Justia Contracts Opinion Summaries

Articles Posted in Idaho Supreme Court - Civil
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Plaintiffs-Appellants Norman and Robin Riley appealed the district court's grant of summary judgment in favor of respondents Spiral Butte Development, LLC and Jim Horkley. Plaintiffs alleged breach of contract against Spiral Butte and sought specific performance of the parties' Lease Option Agreement. Finding no reversible error, the Supreme Court affirmed. View "Riley v. Spiral Butte Development, LLC" on Justia Law

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Utah resident Elham Neilsen wanted to purchase a residence close to the city of Tyler in Smith County, Texas. He contacted Plaintiff-Appellant Holli Telford because he had heard that she knew how to acquire properties through tax or other distress sales and had contacts for obtaining financing for prospective buyers. Mr. Neilsen entered into an agreement with Plaintiff that she would bid on the property and sell it to him after she had obtained the warranty deed. Plaintiff submitted a bid, but did not obtain title to the property because, according to her, it was wrongfully redeemed by the prior owners after she had spent money improving it. She sought specific performance of the alleged contract with Smith County, Texas, or damages for breach of the alleged contract. Defendants moved to dismiss this case for lack of personal jurisdiction. The district court granted the motion and dismissed the case with prejudice as to them and without prejudice as to the other defendants. The Supreme Court affirmed the dismissal for lack of jurisdiction, but vacated the dismissal with prejudice and remanded the for entry of a judgment dismissing the complaint without prejudice. View "Telford v. Smith County" on Justia Law

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Appellant Intermountain Real Properties, LLC, appealed a district court's grant of summary judgment to Respondent Draw, LLC. Intermountain initially brought a cause of action, as an assignee of a materialmen's lien, against Draw and other defendants to recover payment on work paving a private drive a property development project. The district court granted summary judgment to Draw on the grounds that Intermountain failed to raise a material issue of fact as to Draw's liability on the contract. Specifically, the district court found that Intermountain's lien as it applied to Draw's property was void, and that Draw should have quiet title to its property. Finding no error or abuse of discretion, the Supreme Court affirmed the district court. View "Intermountain Real Properties, LLC v. Draw, LLC" on Justia Law

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Appellants Richard Hehr and Greystone Villages, LLC (collectively "Greystone") appealed a district court's grant of summary judgment in favor of Respondent City of McCall. Greystone's claims arose out of its development agreement with McCall. Greystone alleged it deeded nine lots to McCall in lieu of paying the required community housing fee, which was later declared unconstitutional in a separate proceeding. Greystone brought inverse condemnation claims against McCall alleging that the conveyance of the lots and the improvements made to those lots constituted an illegal taking under both the Idaho Constitution and the United States Constitution. McCall moved for summary judgment, which the district court granted. Finding no error in the district court's decision, the Supreme Court affirmed. View "Hehr v. City of McCall" on Justia Law

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The issue on appeal to the Supreme Court in this case stemmed from district court decisions regarding an uninsured motorist claim between Plaintiffs-Appellants Sam and Deva Ferrell and Defendant-Respondent United Financial Casualty Company (United Financial, d.b.a. Progressive Insurance Company). The parties underwent arbitration, and the Ferrells subsequently filed a petition that sought confirmation of the arbitration award and an award of costs and attorney fees. The district court ordered confirmation of the arbitration award and interest based upon an agreement of the parties. On the issue of attorney fees, the district court found that arbitration began five months prior to the amendment of I.C. 41-1839 which explicitly allowed attorney fees in arbitration, and therefore the statute as it existed did not provide for attorney fees in this case. The Supreme Court reversed in part and remanded the case back to the district court. View "Ferrell v. United Financial Casualty Co." on Justia Law

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The Supreme Court affirmed the district court’s order granting a new trial on plaintiffs' claim for breach of the implied warranty of habitability and its denial of defendants' request for attorney fees at trial. Plaintiffs Shawn and Shellee Goodspeed purchased a home from Robert and Jorja Shippen via warranty deed. After the basement of the home flooded, the Goodspeeds filed suit against the Shippens, alleging breach of the implied warranty of habitability. The district court denied a request for a jury instruction on the requirements for disclaiming the implied warranty of habitability and the case went to trial. The jury returned a verdict in favor of the Shippens, and the Goodspeeds moved for judgment notwithstanding the verdict or, alternatively, for a new trial, arguing the disclaimer of the implied warranty of habitability in the purchase and sale agreement was ineffective because it was not conspicuous. The district court granted a new trial after determining it had excluded the disclaimer instruction based upon its incorrect belief that the Goodspeeds had actual knowledge of the disclaimer. View "Goodspeed v. Shippen" on Justia Law

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William Shapley appealed the district court’s dismissal of his breach of contract and negligence claims against Centurion Life Insurance Company and Wells Fargo Financial. Shapley and his wife applied for credit life insurance with Centurion on the same day they closed on a real estate loan with Wells Fargo. The Shapleys were provided with a notice of insurance underwriting practices. The application papers stated that the Shapleys would receive insurance coverage only if Centurion approved their application. Centurion never had a chance to have a phone interview with Mrs. Shapley (a requirement for the policy). The day after the Shapleys closed on their loan, Mrs. Shapley suffered a brain hemorrhage from which she died four days later. Mr. Shapley contacted Centurion the same day to claim benefits in connection with Mrs. Shapley’s passing. Centurion denied the claim because it never issued an insurance policy on Mrs. Shapley. Because the interview never took place, Centurion issued insurance solely to Mr. Shapley. Mr. Shapley argued on appeal that the district court's dismissal was in error. Upon review, the Supreme Court affirmed the district court’s decisions, finding that while the district court incorrectly concluded that there must be a contract for estoppel to apply, the denial of Mr. Shapley’s motion to amend was appropriate because his estoppel claim was futile. View "Shapley v. Centurion Life Ins Co" on Justia Law

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Appellants Tommy and Erin Dorsey contended that they were conveyed beachfront property when they bought "Lot 1." Respondents, who own the other lots in the subdivision, contended that the property was dedicated to the use and benefit of the entire subdivision. The district court agreed with Respondents. Plaintiffs appealed. But after a review of the trial court record, the Supreme Court affirmed the district court. View "Ross v. Dorsey" on Justia Law

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The Bank of Commerce filed suit to foreclose on two mortgages against properties under development by Jefferson Enterprises, LLC. Jefferson raised a variety of counterclaims. Ultimately the district court granted summary judgment in favor of the Bank, ordering the foreclosures. Jefferson raised numerous issues on appeal, but finding no error or abuse of the district court's discretion, the Supreme Court affirmed. View "Bank of Commerce v. Jefferson Ent" on Justia Law

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Richard and Lisa Keane and the companies they managed, and Bald, Fat & Ugly, LLC (BFU) had a disagreement arising from a development deal involving the Houston Professional Plaza. They went to mediation, but the parties had a disagreement regarding the terms of the mediated agreement. They then turned to arbitration. The arbitrator granted two awards in favor of BFU. The award did not specify any date by which the Keanes were to pay the money, nor did the award include interest. The district court confirmed the arbitration awards, and issued a writ of execution. The sheriff returned the writ not satisfied. BFU then obtained an order for a debtor's examination. A partial satisfaction of judgment was made, but the Keanes did not direct how the payment made was to be applied to the two arbitration awards. BFU applied the partial satisfaction to one of the awards, and filed a motion to have the Keanes held in contempt for failing to pay the second. The Keanes challenged the contempt action. The Supreme Court, after its review of the matter, found that because the order confirming the arbitration award did not require the Keanes to do anything and because contempt cannot be used to enforce payment of the debt in this case, the Court reversed the judgment of the district court finding them in contempt and the order later entered awarding the respondent attorney fees and court costs. View "Bald, Fat & Ugly v. Keane" on Justia Law