Justia Contracts Opinion Summaries

The district court granted summary judgment dismissing the negligence, contract, and fraud claims brought by Path to Health, LLP (“Path”) against Daren Long and ALL-IN INC. d/b/a RE/MAX ALL-IN REALTORS (collectively “Realtors”). Path’s claims were based on the allegation that Long misrepresented that property Path purchased was zoned for commercial use when it was actually zoned for residential use. After review, the Supreme Court found that the district court erred in dismissing Path's breach of contract claim because Idaho Code section 54-2087 was incorporated into the Buyer Representation Agreement at issue in this case. Further, the Court found the district court erred in dismissing Path's fraud claim because it found issues of fact as to whether Path justifiably relied upon Long's representations. The Court reversed on those two issues, but affirmed as to all others. The case was remanded for further proceedings. View "Path to Health, LLP v. Long" on Justia Law

The issue in this appeal centered on whether a force majeure clause in a written contract between the county and a developer did not apply to the developer’s failure to obtain zoning approval in order to construct the cement plant required in the agreement. After review of the contract and the clause at issue here, the Supreme Court held that the clause was broad enough to apply. Accordingly, the Court vacated the district court's judgment and remanded this case for further proceedings. View "Burns Concrete, Inc v. Teton County" on Justia Law

This appeal centered on the legality of a Joint Powers Agreement (“JPA”) entered into in 2003 between the Independent Highway District (“IHD”) and the City of Sandpoint (“City”) to settle litigation between the two. The JPA provided for the City to assume control of all streets in the City and for IHD to pay over to the City all highway ad valorem taxes collected on property in the city limits. After the parties had operated under the JPA for ten years, IHD notified the City that, upon reflection, it had determined the JPA was legally void and that it would no longer pay its share of the property taxes to the City. The City filed suit against IHD for breach of contract and sought both a declaratory ruling that the JPA was valid and an order enjoining IHD from interfering with the City’s control of the streets within city limits. The district court ruled in favor of the City on summary judgment and granted attorney fees. IHD appealed. Finding that the JPA was void and unenforceable (violating Idaho Code section 67-2328), the Supreme Court reversed the trial court's judgment and remanded this case for for the trial court to unwind the relationship between the parties. View "City of Sandpoint v. Independent Hwy Dist" on Justia Law

Kenneth and Sally Eyer and Idaho Forest Group, LLC (IFG) entered into a Log Purchase Agreement in which IFG agreed to purchase timber harvested from the Eyers’ land. Before logging, IFG sent an agent to the Eyers’ property to assist them in locating property lines. When the logging occurred, the loggers mistakenly cut timber located on neighboring land. The neighbors sued the Eyers for timber trespass and the Eyers brought a third-party action against IFG for breach of an assumed duty to properly mark the property lines. A jury found in favor of IFG, finding that IFG had not assumed a duty to the Eyers. The district court then awarded IFG $95,608 in attorney fees. On appeal, the Eyers argued the district court erred in awarding fees under Idaho Code section 12-120(3), contending: (1) the gravamen of the Eyers’ complaint was not a commercial transaction; and (2) the Eyers did not sell timber for a “commercial purpose” since they used the proceeds of the sale to pay medical bills. Finding no reversible error, the Supreme Court affirmed. View "Eyer v. Idaho Forest Group" on Justia Law

Stafford and Woodruff Smith (Woody) were brothers. Their father established Smith Chevrolet, and over the years the brothers have co-owned several auto dealerships, other businesses, and parcels of real property. The brothers each owned 50% of Staffwood, an entity that owned properties and other assets. In 2010, a dispute arose between the brothers involving their business dealings, and in 2010, the brothers entered into a settlement agreement (the 2010 Agreement) that gave ownership of Smith Chevrolet to Stafford. The 2010 Agreement also identified four parcels of land that either brother could purchase through a bid process. Between 2010 and 2012, various transactions occurred between Smith Chevrolet, Woody, Stafford, and Staffwood which culminated in another dispute between the brothers and another settlement agreement (the 2012 Agreement). The 2012 Agreement provided that each brother had the right to initiate a bid process to purchase the properties owned by Staffwood. In 2013, Woody sent a letter to the management of Staffwood in which he asserted that he had won the bidding process and asked Stafford to clear the title to the Smith Chevrolet Property. Woody appealed the district court’s grant of judgment on the pleadings and award of attorney fees to Stafford in his subsequent suit seeking specific performance of his winning bid. Finding no reversible error in the district court's judgment, the Supreme Court affirmed. View "Smith v. Smith" on Justia Law

In 2011, Medical Recovery Services, LLC (“the Collection Agency”), filed this action against defendants Allison and Nathan Olsen to recover on two entities’ unpaid medical bills. In 2012, the parties stipulated that the Collection Agency could recover a judgment against defendants and that it would forbear executing on the judgment if the defendants paid $100 per month between the 25th and 30th of each month until the judgment was paid. The court entered a judgment providing that the Collection Agency could recover from the Defendants the sum of $4,973.46. Defendants failed to make any payment on the judgment, and the Collection Agency attempted to execute on the judgment. The Collection Agency sought to execute on defendants’ bank account, but the account had been closed. The Collection Agency then sought a continuing garnishment to obtain Mr. Olsen’s disposable earnings from Petersen, Moss, Hall & Olsen, but that garnishment was returned unsatisfied because “Defendant is a partner in the firm, not an employee.” The Collection Agency also sought to execute on Mr. Olsen’s partnership interest, but the writ was returned unsatisfied because Mr. Olsen’s equity in the partnership was stated to be zero. The Collection Agency then sought to depose Stephen Hall, the partner in the law firm who had signed the responses to the writs of garnishment. The Collection Agency agreed to forgo taking his deposition if Hall would make $250 bi-monthly payments until the judgment was paid in full. Hall made those payments, but the Collection Agency would not accept final payment endorsed "payment in full" because it wanted to seek post-judgment attorney fees. Defendants filed a motion seeking to compel the Collection Agency to record a satisfaction of judgment in every county in which it had recorded the original judgment. The Agency responded by filing for an award of post-judgment fees it incurred trying to collect on its judgment. The Agency's motion was denied, and the Agency estopped from further collection of fees, citing the agreement reached in satisfying the judgment. The district court upheld the magistrate court's judgment. Finding that Hall only agreed to satisfy the judgment, the Supreme Court concluded the district court erred in affirming the magistrate. The case was remanded for further proceedings. View "Medical Recovery Svcs. v. Olsen" on Justia Law

A wildfire destroyed David and Kristina Parks’ house, which was insured by Safeco Insurance Company (“Safeco”). The Parks purchased an existing house, and Safeco paid the Parks a total of $255,000, the cost of the replacement house less the value of the land. The Parks filed a complaint against Safeco alleging: (1) they were entitled to $440,195.55 under the policy; and (2) Safeco committed bad faith in handling the claim. Safeco filed a Motion for Summary Judgment asserting that the policy was not breached and its conduct did not constitute bad faith. The Parks filed a Cross-Motion for Summary Judgment asserting that Safeco misrepresented the policy. Additionally, the Parks moved to amend their complaint to include a claim for punitive damages. The district court held that: (1) there was no breach of contract because the policy was unambiguous and the Parks received the amount due under the clear language of the policy; (2) Safeco did not commit bad faith in handling the claim because it complied with the terms of the policy and paid the Parks the amount owed; and (3) the Parks had not established a reasonable likelihood of proving facts at trial sufficient to support an award of punitive damages. The Parks appealed, but finding no reversible error, the Idaho Supreme Court affirmed. View "Parks v. Safeco Ins Co of Illinois" on Justia Law

In early 2011, Trent Gearheart was severely injured in an automobile accident caused by an underinsured motorist (“UIM”). After the accident, Trent’s parents, Ronald Gearhart and Brandi L. McMahon, who were divorced, each attempted to collect on their separately held auto insurance policies with Enumclaw. Each of those policies provided maximum coverage of $300,000 for accidents caused by underinsured motorists. Enumclaw contended that because of anti-stacking language in the policies, the total UIM benefit under the combined policies was limited to $300,000. The district court held on summary judgment that the UIM anti-stacking provision in each policy was invalid and, therefore, ruled that Enumclaw was obligated for the full $300,000 policy limit on both policies. Enumclaw appealed. Finding no reversible error, the Idaho Supreme Court affirmed the district court's judgment. View "Gearhart v. Mutual of Enumclaw Ins Co" on Justia Law

John Kugler appealed the grant of summary judgment in his suit against Ron Nelson, David Powers, Steven Kenison, William Armstrong, and Powers Candy Co., Inc. (collectively “the Defendants”). Until mid-2010, Kugler, Nelson, Powers, Kenison, and Armstrong were all shareholders of H & M Distributing, Inc. (H & M), a wholesale distributor of beverages, cigarettes, and other miscellaneous items. In his complaint, Kugler alleged breach of various agreements and wrongful actions taken by the Defendants all in relation to Nelson's departure from H & M. The district court dismissed all of Kugler’s claims because it found that the claims were derivative and Kugler failed to comply with derivative action requirements. Finding no reversible error, the Supreme Court affirmed. View "Kugler v. Nelson" on Justia Law

Appellant Bryan Trucking, Inc., sued Respondent Terry Gier for fraud, based on statements and representations Gier allegedly made to Bryan Trucking that induced Bryan Trucking to purchase a used commercial truck from a third party. Gier was a member of Gier Jammer’s Diesel Repair, LLC. Gier Jammer’s serviced long-haul trucks for Bryan Trucking starting in 2009. In August 2012, Gier Jammer’s overhauled the motor in a 2005 Kenworth truck owned by Niel Ring Trucking, Inc. (“Ring Trucking”). Niel Ring (“Ring”) notified Gier that Ring Trucking wanted to sell the truck, and Gier arranged the deal. The district court dismissed the claim by stipulation of the parties. Bryan Trucking appealed the district court’s subsequent award of costs and attorney fees to Gier. Finding no reversible error in the district court's decision, the Supreme Court affirmed. View "Bryan Trucking v. Gier" on Justia Law