Justia Idaho Supreme Court Opinion Summaries

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

Petitioner-Appellant Roger Steele and several residents appealed a district court order that dismissed their claim that the City of Shelley (City) illegally annexed land in Bingham County known as "Kelley Acres." The district court found that there was no statutory authorization for the district court's review of the annexation. On appeal to the Supreme Court, Appellants argued that the annexation was "arbitrary and capricious" and procedurally defective. Upon careful consideration of the arguments and the applicable legal authority, the Supreme Court found that there was indeed, no statutory authority for judicial review of the annexation. Furthermore, the Court found substantial evidence that supported the City's annexation of Kelley Acres. The Court affirmed the lower court's decision. View "Steele v. City of Shelley " on Justia Law

Appellant Twin Lakes Canal Company (Twin Lakes) owned a reservoir. Respondents Warren and Sessilee Choules own property subject to a "prescriptive overflow" easement by Twin Lakes. In 2008, Twin Lakes filed suit against the Choules, alleging that the Choules moved earth, rocks, concrete and other debris from elsewhere on their property into areas below the height of the reservoir, which reduced the reservoir's storage space and damaged a lining designed to prevent leaks. The district court determined that state law allows the Choules as owners of the servient property, to use their property in any way they see fit, despite the common law rule that generally prohibits them from using their property in a way that interferes with the "dominant estate." The district court dismissed Twin Lakes' complaint. On appeal to the Supreme Court, Twin Lakes argued that the district court misinterpreted state law in its ruling in favor of the Choules. Upon careful consideration of the plain meaning of the applicable legal authority, the Supreme Court affirmed the lower court's decision. View "Twin Lakes Canal Co. v. Choules" on Justia Law

Plaintiffs Knipe Land Company (KLC) and John Knipe appealed a jury verdict in favor of Defendants Richard and Johnnie Robertson and Robertson Kennels, Inc. KLC is a real estate broker that specializes in agricultural and commercial real property. In 2005, the Robertsons signed an employment contract with KLC, where KLC was granted an exclusive listing to sell 1400 acres they owned. KLC would earn a percentage commission of the sales price or nonrefundable portions of any earnest money paid. In 2005, Robert and Sheila Harmon signed a purchase contract to buy the Robertsons' 1400 acres. The Harmons paid $50,000 as earnest money. Under the terms of the purchase agreement, $35,000 of the earnest amount would be non-refundable. The Harmons did not purchase the property, and the nonrefundable portion of the earnest money was transferred from the Harmons' real estate broker to KLC, which in turn distributed it to the Robertsons. In 2007, Robertson Kennels signed an employment contract with KLC to sell 1887 acres of land it owned. MidAmerican Nuclear Energy Company, LLC entered into a purchase agreement to purchase all of the Robertsons' property. The company paid $450,000 as nonrefundable earnest money. MidAmerican did not purchase the Robertsons' property. After the Harmon and MidAmerican purchase contracts ended, KLC demanded the Robertsons' pay its commission from the two cancelled purchase agreements. Upon review, the Supreme Court found that the Robertsons "clearly breached the unambiguous employment contracts and there was insufficient evidence to support the jury's verdict." The Court vacated the damages and attorney fees that were awarded to the Robertsons at trial, and remanded the case to the district court for further proceedings. View "Knipe Land Co. v. Robertson" on Justia Law

Appellants Samuel Jr. and Laurie Schneider appealed the district court's decree quieting title to real property in favor of Respondents Vernon and Dorothy Kennedy as adverse possessors. In 1924, Mr. Kennedy's great-uncle purchased the property that would eventually be passed to the Kennedys. When the Kennedys decided to place their property up for sale, they became aware that three parcels of the property that they believed had been owned by their family for generations were the subject of deeds in favor of other parties. In 2007, the Kennedys initiated a quiet title action to assert ownership over the three parcels as adverse possessors under a written claim of title. A default judgment in favor of the Kennedys was entered against the titleholders of record for two of the three parcels. The Schneiders answered and defended the Kennedys' claim to the third parcel. The district court issued a memorandum finding that the Kennedys had proved the elements of their claim of adverse possession by clear and satisfactory evidence. The court then entered a decree quieting title to the third parcel. The Schneiders appealed to the Supreme Court. Upon review, the Supreme Court found that there was not substantial, competent evidence to support the district court's findings. The Supreme Court vacated the lower court's decree and its judgment awarding attorney fees. The Court remanded the case for further proceedings. View "Kennedy v. Schneider" on Justia Law

The Idaho Department of Water Resources (Department) appealed an order of the district court that required it to strike a term from a hydropower water right license issued to the Idaho Power Company. In 1984, an agreement was entered into between Idaho Power, the State, the governor, and the attorney general, in an effort to resolve a controversy associated with the company's water rights at the Swan Falls Dam. As part of the Swan Falls agreement, the parties agreed to support legislation for the commencement of an adjudication of water rights in the Snake River Basin. One key piece of the legislation that was passed pursuant to the Swan Falls Agreement gave the Department specific authority to subordinate hydropower rights in a permit or license to the rights of subsequent upstream depletionary users. The Department was also authorized to limit a permit or license involving hydropower to a term of years. The Department issued a final order that articulated the legal basis for including the "term of years" condition in the license to Idaho Power. The Company sought judicial review of the Department's final order, arguing that the Department did not have statutory authority to include a term condition in its license. The court indeed concluded that the Department did not have the authority to limit the license. The Department appealed to the Supreme Court. Upon review, the Supreme Court found that the Department had the statutory authority to include a term condition in Idaho Power's license. The Court reversed the district court's decision. View "Idaho Power Company v. Idaho Dept of Water Resources" on Justia Law