Justia Idaho Supreme Court Opinion Summaries

Defendants Robert and Margaret Harvey owned 220 acres of farmland near a section of irrigation canal owned by Plaintiff Lower Payette Ditch Company. The canal delivered water to approximately 490 landowners and 13,000 acres of irrigated farmland. Defendants pumped water from Plaintiff's canal to irrigate their farmland. In 2009, Plaintiff filed suit against Defendants, alleging that Defendants' irrigation of their land on a bluff caused landslides in 2003 and 2006 which damaged the canal. As a result of the 2006 landslide, a neighboring landowner whose property was also damaged sued both Plaintiff and Defendants which resulted in a jury verdict, assigning 5% of the damages to Plaintiff and 95% to Defendants. Plaintiff and Defendants eventually settled their dispute, and the district court entered a judgment adopting the parties' stipulation. Defendants then sought an award of attorney fees, and Plaintiff objected. The district court granted the objection, holding that there was no clear prevailing party." On appeal to the Supreme Court the issue was whether the district court erred in finding there was no prevailing party. The Court found that Defendants failed to show that the district court abused its discretion in determining that there was no overall prevailing party, and affirmed the lower court's decision. View "Lower Payette Ditch Co. v. Harvey " on Justia Law

Idaho Development, LLC (Idaho Development) advanced $1,100,000.00 to Teton View Golf Estates, LLC (Teton View), a joint venture made up of Idaho Development as a 33.3% owner and Rothchild Properties, LLC as a 66.7% owner. Teton View granted Idaho Development a promissory note secured by a deed of trust that specified a set monthly payment and stated that the entire amount was to be paid off in ninety days. Idaho Development filed an action to foreclose on the deed of trust after Teton View failed to satisfy the promissory note. DePatco, Inc., another lienholder on the property, filed a motion for summary judgment to recharacterize Idaho Development’s advance as a capital contribution, which was granted. Idaho Development appealed, arguing that there was a genuine issue of fact as to whether the entire $1,100,000 advance was intended to be a capital contribution. Idaho Development also appealed a subsequent summary judgment brought by ZBS, LLC, which relied on the recharacterization determination in holding that ZBS’ lien on the property had priority over Idaho Development’s lien. Upon review of the trial court's recharacterization of Idaho Development's lien, the Supreme Court concluded that there was a genuine issue of fact as to whether the entire $1,100,000 was intended to be a capital contribution, the district court therefore improperly granted summary judgment. The case was remanded for further proceedings. View "Idaho Development, LLC v. Teton View Golf Estates, LLC " on Justia Law

The issue on appeal in this case stemmed from a 2005 real estate purchase and sales agreement (PSA) entered into between Pines Grazing Association as the seller, and J.C. Investments (owner of Flying Joseph Ranch) as the buyer of the Pines Ranch. Prior to closing, the parties learned that approximately 80 acres of what Pines had previously believed to be a portion of Pines Ranch was omitted from the ranch's legal description. Pines retained attorney Fred Snook to assist with the acquisition of the 80 acres. Mr. Snook determined that the 80 acres had been deeded to Lemhi County and that the County still owned the land. In light of this, the parties entered an addendum to the PSA whereby they would proceed with the original closing on the ranch while giving Pines time to try to acquire the 80 acres from Lemhi County in order to sell the 80 acres to Flying Joseph Ranch. The sale closed before the parties learned that Lemhi County could not sell the 80 acres privately; the land had to be sold at public auction. Pines sent Mr. Snook to the auction to bid on the 80 acres. The parties' agents cut a side deal whereby Pines would be paid not to bid on the 80 acres. Flying Joseph ultimately won the land at auction. Flying Joseph's agent faxed Pines' agent an agreement and release of all claims for the 80 acres. Pines refused to sign, believing that the agreement was not part of the oral agreement not to bid at the auction. Pines subsequently filed suit to enforce the terms of the oral contract. Among the issues brought before the Supreme Court were whether the district court erred in denying Appellant’s motion for JNOV on the grounds that the $20,000.00 offered to refrain from bidding constituted an unauthorized brokerage commission. Upon review, the Supreme Court refused to enforce the oral agreement not to bid at the auction because it was an illegal contract in violation of the Sherman Act. "As such, the parties are left as they are with respect to the oral agreement not to bid, and neither party is entitled to attorney fees on appeal or in the district court with respect to all issues related to the oral agreement not to bid." The Court upheld the jury's finding that Pines did not breach the grazing lease. View "Pines Grazing Association, Inc. v. Flying Joseph Ranch, LLC " on Justia Law

Plaintiff-Appellant Kepler-Fleenor and several other property owners in Division III of the Sawtelle Mountain Subdivision challenged a district court's decision that an unnamed road in their subdivision was public by common law dedication. Although the road did not intrude on any lots in the subdivision, it straddled two lots, one of which belongs to Plaintiffs Joni Kepler-Fleenor and Kistin Fleenor, and the other of which belongs to Blue Sky Management, LLC. According to Plaintiffs, heavy construction traffic heading into and out of an adjoining subdivision was bothersome and was damaging the unnamed road. Plaintiffs installed a berm and a gate to block traffic on the road, but the County removed it believing the disputed road to be public. After the County removed the road obstructions, Plaintiffs filed this lawsuit seeking a judgment to declare the road as private. The district court granted the County’s Motion for Summary Judgment, holding that the plat unambiguously showed the disputed road to be dedicated to public use. Because the subdivision plat unambiguously dedicated the road, the Supreme Court affirmed the district court’s ruling. View "Kepler-Fleenor v. Fremont County " on Justia Law

At the heart of this case laid the existence of two disputed roadways or easements over the Appellants Chris and Dana Belstlers’ property benefitting Respondents Karen and Howard Conines. Since purchasing the property in 1998, the Conines have used two roads to cross the Belstler property and access their property. In the summer of 2006, the Belstlers requested that the Conines cease using the roads. The Conines ceased using the lower of the two roads, which had been cabled and locked by the Belstlers, but refused to cease using the upper road. The parties held discussions but were unsuccessful in resolving the dispute. At district court, an express easement was found over both roads, and a prescriptive easement was found over the upper road. The case was appealed, and on remand, a different district court judge held that there were no express easements. Upon review of the trial court record, the Supreme Court concluded that the district court erred on reconsideration in finding there were no express easements over the Belstler property. The Court reinstated the first district court opinion. View "Belstler v. Sheler (Conine)" on Justia Law

Petitioner-Appellant Brian Sopatyk sought judicial review of the Lemhi County Board of Commissioners' decision to validate Anderson Creek Road, which ran the length of his property. He contended the road never became public and, if so, was abandoned. He also maintained that the validation was an unconstitutional taking, that it was error for the road easement to be validated at fifty-feet wide, that one of the commissioners was biased against him, that the road illegally invades federal public lands, and that the Board of Commissioners failed to explain why the validation is in the public interest. Upon review, the Supreme Court affirmed the validation decision, finding the road became public by legislative declaration in the late 1800s and was never abandoned. View "Sopatyk v. Lemhi County " on Justia Law

Idaho Development, LLC (Idaho Development) advanced $1,100,000.00 to Teton View Golf Estates, LLC (Teton View), a joint venture made up of Idaho Development as a 33.3% owner and Rothchild Properties, LLC as a 66.7% owner. Teton View granted Idaho Development a promissory note secured by a deed of trust that specified a set monthly payment and stated that the entire amount was to be paid off in ninety days. Idaho Development filed an action to foreclose on the deed of trust after Teton View failed to satisfy the promissory note. DePatco, Inc., another lienholder on the property, filed a motion for summary judgment to recharacterize Idaho Development’s advance as a capital contribution, which was granted. Idaho Development appealed, arguing that there was a genuine issue of fact as to whether the entire $1,100,000 advance was intended to be a capital contribution. Idaho Development also appealed a subsequent summary judgment brought by ZBS, LLC, which relied on the recharacterization determination in holding that ZBS' lien on the property had priority over Idaho Development's lien. Because there was a genuine issue of fact as to whether the entire $1,100,000 was intended to be a capital contribution, the Supreme Court concluded that the district court improperly granted summary judgment. Therefore, the decision of the district court granting summary judgment was vacated and the case was remanded for further proceedings. View "Idaho Development, LLC v. Teton View Golf Estates, LLC " on Justia Law

The issue on appeal before the Supreme Court was the grant of summary judgment against Landscapes Unlimited, LLC (LU) in which the district court: (1) applied I.C. 45-508 to postpone LU’s lien claim in golf course property to Hopkins Northwest Fund, LLC’s (Hopkins) deed of trust covering the same, and (2) alternatively apportioned LU’s lien amount. Hopkins filed a complaint in district court seeking to foreclose on its deeds of trust because the borrowers were in default on both promissory notes. Hopkins alleged in the complaint that its interest in the subject properties had priority over LU’s lien claim. LU cross-claimed, alleging that its lien claim was superior to Hopkins’ deeds of trust because LU began work on the project in June 2006 and Hopkins did not record its first deed of trust until August. Accordingly, LU sought to foreclose its lien with respect to the parcels identified in its lien claim. LU filed a motion for summary judgment in December 2008 regarding the validity, superiority, and amount of its lien claim. Hopkins responded that LU’s lien, even if valid, did not have priority over Hopkins’ interest because LU failed to designate what portions of its lien amount are attributed to each parcel or improvement pursuant to I.C. 45-508. LU countered that a single lien claim could be filed, without segregating the amount, when the labor is provided pursuant to a single contract and the work provided amounts to a single improvement. The district court orally ruled that LU’s lien claim on the four parcels at issue was superior to Hopkins’ interest pursuant to I.C. 45-506. Because the Supreme Court found that I.C. 45-508 was inapplicable to LU’s lien claim and that equitable apportionment was not an appropriate alternative remedy where I.C. 45-508 does not apply, the Court vacated the judgment and remanded the case for further proceedings. View "Hopkins Northwest Fund, LLC v. Landscapes Unlimited, LLC " on Justia Law

Plaintiff Jon Wakelum and Mike Ressler attended an auction of three parcels of property owned by Defendant Thomas Hagood that was conducted by Bullock and Company Realtors (Bullock). The auction was advertised as an absolute auction with a variety of terms and conditions for bidders. Wakelum and Ressler offered the high bids for the three parcels, all totaling less than $1 million. When Hagood was approached with the purchase and sale agreements, he refused to sign them. He claimed he had no intention to sell the properties for less than $2 million. Wakelum and Ressler brought suit against Hagood, arguing that the auction sale was enforceable. They later amended the complaint to include a claim that Hagood violated the Idaho Consumer Protection Act (ICPA) and attempted to further amend the complaint to seek a declaratory judgment that Bullock, as agent for Hagood, had authority to sign the purchase agreements. The district court granted Hagood’s motion for summary judgment and dismissed Wakelum’s and Ressler’s claims. The district court denied Wakelum’s and Ressler’s second motion to amend their complaint, finding that even if their claims were proven, they would not have been entitled to relief. Wakelum and Ressler appealed. Upon review, the Supreme Court reversed the district court's holding that the Bullock's Representation Agreement (that listed the terms and conditions with bidders) with Hagood was unenforceable for failing to comply with the statute of frauds. The case was remanded for further proceedings. View "Wakelum v. Hagood " on Justia Law

Do Nguyen, Jana Nguyen, Kenny Nguyen and John Doe’s (collectively "the Nguyens") appealed a district court's grant of a motion to set aside a default judgment in favor of Janice Maynard. On appeal, Maynard contended that the district court abused its discretion in setting aside its previously entered default judgment. In 2006, Maynard filled out an application to rent a trailer home from the Nguyens and reached an agreement with the Nguyens under which Maynard would receive title to the home if she paid $500 in rent each month for a period of three years. In 2008, Maynard reported to the Ada County Jail to serve a sentence, and when she returned home on November 27, 2008, she discovered that the Nguyens had removed her belongings from the trailer home and rented the trailer to other tenants. In 2009, an evidentiary hearing was held on the issue of damages. At the beginning of that hearing Maynard’s attorney told the court that he had received a two-page letter on June 29, 2009, which was addressed to "[counsel for Maynard], Janice Maynard and To Whom it May Concern." Counsel asked whether the court had received that letter, and described various documents which were attached to it. When the court said that it had not received the letter, the attorney offered no further information concerning the letter’s contents, but proceeded to present evidence concerning damages. The district court entered a default judgment against the Nguyens in the amount of $3,265 in actual damages and an enhanced penalty of $15,000 for the ICPA violation. The Nguyens filed a motion to set aside the default judgment. The Nguyens noted that they had sent Maynard’s attorney a letter explaining their version of events and why they believed that Maynard had abandoned the trailer home. On December 7, 2009, the district court granted the Nguyens’ motion to set aside the default judgment, finding that the Nguyens had demonstrated that there were unique and compelling circumstances justifying relief. Upon review of the trial court record, the Supreme Court affirmed the district court’s order setting aside the default judgment and remanded the case for further proceedings. View "Maynard v. Nguyen" on Justia Law