Sayler, seeking injunctive relief to prevent the Saylers from operating a recreational vehicle (RV) park without a conditional use permit, from occupying or using a building without a certificate of occupancy, and from operating a subsurface sewage system without a permit. The district court granted summary judgment in favor of the County and the District. The Saylers appealed, asking the Supreme Court to vacate the district court's judgment. Their argument on appeal was that the RV park did not require a permit because it was allowed as a nonconforming use and that the sewage system and other building were properly permitted. Finding no error in the district court's decision, the Supreme Court affirmed. View "Kootenai County v. Harriman-Sayler" on Justia Law

This issue before the Supreme Court in this case centered on an action to recover damages from a well driller who drilled a well that later caved in. The district court granted the well driller's motion for summary judgment on the ground that the alleged claims of negligence and breach of contract were barred by the applicable statutes of limitations, and the court dismissed the action. Upon review, the Supreme Court held that that the breach of contract claim was indeed barred by the statute of limitations and that the negligence claim was barred by the economic loss rule. The Court affirmed the district court's dismissal of the case. View "Stapleton v. Jack Cushman Drilling" on Justia Law