Justia Contracts Opinion Summaries

TCR, LLC, a Wyoming limited liability corporation, filed a lawsuit against Teton County, Idaho, after the County refused to record a Condominium Plat for property within a planned unit development (PUD) owned by TCR. TCR sought declaratory and injunctive relief, claiming the lot had already been approved for condominium development, and also alleged breach of a 1996 settlement agreement between the County and TCR’s predecessor. The district court granted TCR’s motion for summary judgment on the declaratory and injunctive relief claim, ordering the County to record the Condominium Plat, but granted the County’s motion for summary judgment on the breach of contract claim.The district court found that the County had previously approved amendments to the PUD Plat in 2018 and 2019, allowing TCR to build sixteen standalone condominiums on Lot 12B. The County’s refusal to record the Condominium Plat was based on an alleged site plan from 1995, which the district court found inadmissible. The district court concluded that the County had no legal basis to refuse the recording and enjoined the County from preventing TCR’s attempts to record the Plat.The Supreme Court of Idaho affirmed the district court’s decision to grant TCR’s claim for declaratory and injunctive relief, holding that the County had no valid reason to refuse the recording. However, the Supreme Court reversed the district court’s grant of summary judgment to the County on the breach of contract claim, finding that there were genuine issues of material fact regarding whether the County breached the 1996 Settlement Agreement. The case was remanded for further proceedings on this issue.The Supreme Court also found that the district court erred in denying TCR’s second motion to enforce, which sought to compel the County to issue building permits after the Condominium Plat was recorded. The Court awarded TCR its attorney fees and costs on appeal, concluding that the County acted without a reasonable basis in fact or law. View "TCR, LLC v. Teton County" on Justia Law

The case involves property owners Brenda and Ray von Wandruszka and Robert R. Davis, who sued the City of Moscow after the city adopted a resolution in 2021 revising its utility billing process. The new policy required property owners to sign contracts making them responsible for tenants' unpaid water bills, under threat of water service termination. The plaintiffs signed the contracts under protest and claimed they were unenforceable adhesion contracts signed under duress.The District Court of the Second Judicial District of Idaho reviewed cross-motions for summary judgment. The court ruled that the city was not authorized to recover tenants' unpaid utility charges from property owners, citing City of Grangeville v. Haskin. However, it also ruled that the city could require owner-occupied properties to enter agreements to pay for water consumed. Both parties appealed the split decision.The Supreme Court of Idaho reviewed the case and clarified that City of Grangeville does not prohibit municipalities from collecting tenants' unpaid utilities from property owners if there is a contractual basis. The court found that the utility billing agreements were not secured under duress, as the city's actions were not coercive. However, the court determined that the lien provisions in the agreements were too vague and indefinite to be enforceable, rendering the contracts invalid.The Supreme Court of Idaho affirmed the district court's summary judgment in favor of the plaintiffs regarding tenant-occupied properties but reversed the summary judgment in favor of the city concerning owner-occupied properties. The case was remanded for further proceedings consistent with the opinion. The plaintiffs were awarded costs as the prevailing party, but no attorney fees were granted to either side. View "Von Wandruszka v. City of Moscow" on Justia Law

John Gomez, Gilbert Hurtado, and Jesus Hurtado were members of G&H Dairy, LLC, which defaulted on its loans in 2013. To avoid bankruptcy, they negotiated with Wells Fargo and signed a Letter of Intent (LOI) to distribute G&H's assets among themselves. Gomez and Jesus Hurtado purchased the personal property assets and assumed portions of G&H’s debt, but they could not agree on the sales price for the real property. Gomez sued the Hurtado brothers and G&H for breach of contract, estoppel, unjust enrichment, and breach of fiduciary duty, and sought judicial dissolution of G&H. The Hurtados counterclaimed for damages and also sought dissolution.The District Court of the Fifth Judicial District of Idaho granted summary judgment for the Hurtados on Gomez’s breach of contract claim, ruling the LOI unenforceable, but denied summary judgment on the other claims. After a bench trial, the court ordered the dissolution and winding up of G&H and dismissed the remaining claims. Gomez appealed.The Supreme Court of Idaho affirmed the district court’s decision. It held that the LOI was unenforceable as it was an offer contingent on future agreements and lacked definitive terms. The court also found no breach of fiduciary duty by the Hurtados, as the LOI was unenforceable and the parties had not agreed on the real property transfer terms. The court dismissed Gomez’s quasi-estoppel claim, concluding that the Hurtados did not change their legal position since the LOI was not enforceable. The court also upheld the district court’s final accounting and winding up of G&H, finding no error in the characterization of transactions or member allocations. The court awarded attorney fees to the Hurtados, determining that Gomez’s appeal was pursued unreasonably and without legal foundation. View "Gomez v. Hurtado" on Justia Law

This case involves a dispute between two neighboring landowners, David W. Axelrod, as Trustee of the David W. Axelrod Family Trust, and Reid Limited Partnership (RLP) and Michael Reid, an individual. The dispute arose from a settlement agreement concerning the real property and easement rights of the two parties. Axelrod purchased a property in Teton County in 2003, which was not accessible by road. Reid, who owned and operated an organic dairy farm nearby, preferred Axelrod to build onto an existing dirt road on Reid's property rather than using two easements provided in Axelrod's deed. In 2004, Axelrod built onto the existing dirt road, referred to as the "RLP Easement." However, the relationship between Axelrod and Reid began to sour in 2011, leading to a series of disputes and legal actions.The district court initially concluded that Axelrod did not have an express easement for use of the RLP Easement, but he did have an easement by estoppel. The parties then executed a settlement agreement and stipulated to dismiss the suit. However, disagreements over the implementation of the settlement agreement led to further litigation. The district court granted Axelrod's motion for summary judgment, concluding that Reid had failed to properly support any assertion of fact or address the assertions of fact in Axelrod's motion for summary judgment.On appeal, the Supreme Court of the State of Idaho affirmed in part, vacated in part, and remanded the case for further proceedings. The court affirmed the grant of summary judgment against Reid individually and affirmed the district court's judgment dismissing RLP's counterclaims for conversion and violation of the implied covenant of good faith and fair dealing. The court also affirmed the judgment of the district court on Axelrod's breach of contract claim and the judgment of the district court refusing to allow amendment of the pleadings to add RFLP as a party. However, the court vacated the judgment of the district court dismissing RLP's trespass claim. The court also vacated the attorney fee award as against RLP and remanded for further proceedings consistent with this opinion. View "Axelrod v. Reid Limited Partnership" on Justia Law

This case involves a dispute over a real estate and construction contract. The plaintiffs, Myles Davis and Janelle Dahl, sued their homebuilder, Blast Properties, Inc., and Tyler Bosier, alleging breach of contract, fraud, and violations of the Idaho Consumer Protection Act. The plaintiffs sought to amend their complaint to include a prayer for relief seeking punitive damages. The U.S. District Court granted the plaintiffs' motion to amend their complaint, but certified a question to the Supreme Court of the State of Idaho due to inconsistencies in the interpretation of Idaho Code section 6-1604(2), which prohibits claimants from including a prayer for relief seeking punitive damages in their initial pleading.The U.S. District Court asked the Supreme Court of the State of Idaho to determine the proper means a trial court must apply when considering a motion to amend a pleading to include a prayer for relief seeking punitive damages pursuant to Idaho Code section 6-1604(2). The Supreme Court of the State of Idaho rephrased the question to clarify the obligations of a trial court under Idaho Code section 6-1604(2) when ruling upon a motion to amend a complaint or counterclaim to include a prayer for relief seeking punitive damages.The Supreme Court of the State of Idaho held that section 6-1604(2) requires the trial court to conduct a careful examination of the evidence submitted by the moving party in support of its motion to amend and the arguments made to determine whether there is a "reasonable probability" that the evidence submitted is: (1) admissible at trial; and (2) "sufficient" to support an award of punitive damages. The word "sufficient" means that the claim giving rise to the request for punitive damages must be legally cognizable and the evidence presented must be substantial. The court clarified that the clear and convincing evidentiary standard is the standard for a jury, not the trial court when it is ruling on a motion to amend a pleading to include a prayer for relief seeking punitive damages. View "Davis v. Blast" on Justia Law

This case involves a dispute between two neighboring landowners, David W. Axelrod, as Trustee of the David W. Axelrod Family Trust, and Reid Limited Partnership (RLP), over real property and easement rights. Axelrod purchased a property in Teton County in 2003, which was not accessible by road. Michael Reid, who owned and operated an organic dairy farm on land owned by RLP, leased land adjacent to Axelrod's property. Axelrod built an access road through the RLP property, which led to a series of disputes between the parties. In 2017, Axelrod filed a lawsuit seeking clarification about his easement rights. The parties reached a settlement agreement, which required Axelrod to build a new road along a different easement and Reid to pay for the installation of a cattle guard. However, disagreements arose over the placement and cost of the cattle guard, leading to further litigation.The district court granted Axelrod's motion for summary judgment, concluding that Axelrod did not have an express easement for use of the RLP Easement, but he did have an easement by estoppel. The court also found that Reid had breached the settlement agreement by failing to pay for the cattle guard. Reid appealed the decision.The Supreme Court of the State of Idaho affirmed the district court's decision in part and vacated it in part. The court affirmed the grant of summary judgment against Reid and the dismissal of RLP's counterclaims for conversion and violation of the implied covenant of good faith and fair dealing. The court also affirmed the judgment on Axelrod's breach of contract claim and the refusal to allow amendment of the pleadings to add Reid Family Limited Partnership as a party. However, the court vacated the dismissal of RLP's trespass claim and the award of attorney fees to Axelrod against RLP, remanding for further proceedings. View "Axelrod v. Reid Limited Partnership" on Justia Law

In this case, David W. Axelrod, as Trustee of the David W. Axelrod Family Trust, and Reid Limited Partnership (RLP), along with Michael Reid, an individual, were neighboring landowners in Teton County, Idaho. Axelrod purchased a parcel of land in 2003 that was not accessible by road. Reid, who owned and operated an organic dairy farm nearby, leased land adjacent to Axelrod's parcel. Axelrod had two options for building an access road: build along two easements provided in his deed or build onto an existing dirt road that came through the RLP property. Reid preferred Axelrod to build onto the existing dirt road, which Axelrod did in 2004. However, in 2011, the relationship between Axelrod and Reid began to sour, leading to a series of disputes and legal actions.The District Court of the Seventh Judicial District, State of Idaho, Teton County, initially concluded that Axelrod did not have an express easement for use of the RLP Easement, but he did have an easement by estoppel. The parties then executed a settlement agreement and stipulated to dismiss the suit. However, disagreements over the implementation of the settlement agreement led to further litigation. The district court granted Axelrod's motion for summary judgment, concluding that Reid, as the nonmoving party, had failed to properly support any assertion of fact or address the assertions of fact in Axelrod’s motion for summary judgment.On appeal, the Supreme Court of the State of Idaho affirmed the district court's grant of summary judgment against Reid individually and affirmed the district court’s judgment dismissing RLP’s counterclaims for conversion and violation of the implied covenant of good faith and fair dealing. The Supreme Court also affirmed the judgment of the district court on Axelrod’s breach of contract claim and the judgment of the district court refusing to allow amendment of the pleadings to add Reid Family Limited Partnership (RFLP) as a party. However, the Supreme Court vacated the judgment of the district court dismissing RLP’s trespass claim and remanded for further proceedings. The Supreme Court also vacated the attorney fee award as against RLP and remanded for determination of an appropriate fee award at the conclusion of the proceedings. View "Axelrod v. Reid Limited Partnership" on Justia Law

This case involves a medical debt collection claim between Medical Recovery Services, LLC (MRS), a debt collection service representing Franklin County Medical Center (FCMC), and Cierra Moser, a former FCMC employee. MRS sought to collect debt for medical services provided to Moser at FCMC during her employment. FCMC offered a 50% discount to employees for unpaid medical bills after insurance payments. When Moser's employment ended, FCMC allegedly retracted the discount and assigned the debt to MRS.The magistrate court granted partial summary judgment favoring MRS regarding a minimum principal amount of debt owed by Moser and decided in favor of MRS on the issue of FCMC's right to retract the employee discount. However, the district court reversed the partial grant of summary judgment and remanded all issues for retrial due to disputed facts requiring retrial.On appeal, MRS argued that the district court erred in reversing the partial grant of summary judgment and in remanding all issues for retrial. The Supreme Court of Idaho affirmed the district court's decision, finding that there was a material dispute of fact over the amount of medical debt owed by Moser, which precluded a grant of partial summary judgment. Furthermore, MRS failed to ensure relevant transcripts were included in the record on appeal to the Supreme Court, which was fatal to its position that the district court erred in remanding for a retrial on all issues. View "Medical Recovery Services v. Moser" on Justia Law

This case involved a property dispute between neighbors Robert and Debra Talburt and Miles and Leanne Millard in Idaho. The Millards sought to establish their rights to a disputed tract of land and two easements, as well as breach of contract damages for maintenance of a shared well. The Talburts countered by constructing a fence within the roadway easement, stating they were relocating the roadway easement, and locking the pump house for the shared well. The Supreme Court of Idaho affirmed the district court's judgement in favor of the Millards on their claims related to the easements and ordered the Talburts to remove the fence and cease efforts to block access to the shared well. The court also found the Talburts' attempt to relocate the roadway easement to be unlawful, invalid, and void. However, the district court found that the Millards had abandoned their breach of contract claim and failed to establish a right to the disputed property. The Supreme Court also affirmed the district court's award of a portion of the Millards' attorney fees and costs to them. View "Millard v. Talburt" on Justia Law

This case involves a dispute between Melissa Sanchez, a tenant, and Chris and Jennifer Pickering, her landlords, over the terms of a lease agreement for a mobile home owned by the Pickerings. Sanchez believed the agreement was a lease-to-own contract, while the Pickerings asserted it was a lease with a purchase option contract. After the Pickerings initiated an eviction action due to Sanchez's alleged violations of the agreement, Sanchez caused extensive damage to the home.The Pickerings sued Sanchez for waste, claiming she caused $40,000 in damages and sought treble damages. Sanchez counterclaimed, alleging violation of the Idaho Consumer Protection Act (ICPA), breach of contract, unjust enrichment, and retaliatory eviction. The district court found Sanchez liable for damages to the residence and awarded treble damages. It also determined that there was no deception on the Pickerings' part to sustain Sanchez's ICPA claim, the agreement was unenforceable due to a lack of mutual understanding, and that the Pickerings were unjustly enriched by the $10,000 down payment and offset the Pickerings' damages award by this amount. The remaining claims were dismissed.On appeal, the Supreme Court of Idaho affirmed the district court's decision. The court found substantial and competent evidence supporting the district court's decision that the Pickerings did not engage in a deceptive act under the ICPA. The court also rejected Sanchez's contention that the district court's damages award should have been reduced to reflect an insurance payment received by the Pickerings as Sanchez failed to provide an adequate record for review. Finally, the court upheld the district court's unjust enrichment award, finding that Sanchez had not demonstrated an abuse of discretion. The Pickerings were awarded attorney fees for having to respond to the collateral source issue. View "Pickering v. Sanchez" on Justia Law