Articles Posted in Idaho Supreme Court - Civil

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This consolidated action began as four separate lawsuits arising from transactions involving a dairy operation. This appeal focused on the claims asserted by Jack McCall against Max Silva personally. Max Silva appeals from the judgment of the district court in Twin Falls County finding him personally liable for the purchase of 116 dairy cows. After a bench trial, the district court found Silva personally liable for the purchase of the cows and dismissed the other claims against him. Silva contended that the district court erred when it found him personally liable for the purchase. Silva also argued that the district court abused its discretion when it failed to award him attorney fees proportionate to the claims on which he prevailed at trial. Finding no reversible error, the Idaho Supreme Court affirmed. View "McCall v. Silva" on Justia Law

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The Idaho Supreme Court concluded the district court erred in determining that the insurer did not breach its insurance contract with its insureds, and in dismissing the insureds’ bad faith claim that resulted from that determination. Plaintiffs Joel and Kathleen Harmon filed a claim with their insurance company, State Farm Mutual Automobile Insurance Co., after their motorhome was broken into and damaged. The Harmons subsequently brought suit against State Farm in district court, claiming that State Farm breached the insurance agreement by failing to pay the amount required to actually repair the vehicle or pay the cash value. The Harmons also brought a claim for bad faith. State Farm moved for summary judgment on both claims, which the district court granted. The case was remanded for further proceedings. View "Harmon v. State Farm Mutual Auto Ins Co." on Justia Law

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American Semiconductor, Inc. sued to recover damages arising out of Zilog, Inc., contracting with Sage Silicon Solutions, LLC, to perform engineering services for it, where that entity was formed by, and the services were provided by, employees of American Semiconductor, Inc. American Semiconductor, Inc., obtained a jury verdict awarding damages against the engineers and the entity they had formed, but it did not recover against Zilog, Inc. American Semiconductor, Inc., appealed, challenging the dismissal of one of its claims against Zilog, Inc., and seeking a new trial on damages against the engineers and their entity. The Supreme Court found no reversible error and affirmed the district court judgment. View "American Semiconductor v. Sage Silicon Solutions" on Justia Law

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The faulty, inadequate, or defective work exclusion did not apply to the loss in this case. At issue in this appeal was the dismissal of Plaintiff’s action seeking to recover under an insurance policy for the loss of her house caused when a renter, who had an option to purchase the house, demolished it. The district court held that coverage for such loss was excluded under the policy. The Supreme Court vacated the judgment of the district court and remanded this case for further proceedings. View "Fisher v. Garrison Property & Casualty Ins" on Justia Law

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Val and LaRee Westover appealed the district court’s judgment and denial of their request for writs of mandate and prohibition against Franklin County Assessor Jase Cundick. The dispute arose when the Westovers granted an easement to Rocky Mountain Power on property owned by the Westovers. Based on his office’s records, Cundick sent a letter to Rocky Mountain Power stating that the Westovers did not own the property in question. The Westovers sought a writ of mandate to require Cundick to retract the letter and a writ of prohibition to prevent him from sending such letters in the future. The district court denied the Westovers’ request for writs of mandate and prohibition after it concluded that there were other remedies available at law. On appeal, the Westovers argued the district court erred by failing to grant injunctive relief prohibiting Cundick from sending out letters concerning real estate transactions and property ownership. Although the Westovers’ complaint did not request that the district court grant injunctive relief, they argued that the district court erred because the Westovers were clearly entitled to injunctive relief under Idaho Rule of Civil Procedure 54(c). Finding no reversible error, the Supreme Court affirmed. View "Westover v. Cundick" on Justia Law

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This appeal arose from a lawsuit brought by a contractor, Michael Kelly against his former client, Pamela Wagner, alleging nonpayment of amounts due to him for the performance of construction work. The district court found in favor of Kelly and awarded him a total judgment of $13,762.54 ($4,694.64 of damages and $9,067.90 of prejudgment interest). On appeal, Wagner argued that the district court erred in finding that Kelly was owed for the construction work. She further argued that the district court erred in awarding prejudgment interest to Kelly. Finding no reversible error, the Supreme Court affirmed. View "Kelly v. Wagner" on Justia Law

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Gordon Paving Company, Inc., Northwest Sand & Gravel, Inc., Blackrock Land Holdings, LLC (collectively, “Gordon Paving”), Brandon Hansen, an individual, Brian Hansen, an individual, Carol Hansen GPC Nevada Trust, Craig Hansen GPC Nevada Trust, Canyon Equipment and Truck Service, Inc., and Doe Entities owned by Brian, Brandon, and Craig Hansen (collectively “Guarantors”) appealed the district court’s denial of their motion to set aside default in a breach of personal guarantee action brought by AgStar Financial Services, ACA (“AgStar”). Between 2007 and 2008, Gordon Paving borrowed $10 million from AgStar. In addition to real and personal property collateral, the indebtedness was secured by separate guarantee agreements executed by Guarantors. By 2012, Gordon Paving had defaulted and AgStar sued for foreclosure. A year later, the district court entered a Judgment and Decree of Foreclosure against Gordon Paving. AgStar purchased the real property collateral at a foreclosure sale. AgStar moved for entry of a deficiency judgment for the difference between the unpaid judgment as of the time of the sale and its credit bids for the real property. The district court denied AgStar’s motion for a deficiency judgment, finding that the reasonable value of the properties that AgStar purchased by credit bids was nearly two million dollars greater than Gordon Paving’s indebtedness. In an Opinion issued in early 2017, the Idaho Supreme Court held that Gordon Paving’s indebtedness to AgStar had been fully satisfied and discharged. AgStar brought the present action against Guarantors, bringing a number of theories, including breach of personal guarantee. The district court ultimately entered a judgment against Guarantors on the cause of action based on breach of their personal guarantees. AgStar agreed to dismiss the other claims with prejudice because the judgment on the guarantees represented the total remaining amount due on Gordon Paving’s indebtedness. AgStar moved for an award of attorney fees and costs, which was granted. Guarantors timely appealed, but finding no error in defaulting the Guarantors, and in the award of fees and costs, the Supreme Court affirmed. View "Agstar Financial v. Gordon Paving Co, Inc." on Justia Law

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AgStar Financial Services, ACA (AgStar) appealed the district court’s award of attorney fees to Northwest Sand & Gravel, Inc., Gordon Paving Company, Inc., and Blackrock Land Holdings, LLC (collectively, Gordon Paving), following a deficiency proceeding. Gordon Paving’s cross-appeal asserted that the district court erred in three respects: (1) by permitting AgStar to sell personal property serving as collateral for Gordon Paving’s debt to AgStar after the district court determined that AgStar was not entitled to a deficiency judgment; (2) by awarding AgStar post-judgment attorney fees; and (3) allowing AgStar’s claim of exemption to a royalty check. AgStar moved the district court for an order directing Gordon Paving to transfer the titles of various vehicles that Gordon Paving had pledged as collateral for certain bond obligations to AgStar, and for a comfort order allowing AgStar to sell the personal property collateral at auction. Gordon Paving opposed AgStar’s motion, arguing that because the district court had already determined that AgStar had received real property worth more than the debt owed under the foreclosure judgment and denied AgStar a deficiency judgment, AgStar was estopped from selling any further collateral because Gordon Paving’s debt was extinguished. Gordon Paving moved for an award of attorney fees, asserting that, as the prevailing party in the deficiency proceeding, it was entitled to attorney fees. AgStar opposed Gordon Paving’s request for attorney fees. After review, the Supreme Court found: (1) the district court abused its discretion when it awarded attorney fees without first determining the prevailing party in the entire action; (2) the district court did not err when it held a bond agreement did not bar Gordon Paving from being awarded attorney fees; (3) the district court erred when it allowed AgStar to continue to sell the personal property collateral to satisfy the foreclosure judgment. The Court did not reach the issue of the district court’s award of post-judgment attorney fees to AgStar because Gordon Paving did not support its claim with sufficient argument or authority. As such, the Court reversed the district court’s order allowing AgStar to sell the personal property collateral to satisfy the foreclosure judgment; vacated the judgment awarding attorney fees and costs to Gordon Paving; and remanded for the district court to determine attorney fee and cost issues and for further proceedings. View "Agstar Financial v. NW Sand & Gravel" on Justia Law

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This case was an appeal of a judgment: (1) denying recovery on an alleged oral promise to grant the Plaintiffs a right of first refusal with respect to a parcel of real property they were leasing; (2) denying recovery on an alleged oral promise to purchase the Plaintiffs’ buildings that were located on that property; and (3) finding that the Plaintiffs were guilty of unlawful detainer. Finding no reversible error, the Supreme Court affirmed the judgment. View "Nicholson v. Coeur d'Alene Placer Mining Corp" on Justia Law

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Jeremy and Jessica Litster appealed a district court dismissal on summary judgment. The case concerned the enforceability of three promissory notes, which were prepared and issued by Jeremy to Jason Lee , Scott McNab, and a non-party, Rick Lee. In February 2009, Jeremy learned of an "investment opportunity" that required a minimum buy-in of $500,000. Jeremy and Jason solicited close friends and family to "invest" by transferring money to them, which would later be transferred to Jeremy's relative, Marc Jenson. Ultimately, the "investment" failed, and Plaintiffs and other "investors" looked to Jeremy for repayment. Jeremy made payments on these promissory notes. However, in July 2011, Jeremy stopped making payments because he learned that the Idaho Department of Finance had been notified regarding his investment solicitation activity. Plaintiffs filed a complaint against the Litsters in 2014, alleging three counts of breach of contract for failure to pay the amounts due according to the promissory notes. The Litsters answered asserting, inter alia, the affirmative defense that the notes were issued under duress. Plaintiffs filed a motion for summary judgment of the issues of breach of contract and duress. The district court granted Plaintiffs' motion. On the issue of duress, the district court found in Plaintiffs' favor under two different legal theories: (1) the Litsters failed to provide sufficient evidence of their claim for duress to create a genuine issue of material fact; and (2) the district court noted that the undisputed evidence demonstrated that Jeremy ratified the promissory notes by making payments thereon. It concluded that, in addition to the absence of a genuine issue of material fact, the Litsters' "claim for duress fails because [Jeremy ] ratified the contracts by making payments on the [n]otes." The Supreme Court affirmed summary judgment, finding that the Litsters failed to contest the alternate grounds upon which the summary judgment was granted. View "Lee v. Litster" on Justia Law