Justia Idaho Supreme Court Opinion Summaries

This appeal arose from a condemnation action brought by the Idaho Transportation Board (ITB) against HI Boise, LLC. ITB sought to acquire a strip of land as part of a project to improve the I-84/Vista Avenue Interchange in Boise. ITB offered HI Boise the condemned property's appraised value of $38,177, but HI Boise filed a counterclaim for inverse condemnation, claiming damages of $7.5 million for additional lost rights of access and visibility. HI Boise appeals the district court's summary dismissal of those claims. Because the Supreme Court found that neither claim involved a compensable taking, the Supreme Court affirmed. View "Idaho Transportation Board v. HI Boise, LLC" on Justia Law

This case was the third appeal to the Supreme Court arising from a 2002 real estate transaction between Thomas and Colleen Birch-Maile and the Theodore L. Johnson Revocable Trust. Attorney and Real Estate Broker Thomas Maile advised the Trust to reject an offer to sell certain trust property. Months later, Mr. Maile submitted an earnest money agreement for the same property. The prospective buyers, collectively the Taylors, sued the Mailes and Berkshire Investments, LLC (the company that the Mailes formed and to whom they assigned rights to the property) for professional malpractice and breach of fiduciary duties. The Mailes filed suit seeking to set aside a 2006 judgment against them, which the Court affirmed in the second appeal. The district court determined on summary judgment that the 2006 judgment was res judicata with regard to the issues raised in the Mailes' complaint. At trial the jury awarded damages against the Mailes on the Taylors' counterclaim. The Mailes appealed and the Supreme Court affirmed: the district court was correct in summarily dismissing the Mailes' lawsuit and denying their motion for JNOV. Further, the district court did not abuse its discretion in awarding attorney to two of the prospective buyers. View "Berkshire Investments, LLC v. Taylor" on Justia Law

The issue before the Supreme Court in this case concerned the approval of a permit application for a Livestock Confinement Operation (LCO), also known as a Concentrated Animal Feeding Operation (CAFO), by the Jerome County Board of County Commissioners. The Board approved the application after a remand by the district court of the Board's decision previously denying the permit. Several individuals and organizations opposed to the LCO because of the potential harms to the neighboring farms and to the Minidoka National Historic Site petitioned the district court for review of the Board's decision. The district court affirmed the Board's approval of the permit, finding in the process that four of the organizations concerned with the effects on the Minidoka National Historic Site lacked standing. Several of the objecting parties appealed the district court's decision, asking the Supreme Court to find that these parties had standing to challenge the permit approval, that the Board's procedure for presenting evidence before the Board violated procedural due process rights, and that the Board failed to follow all of the county's relevant zoning ordinances when it approved the application. The issue central to the Court's opinion pertained to standing of all the appellant-organizations, the Board's procedure for presenting evidence throughout the LCO permit application process, the constitutionality of the "one mile rule" of Idaho Code section 67-6529, and the application of the Jerome County Zoning Ordinances. The Court concluded that the Board properly applied its zoning ordinance to the LCO permit application process, that I.C. 67-6529 was not unconstitutional, and that the public was afforded appropriate due process prior to, and during the LCO permit application hearing. View "Friends of Minidoka v. Jerome County" on Justia Law

HJ Grathol is a California general partnership that owed real estate in Idaho. Grathol purchased a parcel for development. The Idaho Transportation board later sought to condemn sixteen acres of the parcel in order to realign US Highway 95 and to construct an interchange with State Highway 54. Grathol contended that the Board failed to negotiate for the sixteen acres in good faith because the Board's offer did not account for the extension of two roads which were believed to have significantly increased the property's value. Grathol also asserted that the Board failed to file its complaint and order of condemnation in accordance with Idaho law before moving for early possession of the property pursuant to a "quick take" provision. Upon review, the Supreme Court concluded that the Board indeed did negotiate in good faith for the subject property, and filed its complaint and order of condemnation in accordance with the applicable statute. Therefore, the Supreme Court affirmed the district court's decision that the "quick take" provision in question was satisfied. View "Idaho Transportation Board V. HJ Grathol" on Justia Law

In 2008, Pioneer Irrigation District filed suit against the City of Caldwell seeking declaratory and injunctive relief, as well as the removal of urban stormwater discharge conduits constructed by the City without Pioneer's authorization. The district court granted summary judgment in favor of Pioneer. The court held that Pioneer held exclusive interests in its irrigation easements and rights-of-way such that Pioneer could maintain trespass claims against the City. The court also held that I.C. 42-1209 granted Pioneer the power to remove encroachments constructed without its permission that it deemed to unreasonably or materially interfere with its easements and rights-of-way. The district court held that review of certain decisions by the irrigation district would be limited to whether they were arbitrary and capricious or reached in an unreasonable manner. The City moved for permissive appeal, which motion the district court granted. Upon review, the Supreme Court affirmed the district court's decision, except for its holding that irrigation easements and rights-of-way were exclusive interests. View "Pioneer Irrigation v. City of Caldwell" on Justia Law

This appeal arose from an action brought by Stonebrook Construction, LLC against Chase Home Finance, LLC where it sought to foreclose a mechanic's lien. The district court granted Chase's motion for summary judgment, holding that Stonebrook was precluded from placing a lien against the subject property because it did not properly register under the Idaho Contractor Registration Act (ICRA) Stonebrook appealed, arguing that Chase lacked standing to assert this defense and was not within the class intended to be protected by the ICRA. Alternatively, Stonebrook contended that the good-faith registration of one member of the LLC constituted actual or substantial compliance with the requirements of the ICRA. Upon review of the matter, the Supreme Court affirmed: "the plain language of the Act unambiguously indicates that the Legislature intended to require all limited liability companies engaged in the business of construction to register as contractors and to preclude those that do not register from enforcing mechanic's liens. Although the result for Stonebrook is harsh, it is the result the Legislature intended. [The Court was] not at liberty to disregard this legislative determination as to the most effective means of protecting the public." Thus, the Court declined to vacate the district court’s decision. View "Stonebrook Construction, LLC v. Chase Home Finance, LLC" on Justia Law

Property at issue in this case was a five-sided parcel roughly the shape of a rectangle. North of the property is a paved road that curves northwest. On the east side, a north-south right-of-way that provided access from the paved road to a lot adjoining the property to the south. In 2006, Defendants-Respondents Cornelius and Patricia Mercea purchased the property; in 2007, Plaintiff-Appellant Diana James purchased the property from the Merceas. Prior to the purchase, she did not have any conversations with the Merceas, nor did they make any representations regarding the property except those contained in the property disclosure form required by the Idaho Property Condition Disclosure Act. Plaintiff obtained title insurance from First American Title Insurance Company, and First American Title Company, Inc., was the closing agent. In 2009, Plaintiff filed this action against the Merceas, the prior owners of the parcel, and First American Title Insurance Company, alleging that when she purchased the property, she believed that the pavement going from the paved street to her garage was entirely her private driveway and that she did not know that most of that pavement was on a public right-of-way. She also alleged that she believed a portion of an adjoining lot was also part of the property she purchased. The trial court granted summary judgment in favor of the Merceas, finding that they did not violate the Idaho Property Condition Disclosure Act or commit fraud by failing to disclose that the public road alongside the property was not a private driveway on the property. The Supreme Court affirmed the trial court's judgment finding Plaintiff failed to meet her burden of presenting sufficient evidence to maintain her claims. View "James v. Mercea" on Justia Law

Defendant-Respondent High Mark Development, LLC owned a commercial building located in the City of Ammon. In 2006, it had leased a portion of the building to The Children's Center, Inc., for a period of ten years. In 2007, High Mark listed the real property for sale through its realtor. Plaintiff-Appellant Thomas O'Shea, a resident of California, learned of the property through a realtor friend in Boise. Appellant and his wife were trustees of the "Thomas and Anne O'Shea Trust u/d/t Dated November 2, 1998," which they had formed to protect their assets and provide for their children. They decided to purchase the real property. The Trust entered into a real estate contract agreeing to purchase the property from Defendant High Mark for $3.7 million. The sale closed late 2007. The Children's Center made no payments to Plaintiffs after they acquired the property. Shortly thereafter, the Children's Center vacated the property, and went out of business. Plaintiffs filed suit against High Mark and two of its principals, Gordon, Benjamin and Jared Arave arguing Defendants had induced them to acquire the property by providing false information that the Children's Center was current in its payments of rent and/or concealing or failing to disclose that the Center had failed to pay all rent due under the lease. Plaintiffs alleged claims for breach of contract and fraud by misrepresentation and nondisclosure against all of the Defendants, but the issues were narrowed after cross motions for summary judgment. The case was tried to a jury on the issues of: High Mark's breach of contract; High Mark's alleged fraud by misrepresentation and nondisclosure; Gordon Arave's alleged fraud by misrepresentation and nondisclosure; and Benjamin Arave's alleged fraud by nondisclosure. The jury returned verdicts in favor of all of those Defendants. The Plaintiffs filed a motion for a judgment notwithstanding the verdict on the issue of liability or, in the alternative, for a new trial, which the district court denied. The Plaintiffs then timely appealed. Upon review, the Supreme Court concluded that the jury could reasonably have determined that the Plaintiffs failed to prove that they were damaged by the breach and that they failed to prove that the breach of contract caused any damages. In addition, the jury could have found that the breach did not cause any damages because the Plaintiffs did not have the right to terminate the contract for the misrepresentation in an estoppel certificate. Therefore, the district court did not err in denying the motion for a judgment notwithstanding the verdict on the breach of contract claim. View "O’Shea v. High Mark Development, LLC" on Justia Law

At issue in this case was a district court's grant of a motion for voluntary dismissal of a suit filed by Fern Peterson against Cecil and Yu Wen Davis, Kevin and Sherri Murray, David Lawrence and Private Wilderness, LLC (collectively, Private Wilderness). The issues arose from Peterson's attempt to sell property to the Davises, Murray and Lawrence. Private Wilderness asserted an easement over the property. Ultimately the case ended with the dismissal of a third-party complaint filed by Private Wilderness against Robert and Nancy Peterson (the Petersons). In resolving the appeal, the Supreme Court addressed issues raised by Private Wilderness concerning whether the district court erred when it concluded there was no prevailing party when it granted the voluntary dismissal. The Court also addressed the Petersons' cross-appeal, in which they argued that the district court erred in denying their motion for reconsideration of their I.R.C.P. 12(b)(6) and 12(c) motion to dismiss on the basis that it was moot, and by not addressing their pending summary judgment motion at the time of dismissal. Upon review, the Supreme Court vacated in part and remanded, upholding the district court's discretion concluding no prevailing party, but found the court erred by denying the motion for reconsideration. View "Peterson v. Private Wilderness, LLC." on Justia Law

This appeal arose from a decade-long fight over title to a piece of real property. Juan Cuevas allegedly agreed to sell the property to Defendant-Counterclaimant-Appellant Bernardino Barraza in 2001. However, after Barraza failed to pay the purchase price, Juan filed a quiet title action against Barraza. Barraza defaulted. While Barraza was seeking to set aside the default, Juan quitclaimed the property to his relative, Plaintiff-Counterdefendant-Respondent Wilfrido Cuevas. Meanwhile, Barraza was successful in setting aside the default on appeal. On remand, Juan defaulted and the district court quieted title in Barraza. Wilfrido then filed the present quiet title action against Barraza, in which the district court found the default judgment against Juan void and quieted title in Wilfrido. Upon review, the Supreme Court held that the default judgment against Juan is void, but vacated the summary judgment quieting title in Wilfrido as against Barraza. View "Cuevas v. Barraza" on Justia Law