Justia Idaho Supreme Court Opinion Summaries

At issue in this appeal was a district court’s dismissal of Rencher/Sundown LLC’s (“Sundown”) complaint against Butch Pearson. The Idaho Supreme Court determined Sundown did not serve the complaint or summons within the six months required by Idaho Rule of Civil Procedure 4(b)(2); Pearson moved to dismiss the complaint. The district court dismissed Sundown’s complaint after finding Sundown could not show good cause for failure to timely serve. The Supreme Court affirmed dismissal of Sundown's complaint. View "Rencher/Sundown LLC v. Pearson" on Justia Law

Appellants Jerry and JoCarol Losee appeal the district court’s decision granting Deutsche Bank National Trust Company’s motion for summary judgment, arguing the district court erred by refusing to consider their “Chain of Title Analysis” as inadmissible hearsay. The Losees also argue the district court erred in failing to rule on two of their claims against Deutsche Bank. In 2009, the Losees became delinquent in their mortgage payments, eventually defaulting on their home mortgage loan. Over two years after the foreclosure sale was supposed to take place, a second notice of default was recorded on April 20, 2014. However, the foreclosure sale was postponed when the Losees requested a loss mitigation review. The owner of the loan would not allow loan modification, so the Losees were advised that a short sale of the property was the only loss mitigation available. On August 17, 2015, this case commenced when the Losees, acting pro se, filed their “Original Petition for Breach of Contract, Slander of Title for Declaratory Judgment and Motion for Temporary Restraining Order and Application for Temporary Injunction” (“Complaint”) with the district court. In 2017, the Losees submitted a “Notice of Filing for Judicial Review,” to which they attached a “Chain of Title Analysis.” The “Chain of Title Analysis” was a report resulting from a mortgage fraud investigation conducted by a private investigation company they hired. The district court granted the Bank's motion for summary judgment, concluding there was no breach of the Deed of Trust, title to the property had not been slandered or become clouded by assignment, and that the Chain of Title Analysis was inadmissible hearsay not appropriate for consideration by the court on summary judgment. The Idaho Supreme Court found no reversible error in the district court's grant of summary judgment and affirmed. View "Losee v. Deutsche Bank Nat'l Trust" on Justia Law

Peter Nemeth and his wife Mary Nemeth (deceased), and Peter Nemeth acting as trustee of the Peter and Mary Nemeth Family Trust (collectively, “the Nemeths”), petitioned Shoshone County, Idaho, to validate a public right-of-way across federal land pursuant to Idaho Code section 40-204A and United States Revised Statute 2477 (“R.S. 2477”). The right-of-way followed a road which crossed federal land that Nemeths claimed historically provided access to their property and patented mining claims. When the County failed to act on the petition, the Nemeths filed a declaratory judgment action seeking validation of the right-of-way pursuant to Idaho Code section 40- 208(7). On a motion from the County, the district court dismissed the complaint pursuant to I.R.C.P. 12(b)(6) on grounds that because the Road traversed federal land, only a federal court had jurisdiction to hear the claim, which had to be brought under the federal Quiet Title Act (QTA), 28 U.S.C. section 2409a. The Nemeths appealed, arguing that state courts had jurisdiction to validate rights-of- way on federal land pursuant to R.S. 2477 and that the QTA did not preempt Idaho law that provided for such validation. After review, the Idaho Supreme Court reversed, because the district court erred in dismissing the Nemeths’ action on the basis it lacked subject matter jurisdiction. View "Nemeth v. Shoshone County" on Justia Law

In its motion for summary judgment, Farmers Insurance Company of Idaho argued that Erica Klein was barred from pursuing a supplemental UIM claim because the five-year statute of limitations in Idaho Code section 5-216 had run. Farmers asserted the statute of limitations began to run on either the date of the accident or the date Klein settled with the third party tortfeasor, both of which occurred more than five years prior to Klein filing her complaint to compel arbitration of her UIM claim. The district court denied Farmers’s motion and subsequent motion for reconsideration, holding that the “breach of contract” rule was the proper method of calculating the accrual date for Klein’s cause of action. Farmers appealed the district court’s denial of both motions. The Idaho Supreme Court determined the issue raised by this case was one of first impression, inasmuch as it was asked to determine when the statute of limitations began to run on a cause of action for UIM benefits under an automobile insurance policy. After considering the different approaches taken by other states, the Court adopted the majority’s “breach of contract” rule and affirmed the district court’s decisions. View "Klein v. Farmers Insurance Co." on Justia Law

First Bank of Lincoln (First Bank) challenged a district court’s grant of summary judgment in favor of Land Title of Nez Perce County Incorporated (Land Title). In 2011, First Bank loaned Donald Tuschoff $440,000 to purchase the Hotel Lincoln in Lincoln, Montana. The loan was secured by a deed of trust against the hotel. As additional collateral, Tuschoff assigned First Bank his interest in a note and deed of trust on a bowling alley in Washington. Later, following a sale of the bowling alley, Land Title distributed the proceeds to Tuschoff and other interested parties rather than First Bank. First Bank did not learn of the bowling alley sale until it completed its annual loan review of Tuschoff’s hotel loan. Subsequently, Tuschoff defaulted on the hotel loan. First Bank held a non-judicial foreclosure sale of the hotel and placed a full-credit bid of the approximately $425,000 owed to it by Tuschoff. First Bank was able to later sell the hotel for approximately $190,000. First Bank then initiated several lawsuits against various parties in Washington, Montana, and Idaho, seeking to recover the “deficiency” between what it was owed and for what it sold the hotel. Relevant here was First Bank’s suit against Land Title in Idaho. The district court, applying Montana law, granted summary judgment in favor of Land Title. The court determined that First Bank’s full credit bid extinguished Tuschoff’s debt, and once that debt was extinguished, the assignment of Tuschoff’s interest in the bowling alley as collateral for that debt was also extinguished. The Idaho Supreme Court concurred with this conclusion, and affirmed. View "First Bank of Lincoln v. Land Title of Nez Perce County" on Justia Law

This appeal stemmed from an unlawful-detainer and breach-of-contract action filed by Caldwell Land and Cattle, LLC, (“CLC”) after purchasing a building where the holdover tenant, Johnson Thermal Systems (“JTS”), asserted a right to remain on the property. The dispute centered on the interpretation of a lease between JTS and the original property owner which granted JTS an option to extend the lease. JTS contended it properly exercised the option; CLC contends JTS did not. The district court held that JTS failed to exercise the option and thus became a holdover tenant. The court further held that when JTS did not vacate within the proper timeframe, JTS unlawfully detained the premises and was liable for the ensuing damages. JTS appealed, but finding no reversible error, the Idaho Supreme Court affirmed. The district court’s amended final judgment and its order of attorney’s fees was remanded, however, for reentry of damages consistent with the Supreme Court’s opinion , and for reconsideration of attorney’s fees. View "Caldwell Land & Cattle v. Johnson Thermal" on Justia Law

The Fletchers owned property in the Twin Lakes Meadows Subdivision in Kootenai County, Idaho. Some of the lots, but not all, adjoin or connect to a private gravel and dirt road known as “Lone Mountain Road” which ran through the subdivision. road. Over the years, because Delores Fletcher suffered from asthma, the Fletchers used asphalt grindings, oiling, and other dust control methods, at their own expense, to abate the dust on the stretch of road adjacent to their property. Disputes arose for several contentious years between the Fletchers and the “Lone Mountain Road Association” - i.e. the Fletchers’ neighbors - over the payment of maintenance costs incurred by the Association, attempts to stop the Fletchers from utilizing their own dust control methods, and the repair of potholes. The disputes came to a head in 2009 when the Association made written demand that the Fletchers stop oiling Lone Mountain Road. In response to their neighbors’ demand, the Fletchers brought a declaratory judgment action, seeking a declaration which outlined the rights and responsibilities of subdivision property owners with respect to Lone Mountain Road. The Fletchers also brought a claim for trespass against defendants Alan Sims and Lone Mountain Road Association. Counterclaims were filed against the Fletchers alleging nuisance. The district court dismissed the nuisance claims in June of 2015, and later dismissed the trespass claims as well, leaving only the issue of the declaration of the rights and responsibilities of the lot owners for maintenance of Lone Mountain Road. The Fletchers appealed the district court’s denial of attorney fees on remand after an amended judgment was entered in their favor. The district court awarded some costs to the Fletchers as the prevailing parties but found that the subdivision’s covenants, conditions, and restrictions (CC&Rs), which governed this dispute, did not provide a basis for an award of attorney fees. The Idaho Supreme Court reversed the district court’s decision, holding that the Fletchers’ declaratory judgment action constituted an “enforcement action” under section 5.1 of the CC&Rs. The matter was remanded for a determination of the amount of reasonable attorney fees to be awarded and apportionment of those fees against the parties. View "Fletcher v. Lone Mtn Rd Association" on Justia Law

After a dispute over a fence project, the Eagle Springs Homeowner’s Association (“HOA”) filed a complaint seeking injunctive relief against Jan Rodina, a homeowner in the HOA. Rodina asserted, among other defenses, that the HOA approved his project and waived the right to enforce certain provisions of the subdivision’s Covenants, Conditions, and Restrictions (“CC&Rs”). The district court awarded summary judgment in favor of the HOA and granted injunctive relief. After review, the Idaho Supreme Court affirmed, finding that the HOA did not approve his project as built and that Rodina failed to show that a genuine issue of material fact precluded the award of summary judgment against him. View "Eagle Springs HOA v. Rodina" on Justia Law

Three cases were consolidated by the Idaho Supreme Court for the purposes of appeal. The cases involved three separate actions: one brought by First Security Corporation and two others brought by Richard Fosbury to quiet title to their purported ownership of irrigation water rights to land owned by Belle Ranch, LLC. All parties agreed that partial decrees for the water rights were issued in the Snake River Basin Adjudication (SRBA) in the name of South County Estates, LLC. As South County’s successors in interest, First Security and Fosbury argued their interests in the water rights are senior and therefore superior to the interest of Belle Ranch, LLC. Notwithstanding these claims, the district court quieted title to the water rights in question to Belle Ranch, LLC. First Security and Fosbury appeal. The Idaho Supreme Court determined First Security and Fosbury’s claims were precluded by res judicata: the claims were the same claims that were adjudicated in the SRBA. The Supreme Court found it was appropriate for the district court to quiet title in favor of Belle Ranch, LLC, because Belle Ranch, LLC, filed a notice of a change in ownership during the pendency of the SRBA. Accordingly, the Court affirmed the district court’s judgment. View "First Security v. Belle Ranch" on Justia Law

Dale Johnson maintained roller coasters for Silverwood, Inc. Among rising contentions and a dispute with Silverwood’s new director of construction and maintenance, Johnson resigned his position on June 8, 2015. He subsequently applied for unemployment benefits, but his claim was denied. Johnson challenged the denial with the Appeals Bureau of the Idaho Department of Labor, and a hearing was held on August 5, 2015. When denied again, Johnson appealed to the Industrial Commission. While the appeal was pending, Johnson learned that his hearing’s recording was lost. The Industrial Commission remanded the case to the Appeals Bureau for a new hearing. Ultimately, after two additional hearings and a second appeal to the Industrial Commission, Johnson won his claim for benefits with the Commission finding that Johnson was eligible for benefits. Johnson subsequently filed suit against the Department of Labor for unnecessary delays and other alleged improprieties in the handling of his claim. The district court dismissed the case for failure to file a notice of tort claim pursuant to the Idaho Tort Claims Act and then denied Johnson’s post-judgment motions. Finding no reversible error in the district court’s judgment, the Idaho Supreme Court affirmed the district court. View "Johnson v. Idaho Dept of Labor" on Justia Law