Justia Idaho Supreme Court Opinion Summaries

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

Following a district court's resolution of a property dispute between Respondents Daniel and Sherri-Jo Garner and Appellants Brad and Leiza Povey, Appellants sought an award of attorney fees under the "commercial transaction" prong of I.C. 12-120(3) and for frivolous litigation under I.C.12-121. The district court denied fees on both grounds, and Appellants appealed to the Supreme Court. Upon review of the lengthy trial court record, the Supreme Court reversed the denial of attorney fees to Appellants under I.C. 12-121. Furthermore, the court reversed the denial of fees for Appellants under I.C. 12-120(3) and remanded the case back to the district court for a determination of the appropriate fee award. The Court awarded Appellants costs and attorney fees on appeal. View "Garner v. Povey" on Justia Law

Plaintiffs Stephen and Marilee Bell hired contractor Defendant Perception Construction Management, Inc. (PCM) to build a log home. The parties' relationship deteriorated, and the Plaintiffs terminated the contract before construction was complete. Plaintiffs refused to pay PCM's final invoices, and PCM filed suit to enforce a lien it placed on the home for the unpaid invoices. Plaintiffs filed multiple counterclaims, including construction defect and breach of contract. PCM prevailed at trial, and the district court found PCM was entitled to damages, prejudgment interest and attorney fees. Plaintiffs appealed, contending that the district court erred by excluding certain evidence relating to their defense against the lien, and in its determination of the monies allegedly owed under the lien. The Supreme Court found that the district court impermissibly excluded Plaintiffs' evidence, and as such, the Court vacated the district court's judgment and remanded the case for further proceedings. View "Perception Construction Management, Inc. v. Bell" on Justia Law

Jacklin Land Company (Jacklin) owned real property that it developed into a commercial industrial complex. The development was subject to multiple covenants, conditions and restrictions (CC&Rs). One of the CC&Rs was that the development was not intended for retail businesses. In April 2008, Blue Dog RV, a retailer, began negotiating with Jacklin about the purchase of land in within the complex. During the course of the negotiations, Blue Dog also discussed renting four undeveloped lots across the street, but still within the complex. KL Properties owned those four lots. Ultimately Blue Dog leased space from KL Properties. Citing the CC&Rs, Jacklin sent notice to Blue Dog to vacate the KL leased space. When further negotiations between the parties proved unfruitful, Jacklin filed suit to enjoin KL Properties and Blue Dog from using the space for RV retail. The trial court ruled in KL and Blue Dog's favor. On reconsideration, the court issued an injunction against Blue Dog for violation of the CC&Rs. Upon review, the Supreme Court found that the district court's injunction was technically flawed because it did not give "explicit notice of precisely what conduct was outlawed," and that it enjoined unknown persons who were not party to this action. The Court vacated the district court's judgment, and remanded the case for further proceedings. View "Jacklin Land Co. v. Blue Dog RV, Inc." on Justia Law

At issue in this case were the rights of three brothers who were residuary beneficiaries under a testamentary trust. One of the brothers leased the trust property when the trust terminated. The other two brothers sued him and the trustee to determine their respective rights. The one brother appealed the district court's judgment that found the trust was properly terminated and that he was not entitled to compensation for improvements he made to the property. Upon careful consideration of the district court record, the Supreme Court found there were genuine issues concerning reimbursement for the improvements made to the property. The Court reversed the district court on that issue, but affirmed the lower court as to all other issues. The case was remanded back to the district court for further proceedings. View "Beus v. Beus" on Justia Law