Justia Idaho Supreme Court Opinion Summaries

In 2017, Appellant Shoshone County assessed properties owned by Respondents S&W OPS, LLC; POWDER, LLC; H2O, LLC; GOLF, LLC; APARTMENT, LLC; F&B, LLC; and VILLAGE MANAGEMENT, LLC (collectively “Taxpayers”). Taxpayers disputed the valuation and sought review by the Board of Equalization, and subsequently the Board of Tax Appeals (“BTA”). The BTA reduced the assessed value, and the County appealed to the district court. After a four-day bench trial, the district court upheld the BTA decision, determining that the County’s appraisal evidence was more credible than Taxpayers’ evidence; however, the district court ultimately held the County had not satisfied its burden of showing how the BTA decision was erroneous by a preponderance of the evidence. The County appealed to the Idaho Supreme Court, arguing that the district court applied the wrong standard of review by requiring the County to prove “how or why” the BTA decision was erroneous instead of simply concluding that the market value of the property was different than what was found by the BTA. After review, the Supreme Court agreed with the County’s position. The district court’s decision was reversed, the judgment was vacated, and the case was remanded with instructions for the district court to consider whether the BTA’s decision on valuation was erroneous given the evidence submitted during the de novo trial. If that decision on valuation was erroneous, the district court, as the fact-finder, had to set the valuation. View "Shoshone County v. S&W OPS, LLC" on Justia Law

S Bar Ranch owned approximately 3000 acres of land in rural Elmore County, Idaho. S Bar purchased the land in 2015. There were very few structures on S Bar’s property, save for an airplane hangar that included a five-hundred square-foot apartment. S Bar’s address was listed in Sun Valley, Idaho, and its principal, Chris Stephens, used the property for recreational purposes. Cat Creek Energy, LLC, an Idaho company managed by John Faulkner, owned and managed more than 23,000 acres of land in Elmore County near Anderson Ranch reservoir. Faulkner, on behalf of his other companies, leased land to Cat Creek to develop the project at issue in this dispute. In late 2014 and early 2015, Cat Creek began the process of obtaining conditional use permits (“CUPs”) for a proposed alternative energy development (“the project”) in Elmore County. As initially proposed, the project had five components: a 50,000 acre-foot reservoir with hydroelectric turbines, up to 39 wind turbines, approximately 174,000 photovoltaic solar panels, electrical transmission lines, and an onsite power substation. Cat Creek sought to build the project on approximately 23,000 acres of land that it had leased near Anderson Ranch Reservoir. In 2019, the district court issued a Memorandum Decision and Order, affirming the Board’s decisions with respect to the CUPs. The district court found that S Bar only had standing to challenge the CUPs relating to wind turbines, electric transmission lines, and the on-site substation. The district court also reiterated its prior oral ruling that a 2017 CUP Order was a final agency action and that S Bar’s petition for judicial review of that order was untimely. With regard to the development agreement and a 2018 CUP Amendment, the district court concluded that the Board did not err in a manner specified by Idaho Code section 67-5279 and that S Bar had not shown that its substantial rights had been prejudiced. S Bar appealed, but finding no reversible error in the district court's judgment, the Idaho Supreme Court affirmed judgment in favor of Cat Creek. View "S Bar Ranch v. Elmore County" on Justia Law

Miguel and Janice Aizpitarte sued their neighbors Michael and Laura Minear to quiet title to what they contended was an established easement for an access driveway, and sought a declaratory judgment to recognize their right to an implied easement by prior use. The Aizpitartes also sought injunctive relief enjoining the Minears from blocking access to the drive(10) Wilkins (way. The Aizpitartes moved for summary judgment, which the district court granted. The district court concluded the Aizpitartes had an implied easement by prior use of the driveway crossing the Minear property to the Aizpitarte property. The Minears appealed, arguing the district court erred in granting summary judgment against them because there were genuine issues of material fact in the record. They also argue the scope of the easement recognized by the district court was too broad. Finding no reversible error in the trial court’s grant of summary judgment, the Idaho Supreme Court affirmed. View "Aizpitarte v. Minear" on Justia Law

The issue this appeal presented for the Idaho Supreme Court's review concerned whether a prescriptive easement existed on a road accessing property owned by Shelley and Roger Cook near the Bingham and Bonneville County line. The Cooks’ property was originally owned by Shelley’s grandfather, John Harker, and stayed in the Harker family ever since. The Harker family (including the Cooks) claimed to have used what the parties called “Tower Road” to access their property for as long as the family can remember. Tower Road connected the Cook Property to a county road and ran through property owned by Jay and Shelli Van Orden. The Cooks filed suit against the Van Ordens claiming a prescriptive easement across the Van Ordens’ property via Tower Road. The district court ruled in the Van Ordens’ favor, holding that because the Cooks’ longstanding use of the land was not adverse, it did not have to address the remaining elements of a prescriptive easement. The Cooks appealed to the Supreme Court, contending the district court erred in finding their family’s use of Tower Road was with implied permission and in not addressing the remaining elements. The Supreme Court found the district court erred in granting judgment to the Van Ordens without determining the relevant statutory period for determining adverse use. Judgment was reversed and the case remanded for a determination of the relevant statutory period for the claimed prescriptive easement and whether the evidence established adverse use during that time. View "Cook v. Van Orden" on Justia Law

Stephan Byrd and Erika Mullins jointly filed an application for an encroachment permit with the Idaho Department of Lands to add boat lifts to their existing two-family dock on Priest Lake. Neighbors Cal Larson and Steven Coffey objected the application, arguing that Coffey owned a strip of land between the ordinary high water mark of Priest Lake and the waterward boundary lines of the Appellants’ properties. Following an administrative hearing, the Department of Lands denied the encroachment permit upon concluding that the record failed to show by a preponderance of the evidence that Byrd and Mullins were littoral property owners with corresponding littoral rights (a key requirement to build or enlarge encroachments on the lake under Idaho’s Lake Protection Act). Finding no reversible error in that finding, the Idaho Supreme Court affirmed the district court's judgment upholding the Department's order. View "Byrd v. Idaho State Brd. of Land Commissioners" on Justia Law

Jared and Katherine Sommer brought a declaratory judgment claim against Misty Valley, LLC, after receiving written notice that the real estate developer planned to use an express easement across the Sommers’ land for access to a recently platted residential subdivision. The Sommers contended the planned use constituted an impermissible expansion of the scope of the easement, and brought a claim to terminate the easement. After a bench trial, the district court limited the use of the easement to the dominant parcel, which only included part of Misty Valley’s planned subdivision, and declined to terminate it. Misty Valley appealed the district court’s judgment, and the Sommers cross-appealed. Finding no reversible error, the Idaho Supreme Court affirmed the district court. View "Sommer v. Misty Valley, LLC" on Justia Law

Edward and Janice Easterling owned three contiguous parcels of real property in Ammon, Idaho. The Easterlings brought suit against Hal Pacific Properties, L.P. (“HAL”), claiming an easement by necessity over and upon HAL’s property in order to access their three merged parcels. Following cross-motions for summary judgment, a motion for reconsideration, and a short bench trial, the district court largely ruled in the Easterlings’ favor. The district court denied HAL’s affirmative defense that the Easterlings’ claims were barred by the statute of limitations. The district court further held that the Easterlings were entitled to an easement by necessity over and upon the HAL Parcel to allow access to all three of the Easterlings’ merged parcels. The district court placed the easement at the western border of the HAL Parcel and set its width at twenty-six feet. HAL appealed to the Idaho Supreme Court, contending the district court erred by denying its statute of limitations affirmative defense, granting the Easterlings’ claim for an easement by necessity for all three of their parcels, and improperly determining the location and width of the easement. The Supreme Court reversed the district court’s decision at summary judgment rejecting HAL’s statute of limitations defense under Idaho Code section 5-224. Because of this, the Court vacated the district court’s judgment and reversed its decisions that the Northern Parcel was entitled to an easement by necessity over the HAL Parcel; and that the width of the easement was set at twenty-six feet. The Supreme Court further reversed the district court’s decisions setting the location of the easement and granting an easement by necessity as to the Southern and Eastern Parcels over the HAL Parcel. The matte was remanded for further proceedings. View "Easterling v. Hal Pacific Properties, L.P." on Justia Law

Dennis and Sherrilyn Munden (the Mundens) and their limited liability company, Coyote Creek Ranch, LLC, purchased property in Bannock County, Idaho in 2012 (the Upper Property), and acquired adjoining property (the Lower Property) in 2014. The Mundens’ ranch was accessible by a gravel road (the Road) which left a paved public road before crossing the Lower Property. It then traversed a neighbor’s parcel to the Upper Property, before exiting to the north. The Mundens began ranching on the Lower Property in 2013 and started construction of a barn and living quarters on the Upper Property in 2015 after obtaining a three-year building permit. In 2017, the Mundens were informed by the Bannock County Commissioners that, pursuant to a 2006 county ordinance, the Road had been designated by the Commissioners for “snowmobile use only” between December 15 and April 15. All other vehicular use was prohibited during this timeframe. In January 2019, Bannock County passed an ordinance which gave discretion to the Bannock County Public Works Director (the Director) to determine when snowmobile trails would be closed to all but snowmobile use. Subsequently, the Director decided to close the Road for the 2018–19 winter season. The Mundens filed a complaint in district court against Bannock County, bringing several claims involving the Road, and obtained an ex parte temporary restraining order (TRO) to prohibit enforcement of the 2019 ordinance. The County moved to dissolve the TRO, which the district court granted. The district court then awarded attorney fees to the County. The Mundens amended their complaint to add their ranching operation, Coyote Creek Ranch, LLC, as a plaintiff, to which the County responded with an answer and counterclaim, alleging that the Road was a public right-of-way with no winter maintenance that had been designated as a snowmobile trail by the 2006 ordinance. The County then moved to dismiss the amended complaint for failure to state a claim. The district court granted this motion, concluding that because the claims turned on a legal determination of the Road’s status, the Mundens were required by Idaho Code section 40-208(7) to first petition for validation or abandonment proceedings with the Board of County Commissioners before they could bring a lawsuit. The district court accordingly entered a judgment dismissing the plaintiffs’ amended complaint in its entirety. Ultimately, the district court entered a judgment certified under IRCP 54(b)(1) authorizing an immediate appeal, and the Mundens timely appealed. The only error the Idaho Supreme Court found in review of this case was that the district court erred in issuing a writ of execution before there was a final appealable judgment. Judgement was affirmed in all other respects. View "Munden v. Bannock County" on Justia Law

Mary Eich appealed a district court judgment ordering her to vacate property owned by the trustees of the Wilbur Eich and Henrietta Eich Revocable Trust (the “Trust”). In 2015, Mary filed an action seeking to quiet title to 2.5 acres of an 80-acre tract of real property owned by her father, who held title to the property as trustee of his Trust. Mary alleged that her parents had gifted her the 2.5 acres with the intent that she build a home and reside there for the rest of her life. On cross-motions for summary judgment, the district court ruled that there was no valid transfer between Mary and her parents, but permitted Mary to pursue an equitable claim of promissory estoppel. After a bench trial, the district court ruled in favor of Mary and that she had a year to obtain Teton County’s approval to partition the 2.5 acres from the remaining Trust property. If she could not do so within the time prescribed, the Trust would have to pay Mary $107,400 for the value of improvements she had made on the land plus her reasonable relocation costs, and Mary would have to vacate the property. Mary worked for several years to separate the 2.5 acres from the remaining Trust property to no avail. In August 2019, the Trust moved to compel enforcement of the district court’s alternative remedy and for entry of final judgment. In January 2020, a newly assigned district court judge granted the Trust’s motion and entered a declaratory judgment ordering the Trust to pay Mary $107,400, plus reasonable relocation expenses, and for Mary to vacate the property. Mary appealed, arguing that the newly assigned district court judge abused his discretion by deviating from the original judge’s equitable remedy. Finding no reversible error, the Idaho Supreme Court affirmed the district court’s decision ordering Mary to vacate the property and for the Trustees to pay Mary $107,400. View "Eich v. Revocable Trust" on Justia Law

Pheasant Run VI, LLC, Robert Drinkard, and Nancy Drinkard (collectively, “the Drinkards”) appealed a district court’s order renewing a judgment for Alpha Mortgage Fund II (“Alpha”) for $1,842,509.59. Pheasant Run was a company wholly owned by the Drinkards. Pheasant Run obtained a loan from Alpha. Robert and Nancy acted as guarantors for the loan. Pheasant Run ultimately defaulted on the loan and Alpha foreclosed on property the Drinkards used as collateral for the loan. Although Alpha recouped the property, a significant deficiency existed between the amount Pheasant Run owed and the property’s fair market value. Alpha thereafter sued Robert and Nancy for the amount of the deficiency. The Original Judgment was entered in 2010, and renewed in 2015. Alpha did not record the 2015 judgment. In 2020, Alpha moved the district court to again renew the Original Judgment pursuant to Idaho Code section 10-1111. The Drinkards objected, leading to this appeal. The Idaho Supreme Court found the district court did i not err when it granted Alpha’s motion to renew the Original Judgment, even though the 2015 judgment was not recorded: the judgment remained unsatisfied, and Alpha’s motion was filed within five years of the most recently renewed 2015 judgment. Accordingly, judgment was affirmed. View "Alpha Mortgage Fund v. Drinkard" on Justia Law