Justia Contracts Opinion Summaries

Articles Posted in Idaho Supreme Court - Civil
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Appellant Charles DeGroot and DeGroot Farms, LLC appealed the district court's grant of summary judgment on its claims against Standley Trenching, Inc. d/b/a Standley & Co., relating to the construction and installation of a manure handling system at the DeGroot dairy. Beltman Construction, Inc., d/b/a Beltman Weldling and Construction, was the general contractor for the project. Beltman subcontracted with Standley for the installation of the manure handling equipment. J. Houle & Fils, Inc. manufactured the manure handling equipment installed at the DeGroot dairy. Because of maintenance problems with the manure handling equipment, DeGroot initiated litigation against Standley and Houle. DeGroot then initiated litigation against Beltman. Beltman brought a third party complaint against Standley. Standley counterclaimed against DeGroot for amounts due for parts and services. The district court granted Standley summary judgment on its counterclaim, granted Standley summary judgment on DeGroot's claims, and granted Standley summary judgment on Beltman's third party complaint. DeGroot appealed. Finding no reversible error, the Supreme Court affirmed. View "DeGroot v. Standley Trenching, Inc." on Justia Law

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This appeal stemmed from the failure of Tamarack Resort, which was owned, developed, and operated by Tamarack Resort, LLC. The Resort was slated as a year-round community, complete with cross-country and downhill skiing, a championship golf course, hotel and conference facilities, retail shopping, restaurants, and lounges. Tamarack planned to offer a panoply of real estate options, including custom homes, condominiums, townhomes, chalets, and cottages. Construction at the Resort began in 2003. Housing units were built and sold, hotel facilities were developed, and by 2006, the ski areas, golf course, retail shops, and restaurants were up and running. In 2004, Tamarack hired Teufel Nursery as its landscape developer. Teufel provided landscaping services at the Resort from 2004 until early 2008. This appeal centered the priority of liens as between Teufel Nursery's mechanics lien and Credit Suisse's mortgages. The district court held that while Teufel had a valid and enforceable lien, it was inferior to Credit Suisse’s mortgages. On appeal, Teufel argues that such holding was in error and that the district court also erred in calculating Teufel's lien amount, interest, and attorney fees. Finding no error, the Supreme Court affirmed. View "Credit Suisse v. Teufel Nursery" on Justia Law

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Appellant Edged in Stone, Inc. (EIS) sought damages for breach of contract, breach of warranty, breach of implied covenant of good faith and fair dealing, negligence and unjust enrichment when a skid loader it purchased experienced mechanical problems. The district court dismissed all of EIS's claims except breach of contract and unjust enrichment. Later, the district court entered a judgment in favor of Northwest Power Systems, LLC (NWPS), dismissing EIS's remaining claims and awarded NWPS attorney's fees and costs. EIS appealed to the Supreme Court, arguing arguing that the district court erred in granting summary judgment to NWPS. After careful consideration of the trial court record, the Supreme Court found no reversible error and affirmed that court's grant of summary judgment. View "Edged In Stone v. NW Power Systems" on Justia Law

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Medical Recovery Services, LLC (MRS), a licensed collection agency, appeals from the district court’s order affirming default judgments entered by the magistrate court. Each Respondent’s account indebtedness was assigned to MRS. MRS filed suit to recover payment from each Respondent and also sought $350 in attorney fees from each, based on a contractual provision. None of the Respondents answered the complaints filed by MRS, so MRS filed for default judgments to be entered in each case. The magistrate court entered default judgments as to all Respondents but granted attorney fees in amounts less than the $350 that MRS was requesting under the contracts. MRS asserted that the magistrate erred in awarding attorney fees in the amount of the principal owed by the Respondents for medical services, as opposed to $350, which was the minimum amount that each Respondent contracted to pay. Finding no reversible error, the Supreme Court affirmed the district court. View "Medical Recovery Services v. Strawn" on Justia Law

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The issue on appeal before the Supreme Court in this case was a trial court's order denying a motion to compel nonparties to a contract to arbitrate pursuant to an arbitration clause in the contract. Finding no reversible error, the Supreme Court affirmed. View "Clearwater REI v. Boling" on Justia Law

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Appellant appealed the grant of a summary judgment that dismissed his claim seeking to enforce a vendee’s lien in real property. Because the appellant only addressed on appeal one of two possible grounds upon which the district court granted summary judgment, the Supreme Court affirmed the district court. View "Cuevas v. Barraza" on Justia Law

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In 2007, Steven and Valerie Hruza sought to obtain a loan from Clearwater Mortgage (Clearwater). Clearwater requested Defendant-Respondent Wade Massey to perform an appraisal of their real property located in Caldwell. Massey owned co-defendant Capitol West Appraisals and is a professional appraiser licensed to practice in Idaho. Massey performed the appraisal and sent a Summary Appraisal Report to Clearwater indicating that market value of the property was $1,150,000. Clearwater decided to deny the Hruzas' loan application before considering the appraisal. Massey admitted that both he and Clearwater were aware that the appraisal contained errors. Clearwater's president and Massey agreed that Massey would not fix the errors and Clearwater would not pay Massey for the appraisal. The Hruzas submitted a subsequent loan application to Idahy Federal Credit Union (now known as Icon). Icon approved the loan, secured by a deed of trust on the Hruzas' property. Icon sent a check to Capitol, and Capitol accepted payment. Plaintiff-Appellant CUMIS Insurance Society, Inc. was the fidelity bond insurer for Icon. It paid Icon as a result of the Hruzas' default on their loan. As Icon's subrogee, CUMIS filed suit against Massey and Capitol, alleging professional negligence, negligent misrepresentation, and breach of contract based on Massey's conduct in preparing the appraisal. A central point of dispute between the parties was how Icon obtained the appraisal. CUMIS alleged that the Hruzas included the appraisal with their loan application, thus prompting Icon to pay Capitol for the appraisal. Massey suggested that Icon improperly obtained the appraisal, pointing to Icon's admission that it did not know how it obtained it and that Icon did not request a letter of assignment from Clearwater to use or rely on the appraisal. The district court concluded that CUMIS could not establish that Massey owed a legal duty to Icon, that Idaho does not recognize a cause of action for negligent misrepresentation against appraisers, and that CUMIS had no breach of contract claim. Therefore, the district court granted Massey’s motion for summary judgment and dismissed all claims asserted by CUMIS, with prejudice. Finding that there remained issues of material fact, the Supreme Court vacated the district court's judgment dismissing CUMIS's complaint. The case was remanded for further proceedings. View "CUMIS Insurance Society, Inc. v. Massey" on Justia Law

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In 1999, Rick and Natalie Foeller entered into an agreement with Melaleuca of Canada, Inc., under which the Foellers would serve as independent marketing executives in exchange for monthly commission payments. In 2008, the Foellers breached this agreement but Melaleuca continued to pay them commissions because it was unaware of the breach. Upon learning of the breach, Melaleuca sued to recover the payments it had made to the Foellers after they breached. The district court granted Melaleuca’s motion for summary judgment, finding that under the forfeiture clause of its agreement with the Foellers, Melaleuca was simply excused from performing once the Foellers breached and ordered the Foellers to refund Melaleuca the commissions they received after their breach. The Foellers appealed, arguing that the district court erred because the forfeiture clause was an illegal penalty and Melaleuca was required to prove damages. Agreeing with the Foellers, the Supreme Court vacated the district court’s judgment and remanded the case for further proceedings. View "Melaleuca, Inc v. Foeller" on Justia Law

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American West Enterprises appealed a district court's grant of summary judgement to Case New Holland, Inc. (CNH) in its effort to recover the cost of a remanufactured tractor engine CNH sold to a local seller that American West purchased. The district court dismissed American West's claim of implied warranty because there was no privity between American West and CNH. The district court also rejected American West's claims that it was an intended third party beneficiary of a contract between CNH and Pioneer and that Pioneer was an agent of CNH. American West appeals. The district court denied CNH's request for attorney fees and costs below. CNH cross-appealed. Finding no error, the Supreme Court affirmed all but the denial of attorney fees. The case was remanded to the district court for finding costs and fees in favor of CNH. View "American West Ent. v. CNH, LLC." on Justia Law

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Monsanto, through a wholly owned subsidiary, owns a quartzite mine near Soda Springs. Monsanto and Washington Group International, Inc. (WGI) contracted with each other for WGI to operate the mine. This agreement was memorialized in an agreement set to expire at the end of 2002. A by-product of WGI's operations was silica sand. Silicon International Ore, LLC (SIO) contacted Monsanto about acquiring the sand. SIO presented Monsanto with a proposed contract, but that contract was never executed. However, Monsanto and WGI executed an Addendum to the agreement that authorized WGI to construct and operate a processing facility for silica sand at the quartzite mine and to pay Monsanto royalties for silica that was sold by WGI to a third party. SIO and WGI executed a Master Agreement, under which WGI agreed to provide silica sand to SIO; SIO agreed to pay for the construction of the processing facility for the silica sand; SIO agreed to pay WGI to dry, screen, and bag the silica sand; SIO agreed to pay WGI an additional amount for processed sand; and WGI agreed to load the bagged silica sand onto SIO trucks. Shortly before the First Quarzite Agreement was set to expire, Monsanto and WGI executed a second Quarzite Agreement and addendum. The Second Addendum was almost identical to the First, but provided that WGI would pay Monsanto different amounts for sand based on several considerations and that the "[t]itle to the silica sand sold by SIO shall pass directly from [Monsanto] to SIO upon processing . . . subject to payment." WGI notified SIO that it would no longer be providing SIO with silica sand after the end of the year. After discussions with SIO, SIO was permitted to continue processing and bagging sand through April 29, 2008. SIO dismantled its operations in the quarry and removed its building and equipment. The following year, SIO sued Monsanto and WGI for damages for violating and interfering with an alleged verbal agreement to continue processing silica sand. SIO alleged that it and Monsanto entered into a verbal agreement separate and apart from the Master Agreement for the sale of silica sand. SIO asserted breach of the alleged verbal agreement, breach of the implied covenant of good faith and fair dealing, equitable estoppel, and quasi-estoppel. Monsanto denied SIO's claims and asserted the statute of frauds as an affirmative defense. Against WGI, SIO claimed that WGI breached the covenant of good faith and fair dealing implied into the Master Agreement, and SIO alleged that WGI tortiously interfered with the alleged verbal agreement between SIO and Monsanto. Monsanto and WGI moved to dismiss, which were ultimately granted by the trial court. Finding no reversible error, the Supreme Court affirmed. View "Silicon Int'l v. Monsanto Co." on Justia Law