Justia Idaho Supreme Court Opinion Summaries

Appellant Antranick Harrentsian alleged that the district court erred in its enforcement of a constructive trust. Respondents, Gennieve and Frank Hill were the parents of Sarah Correa, who was Appellant's ex-girlfriend. In 2008, Appellant entrusted Correa with $400,000. In 2009, Correa loaned $101,500 of the $400,000 to Respondents. Respondents used the funds to purchase a house in Boise. Thereafter, Respondents spent nearly $40,000 of their own money to improve the Property. Also in 2009, Appellant sued Correa in California. The California lawsuit resulted in the creation of a constructive trust on the $400,000. Appellant filed this lawsuit in an effort to recover the Property, which was acquired by Respondents with money subject to the constructive trust. The district court found that Respondents were not aware that the money they received from Correa was wrongfully obtained. Accordingly, the district court ordered that title to the Property be transferred to Appellant, but that Respondents were entitled to an equitable lien against the Property for $33,689 for the improvements they made. The district court provided Appellant with 180 days to satisfy the lien. Appellant appealed that judgment, but finding no reversible error, the Idaho Supreme Court affirmed. View "Harrentsian v. Hill" on Justia Law

Edgar Farfan-Galvan appealed his conviction for felony driving under the influence (“DUI”). Farfan-Galvan moved to dismiss or remand the charge, based upon his claim that one of the prior DUI convictions upon which the State relied to enhance the charge from a misdemeanor to a felony was obtained in violation of his Sixth Amendment right to counsel. The district court denied the motion. The Supreme Court reversed. The record before the district court did not contain any indication that Farfan-Galvan had waived the right to counsel in the prior 2010 case. Therefore, that conviction could not serve as the basis to enhance the charge to a felony. The district court’s decision denying his motion to dismiss or remand. was reversed, and in light of this, the Court vacated Farfan-Galvan’s conviction. View "Idaho v. Farfan-Galvan" on Justia Law

NeYada, Inc., a Nevada corporation, appealed a district court’s order granting summary judgment to Respondent Marian Hoke, and declaring a lease (the “Lease”) and an option to purchase (the “Option”) between the parties invalid and unenforceable. In November 2014, Hoke executed the Lease and Option with NeYada for the transfer of an interest in real property located in Canyon County, Idaho. A mere two months later, Hoke filed suit seeking to invalidate the Lease and the Option alleging, inter alia, that neither document complied with the statute of frauds. Both parties moved for summary judgment on that issue. The district court held that the Lease and Option (together, the “Contract”) were invalid and unenforceable because neither complied with the statute of frauds. Further, the district court held that the doctrine of part performance did not require the enforcement of the otherwise invalid Contract. The Supreme Court vacated the district court's holding, finding that the district court erred by failing to specifically enforce the Contract via the doctrine of part performance. At the time this lawsuit was initiated, NeYada’s performance was essentially complete. At oral argument, Hoke’s counsel admitted that NeYada took actual possession of the Property, and there was “probably nothing” more NeYada could have done. "Such an admission undercut Hoke’s argument against the application of the doctrine of part performance. All that remained to be done was to make monthly payments and to convey title." View "Hoke v. NeYada, Inc." on Justia Law

Appellants The Source Store LLC (“Source 1”), The Source LLC (“Source 2”), Michael L. Hodge (“Hodge”), George M. Brown (“Brown”), and Christopher Claiborne (“Claiborne”) appealed the district court’s order denying their Joint Motion to Dismiss, by which they sought to dismiss the derivative claims brought by respondents Donnelly Prehn and Dwight Bandak on behalf of Source 1. The Supreme Court did not reverse the district court’s decision not to hear Appellants’ Joint Motion to Dismiss. Further, the Court affirmed the district court’s finding that Hodge breached his fiduciary duty to Source 1 and its members. Specifically, the Court affirmed the district court’s awards related to the following: (1) Hodge’s breach of his fiduciary duty as to the management of the asset auction; (2) Hodge’s breach of his fiduciary duty related to his failure to minimize expenses during dissolution; (3) Prehn’s entitlement to back salary and reimbursement for the loan; and (4) the unjust enrichment of Hodge and Source 2. The Court affirmed the district court’s award of attorney’s fees. View "Prehn v. Hodge" on Justia Law

This case arose out of statements made to a call-in radio show by Steve Murdock about his neighbor Candace Elliott. The show’s hosts were discussing a Bonneville County case that involved allegations of horse abuse and neglect. Elliott called in to comment. Several callers later, Murdock called in, questioning the veracity of Elliott’s statements, and making various claims about the horse meat market and (referring to Elliott) “Andi’s humane society.” Elliott filed suit, alleging that seven of Murdock’s statements defamed her individually and her foundation, For The Love Of Pets, Inc. The district court granted summary judgment in favor of Murdock. Elliott appealed, limiting her appeal to the statement, “Andi’s humane society puts .02% of the money they hit everybody up [sic] back into the care of animals,” which she alleged defames both her and her foundation. The Supreme Court found no reversible error in the trial court's judgment in favor of Murdock, and affirmed in all respects. View "Elliott v. Murdock" on Justia Law

The issue this case presented for the Supreme Court's review was a contract dispute between Silver Creek Seed, LLC and Sunrain Varieties, LLC, arising from the development of Bacterial Ring Rot (“BRR”) in two of the potato varieties grown by Silver Creek for Sunrain. After a four-day trial, the jury returned a verdict awarding damages to Silver Creek. Sunrain appealed: (1) the district court’s denial of a motion to reconsider an order granting partial summary judgment to Silver Creek; (2) the exclusion of the back side of the Idaho Crop Improvement Association (“ICIA”) blue tag from evidence; (3) the admission of testimony relating to the source of the BRR; (4) alleged errors in jury instructions; (5) the award of prejudgment interest to Silver Creek and (6) the award of attorney fees and costs to Silver Creek. Finding no reversible error, the Supreme Court affirmed. View "Silver Creek Seed v. Sunrain Varieties" on Justia Law

This case arose from an allegedly improper reconveyance of a junior deed of trust (the “EEF Deed of Trust”) held by Appellant, Eagle Equity Fund, LLC (“EEF”). The reconveyance, which was executed by Respondent, TitleOne Corporation, had the effect of divesting EEF of its security interest in the collateral property. Because EEF was divested of its security interest, it did not receive notice when the Property was later sold to DAS Investments, LLC. Being unaware of the sale, EEF had no opportunity to participate in the sale process. Shortly thereafter, DAS resold the Property to Corey Barton Homes, Inc. (“CBH”), for a profit. On discovering the sale and resale of the Property, EEF sued TitleOne, DAS, and CBH, among others, on a litany of counts including tortious interference and negligent reconveyance of the EEF Deed of Trust. On appeal, EEF argued that: (1) the reconveyance damaged EEF by depriving it of the opportunity to insert itself into the sale of the Property; (2) the statute of limitations had not run on EEF’s negligent reconveyance claim under Idaho Code section 45-1205 because it should have been calculated from the date of the sale rather than from the date of the reconveyance; and (3) DAS and CBH were not bona fide purchasers because they had inquiry notice of EEF’s interest. After review, the Supreme Court concluded: (1) EEF had no claim against TitleOne for tortious interference with a prospective economic advantage, so the district court did not err in dismissing EEF's claims against TitleOne on summary judgment; (2) because the district court did not err in so granting summary judgment, the Supreme Court did not reach EEF's contention that the district court miscalculated the statute of limitations; and (3) the district court did not abuse its discretion in refusing t allow EEF to amend its complaint to add a quiet title claim against CBH. Accordingly, the Court affirmed the district court's judgment. View "Eagle Equity Fund v. TitleOne Corp" on Justia Law

Appellants Shawn and Heather Montee, Shawn Montee, Inc., and ABCO Wood Recycling, LLC appealed, among other things, the district court’s grant of summary judgment in favor of Respondent Robert Wolford. Appellants argued the district court erred in ruling that certain promissory notes granted to Wolford by Appellants were clear and unambiguous and that under the terms of those notes Appellants were in default and Wolford was entitled to judgment as a matter of law. Appellants also contended that several of their motions were erroneously denied, including a motion to continue, a motion for examination of Wolford, a motion to amend or alter judgment, and various motions to quash. Furthermore, Appellants appealed the district court’s order of contempt entered against them. After review, the Supreme Court affirmed in part, vacated in part and remanded for further proceedings. The Court found that the district court erred in its grant of summary judgment as to some notes over others; vacated summary judgment with respect to those notes, and remanded for the district court to determine when payments were due, when interest was to accrue, and whether the interest rate was per month or per annum. The Court affirmed the district court in all other respects. View "Wolford v. Montee" on Justia Law

Dennis Sallaz owned a 1954 Cadillac Eldorado that he had purchased in 1964. In 1991, Sallaz granted Eugene “Roy” Rice a lien on the Cadillac, and a new certificate of title was issued in 1991, showing that Roy Rice had a lien on the car. Sallaz had a duplicate of that certificate of title issued to himself. Sallaz was counsel for Rice, and they were close friends and business associates for many years. Their relationship soured, in early 2011, Rice had his son Michael Rice repossess the Cadillac. Michael Rice, on behalf of his father, presented an Affidavit of Repossession to the Idaho Transportation Department, and the Department issued a new certificate of title showing that the owner of the Cadillac was Eugene LeRoy Rice or Rose Jeanette Rice, who was his wife. Rice later sold the Cadillac for $25,000. Sallaz filed this action against Rice, his wife, and his son seeking to recover possession of the Cadillac or, if he could not do so, damages for conversion in the sum of $75,000. Sallaz sought a writ of possession to gain possession of the Cadillac, but the district court denied the writ because “Mr. Rice has shown with sufficient probability that he is the official owner of record of the 1954 Cadillac Eldorado and that he is entitled to possession of the vehicle.” There were other claims filed between the parties, and all of the various claims were tried to a jury from June 30 through July 21, 2014 (the other claims are not relevant to this appeal). After Defendants rested, Sallaz moved for a directed verdict. The district court denied the motion, and the jury returned a special verdict finding that Sallaz had failed to prove his claim against Defendants for conversion of the Cadillac. Plaintiffs appealed. Finding no reversible error, the Supreme Court affirmed the denial of a directed verdict. View "Sallaz v. Rice" on Justia Law

Inclusion, Inc., Inclusion North, Inc., and Inclusion South, Inc., (collectively Inclusion) provided residential rehabilitation support services to Idahoans eligible for Medicaid. In September 2012, Inclusion filed a complaint against the Idaho Department of Health and Welfare (IDHW), alleging IDHW breached binding Medicaid Provider Agreements by failing to adequately reimburse Inclusion for its services. In June 2013, Inclusion amended its complaint with unjust enrichment and quasi-estoppel claims. The district court granted summary judgment for IDHW, concluding no triable issue of fact supported Inclusion’s claims. IDHW then moved for attorney fees under Idaho Code section 12-120(3) and requested $74,925.00 in fees. The district court found that IDHW’s requested award was based on a reasonable amount of hours and a reasonable hourly rate, as determined by the Boise market. As the district court acknowledged, “the hourly rate requested is reasonable and certainly well within the rate in the marketplace in the Fourth District in Ada County, in particular.” Even so, the district court took issue with how IDHW’s requested award was not based on the actual hourly rate billed during litigation. As the district court explained, “[e]xcept where the award of attorney fees is paid to the lawyer, fees awarded to a party should not exceed the amount the client actually paid for the lawyer.” To that end, the district court multiplied 599.4 hours of work by $54.00 per hour1 to award a total of $30,857.11. IDHW moved to reconsider, but the district court upheld the award for $30,857.11. IDHW timely appealed, arguing the district court abused its discretion by basing the award on the amount billed by the Attorney General. The Supreme Court agreed, vacated the judgment and granted IDHW its requested award. View "Inclusion, Inc v. Id. Dept. of Health & Welfare" on Justia Law