Justia Idaho Supreme Court Opinion Summaries

This was an appeal of a judgment which held that a mechanic’s lien had priority over a mortgage. The judgment was predicated upon the district court's refusal to permit the mortgagee to withdraw an admission made in open court by its counsel that the mechanic's lien was valid. Upon review of the matter, the Supreme Court reversed the district court and held that the mechanic's lien was invalid because the lien did not show that it was verified before a person entitled to administer oaths. View "First Federal Savings Bank of Twin Falls v. Riedesel Engineering, Inc." on Justia Law

This was an appeal in which the appellants challenged a judgment ejecting them from real property purchased by the respondent at a mortgage foreclosure sale. The appellants' primary complaint was that the district court denied their claim for unjust enrichment under which they sought to recover damages for improvements they had made to the real property prior to the foreclosure sale. Upon review, the Supreme Court affirmed the district court's judgment. View "Indian Springs v. Andersen" on Justia Law

This was an appeal of a district court’s grant of summary judgment in favor of the State of Idaho, former Governor James E. Risch, and former Fish and Game Department Director Steven Huffaker (collectively "Defendants"). Appellants, Rex and Lynda Rammell, owners of a domestic elk ranch, brought suit against Defendants to recover for the loss and destruction of elk that escaped from their ranch in 2006. Upon review of the matter, the Supreme Court affirmed the judgment of the district court. View "Rammell v. Idaho" on Justia Law

This appeal arose from a claim filed by the Idaho Department of Health and Welfare in the probate proceeding of George D. Perry, the deceased spouse of Medicaid recipient Martha J. Perry. The Department sought to recover funds under I.C. 56-218 from the sale of the couple’s home (their only significant asset) to recoup Medicaid benefits paid to Martha during her lifetime. The magistrate court disallowed the Department’s claim for recovery, finding that Martha had no interest in the real property because George, acting for Martha under a power of attorney, conveyed the property to himself before his death. That decision was upheld on appeal to the district court. The Department appealed to the Supreme Court. Upon review, the Court found that the district court erred in finding that federal law preempted the Department's ability to recover from George's estate what was once Martha's community property during the marriage. The Court reversed the district court and remanded the case for further proceedings. View "Id. Dept. of Health & Welfare v. McCormick" on Justia Law

Krystal Kinghorn and Kelly Clay agreed that Clay would co-sign for a loan for Kinghorn's benefit. In order to protect Clay in the event that Kinghorn defaulted on the loan, Kinghorn agreed to execute a quitclaim deed to real property that Clay could record if King defaulted. When Kinghorn defaulted, Clay recorded the deed and conveyed the property to BRP Incorporated (BRP). Kinghorn filed suit, and the district court unwound the conveyance, granting summary judgment that the deed was a mortgage and that Kinghorn had a right to redeem the property. BRP filed and prevailed upon a cross-claim against Clay for breach of its warranty deed. BRP later petitioned for a writ of attachment. The district court held that Kinghorn had not timely exercised her right to redeem and ordered Clay to foreclose the mortgage. Kinghorn and Clay stipulated that Kinghorn would purchase the property and that the court should perform an accounting and set off of their liabilities. The court found that a balance remained due to Clay, and entered judgment in his favor. Clay's attorney, Brian Smith (Smith), then moved to perfect an attorney's lien as to the judgment. Kinghorn deposited the amount due with the court, and after the court denied Smith's motion, the court awarded the deposited funds to BRP. Smith appealed the court's denial of the motion for lien, as well as the order for transfer of funds to BRP. Upon review, the Supreme Court dismissed the appeal, finding Smith was not a party to the action, and therefore had no standing to assert his claim. View "Kinghorn v. Clay " on Justia Law

This appeal involved a dispute over whether Capstar Radio Operating Company held an easement over the property of Douglas and Brenda Lawrence. Capstar filed a Motion for Summary Judgment, alleging in the alternative, that an easement existed based on the theory of either an easement by implication, an easement by necessity, or a prescriptive easement. The district court filed its Order granting summary judgment, finding that Capstar holds an easement implied by prior use, an easement by prescription, and an easement by necessity. The Lawrences appealed to the Supreme Court, arguing that the district court erred in granting summary judgment because genuine issues of material fact existed. The Lawrences also argued that the district court abused its discretion by failing to recuse itself for alleged bias, and that the lower court erred in determining that the Lawrences' defenses of laches and statute of limitations were meritless. Upon review, the Supreme Court reversed the district court's order granting summary judgment and remanded the case for trial on the (1) easement implied by prior use, (2) easement by necessity, and (3) prescriptive easement theories. The Court affirmed the district court's decision denying the Motion for Disqualification for Cause and affirms the court's ruling that the Lawrences' defenses of laches and statute of limitations were without merit. Nevertheless, the Court ordered that a new judge be assigned to preside over all further proceedings in this case. View "Capstar Radio v. Lawrence" on Justia Law

Jerry and Terry Machado (the Machados) and Richard Clifton appealed a district court's decision finding that their properties were burdened by an express easement and an implied easement by necessity in favor of Charles and Carol Ryan and Kristopher Jones. Ryan and Jones cross-appealed the district court's failure to rule on their claims of implied easement by prior use and easement by prescription. In 1970, Promised Land & Cattle Company conveyed a parcel of land to Timberland Resources, Inc., which included an easement to a then-existing logging road. Later that year, Timberland sold the land to Clifton with the deed containing the easement. The Ryans purchased an adjacent parcel to the Clifton property, conveyed with "all tenements, hereditaments and appurtenances thereunto belonging." The Ryans built a home on the property, accessing their parcel by a private road, access to which was via the former logging road. From 1993 until this suit was filed, the Ryans maintained the private road. Timberland conveyed another portion of its parcel to Jones, with the deed containing reference to the private road. When Clifton purchased his lot from Timberland, there was no public road providing access to what later became the Jones property, and the only access to the Jones property was the private road. Machado filed a complaint to quiet title and for declaratory relief in 2007 with regard to the easement across his property from the private road. Ryan answered and counter-claimed, asking the district court to find an easement of Machado's property by express, implied by necessity, implied by prior use and prescription. Jones was permitted to intervene. Upon review of the district court record, the Supreme Court found that the deed from Timberland to Clifton was unambiguous and did not create an express easement. The Court concluded that there existed an implied easement by necessity as to the Jones property, but to as to the Ryan property. With regard to the Ryans, the Court concluded that the Ryans could not "create" an implied easement because they sited their home in the lease accessible quadrant of their property. The Court reversed the district court with regard to finding an express easement over the Machado property and for finding an easement implied by necessity over the Machado and Clifton properties for the benefit of the Ryans. However, the Court affirmed the district court finding an easement implied by necessity for the benefit of the Jones property. The case was remanded for further proceedings on issues that were not addressed due to the court's findings on the other easement issues. View "Machado v. Ryan" on Justia Law

This case concerned the ownership status of Coolwater Ridge Road in Idaho County. The predecessors in interest of appellant Paddison Scenic Properties, Family Trust, L.C. granted rights of way to the United States for a road which became Coolwater Ridge Road. In the district court, Paddison sought a declaratory judgment that the rights of way did not constitute a public road or highway under Idaho law. That court held that the rights of way were public because the criteria for common law dedication were met. Upon review, the Idaho Supreme Court vacated the district court's judgment because it concluded this case was not ripe for adjudication. View "Paddison Scenic Properties Family Trust v. Idaho County" on Justia Law

This appeal was a consolidation of two actions relating to residential leases on State endowment lands. In one action, the Attorney General sought a declaratory ruling that I.C. 58-310A, which exempts so-called "cottage site" leases from conflict auctions, was unconstitutional in light of Article IX, section 8 of the Idaho Constitution. The district court determined that I.C. 58-310A was constitutional, and thus, dismissed the Attorney General's complaint. The Attorney General appealed that decision. In the other action, Gladys Babcock and several others who lease cottage sites on Payette Lake filed an action against the State Board of Land Commissioners and the Idaho Department of Lands Director. The Payette Lake Lessees alleged that the Board breached their lease agreements when it declined to renew the expiring leases for an additional ten years. The district court granted summary judgment to the Board, finding the Payette Lake Lessees had failed to exhaust their administrative remedies. The Payette Lake Lessees filed a cross-appeal challenging that decision. Upon review of the cases, the Supreme Court reversed the district court's ruling on the Attorney General's claim because I.C. 58-310A was unconstitutional. The Court vacated the district court's holding with respect to the Payette Lake Lessees' claim and remanded both cases for further proceedings. View "Wasden v. Board of Land Commissioners" on Justia Law

This case concerned an appeal by Frank and Gayle Marek (the Mareks) of the district court's decision and judgment decreeing the locations of two boundary lines in dispute between the Mareks and Earl and Sandra Lawrence. Because the deed at issue in this appeal was unambiguous, the Supreme Court found that the district court impermissibly consulted evidence outside of the language of the deed. The Court remanded the case for further proceedings. View "Frank Ronald Marek v. Earl A. Lawrence" on Justia Law