Justia Contracts Opinion Summaries

Plaintiff Advanced Medical Diagnostics entered into a contract for services with Defendant Imaging Center of Idaho, LLC. Defendant stopped making payments and Plaintiff sued for damages for breach of contract. The matter was tried to a jury and the jury returned a special verdict finding that Plaintiff had proved its claim but was not entitled to damages because Defendant proved its affirmative defense. The trial court determined that Defendant was the prevailing party, and was awarded costs and attorney fees. Plaintiff appealed that award to the Supreme Court. After its review, the Supreme Court found no error in the trial court's decision and affirmed. View "Adv Medical Diagnostics v. Imaging Center of Idaho" on Justia Law

In 2006, Trinity Investments, LLC executed and delivered to Idaho Trust National Bank (Lender) a promissory note in the principal amount of $5,625,000.00 to develop a parcel of real property and construct townhouses upon it. Trinity was to make monthly payments of accrued interest and to pay the outstanding principal, plus accrued interest, on December 8, 2007. Borrower and Lender later entered into several agreements to change the terms of the note to reduce the principal and extend the date of maturity. The note was secured by a construction deed of trust on the real property being developed. Michael R. Christian (Guarantor) executed the promissory note as a member of Borrower, and he also signed a guaranty of Borrower's indebtedness to Lender. Trinity ultimately defaulted on the loan, and Lender brought a lawsuit against it to recover on the promissory note. During that proceeding, they stipulated to have a receiver appointed to market and sell the real property that was the collateral for the note. The receiver was authorized to sell the townhouse units for 80% of their appraised value without court approval. Guarantor signed the stipulation appointing the receiver as attorney in fact for Trinity. By June 2011, the receiver had sold all of the remaining properties. Those sales did not generate sufficient funds to pay the sums owing on the note. In 2011, the Lender brought this action to recover from Guarantor the balance owing by Borrower on the note. The district court granted Lender's motion for summary judgment and denied Trinity's motion for reconsideration. The Guarantor timely appealed. Upon review, the Supreme Court affirmed, finding that there under the definition written in the parties' contract, '[i]ndebtedness' include[d], without limitation, loans, advances, debts, . . . and liabilities of Borrower . . . whether: . . . barred or unenforceable against Borrower for any reason whatsoever." View "Idaho Trust Bank v. Christian" on Justia Law

This case arose from the water loss claims Appellant Roger Daniel Rizzo made under Respondent State Farm Fire and Casualty Company's homeowners insurance policy. All of Appellant's claims were for water damage to his home's basement. The district court granted summary judgment in favor of the insurance company, effectively dismissing all of Appellant's causes of action because his homeowner's policy did not cover his water damage claims. Appellant also appealed the district court's denial of his motion to amend his complaint to include various new causes of action and the district court's grant of State Farm's motion for protective order against certain overbroad discovery requests. Finding no error in the district court's grant of summary judgment in favor of State Farm, the Supreme Court affirmed the district court's decisions. View "Rizzo v. State Farm Insurance" on Justia Law

This was an action brought by the grantor of a deed of trust to stop nonjudicial foreclosure proceedings based upon the contention that MERS, the Mortgage Electronic Registration Systems, which was the named beneficiary as nominee for the lender, could not legally act as the beneficiary. The defendants moved to dismiss this action on the ground that the complaint did not state a claim upon which relief could be granted. The district court agreed and entered judgment in favor of the defendants. Upon review, the Supreme Court affirmed the district court's judgment. View "Edwards v. MERS" on Justia Law

In 2007, Employers Mutual Casualty Company (EMC) brought a declaratory judgment action against the Donnellys and Rimar Construction, Inc. (RMI) to establish that under its policy of insurance with RCI, EMC had no duty or responsibility to pay damages claimed by the Donnellys in litigation between the Donnellys and RCI. The declaratory judgment action was stayed until a verdict was reached in the underlying action. In the underlying action, the Donnellys were awarded damages, costs and attorney fees against RCI. Subsequently the district court entered summary judgment in the declaratory action, finding that there was no insurance coverage for the damages the Donnellys incurred, but that there was coverage for costs and attorney fees. On appeal, EMC argued that the district court erred in its determination that it had a duty to pay attorney fees and costs when there were no damages awarded to the plaintiff subject to the policy coverage. The Donnellys cross appealed, arguing the district court erred in its conclusion that EMC did not have a duty to cover the damages in this case, and that the Donnellys were entitled to attorney fees. Upon review, the Supreme Court affirmed the district court's decision. View "Employers Mutual Casualty Co v. Donnelly" on Justia Law

The issue before the Supreme Court in this case concerned the grant of summary judgment dismissing an action to enforce an oral agreement to guaranty the debt of another on the ground that the agreement was barred by the statute of frauds. Sunshine Secretarial Services subleased office space from Accelerated Paving, Inc., and at times provided it with secretarial services. Accelerated Paving owed Plaintiff-Appellant Mickelsen Construction, Inc. money ($34,980.00) for providing asphalt to an Accelerated jobsite. Mickelsen threatened to file a materialmen’s lien against the real property on which the work was being done, and Accelerated's vice president asked that it not do so because that would delay the receipt of payment for the construction job. The vice president offered to pay the debt with an American Express credit card, but Mickelsen responded that it did not accept American Express credit cards. There was disagreement as to what happened next: Accelerate's vice president said there was not enough credit on the card to fund the payment, but when Accelerated received payment for the project it would pay down the balance so that there was enough credit to pay Mickelsen with the card. Mickelsen agreed not to file the lien if Accelerated could find someone to guaranty the payment by the credit card. Defendant-Respondent Lesa Horrocks of Sunshine agreed to do so and gave Mickelsen a check in the amount owed, drawn on Sunshine's account. Sunshine had a credit card machine that was capable of transacting with several credit cards including American Express credit cards. They told her that American Express had approved the transaction and asked her to use Sunshine credit card machine to run the transaction. It appeared to her that the transaction had been approved by American Express. issued the check. Several days later, Accelerated informed her that American Express had not approved the transaction. Accelerated then filed for bankruptcy. Mickelsen then sued Ms. Horrocks and Sunshine alleging that they had agreed to guaranty the credit card payment and so issued the check. The Defendants filed a motion for summary judgment, arguing that the alleged guaranty was barred by the statute of limitations in Idaho Code section 9-505. In response, Mickelsen argued that the check was a sufficient writing under the statute of frauds and, if not, that the transaction was governed by Idaho Code section 9-506 and therefore exempt from the statute of frauds. The district court held that the check was an insufficient writing and that section 9-506 did not apply because the Defendants did not receive any direct benefit. The court granted the motion for summary judgment and entered a judgment dismissing this action. Mickelsen then appealed. Finding no error with the district court's decision, the Supreme Court affirmed. View "Mickelsen Const v. Horrocks" on Justia Law

In 2008, the legislature enacted legislation to establish the Idaho Education Network (IEN), which was to be a high-bandwidth telecommunications distribution system for distance learning in every public school in the state. Syringa Networks, LLC (Syringa), an Idaho telecommunications company, entered into a “teaming agreement” with ENA Services, LLC (ENA). Pursuant to their agreement, ENA submitted a proposal in response to a request-for-proposals (RFP) with the Department of Administration, although the cover letter stated that both ENA and Syringa were responding jointly to the proposal. Qwest Communications Company, LLC, and Verizon Business Network Services, Inc., also submitted responsive proposals. The proposals were then scored based upon specific criteria; the ENA and Qwest proposals received the highest scores. The Department issued a letter of intent to award contracts to Qwest and ENA. One month later, it issued amendments to the two purchase orders to alter the scope of work that each would perform. Qwest became "the general contractor for all IEN technical network services" (providing the “backbone”) and ENA became "the Service Provider." The effect of these amendments was to make Qwest the exclusive provider of the backbone, which was what Syringa intended to provide as a subcontractor of ENA. Syringa filed this lawsuit against the Department, its director, the chief technology officer, ENA and Qwest. The district court ultimately dismissed Syringa’s lawsuit against all of the Defendants on their respective motions for summary judgment. Syringa then appealed the grants of summary judgment, and the State Defendants cross-appealed the refusal to award them attorney fees. Upon review, the Supreme Court affirmed the judgment dismissing all counts of the complaint except count three seeking to set aside the State's contract with Qwest on the ground that it was awarded in violation of the applicable statutes. Furthermore, the Court reversed Qwest’s award of attorney fees against Syringa. We remand to the trial court the determination of whether any of the State Defendants were entitled to an award of attorney fees against Syringa for proceedings in the district court. The Court awarded costs and attorney fees on appeal to ENA. Because the State Defendants and Syringa both prevailed only in part on appeal, the Court did not award them either costs or attorney fees on appeal. View "Syringa Networks v. Idaho Dept of Admin" on Justia Law

The plaintiffs in this case appealed the grant of summary judgment upholding the validity of a bank's mortgage in real property that the plaintiffs had sold to a mortgagor in exchange for an interest in an investment account that turned out to be a Ponzi scheme. Plaintiffs filed an action against other parties to their transaction including the Bank of Commerce arguing, among other things, that they were entitled to rescind the sale of a portion of their property for lack or failure of consideration and mutual mistake ("They argue[d] that they did not receive any consideration because the . . . interest in their investment account with the Trigon Group turned out to be worthless. Mr. Harris testified that he 'assumed that was real money, which it later proved out not to be.'"). Finding no error in the district court's judgment, the Supreme Court affirmed the lower court. View "Harris v. Bank of Commerce" on Justia Law

The issue before the Supreme Court on appeal in this case related to attorney fees incurred in litigation arising from a construction contract for a custom cabin in Island Park, Idaho. There were two issues: (1) whether the district court erred in holding that the Maglebys were entitled to recover only $2,500 from defaulting parties by operation of I.R.C.P. 54(e)(4); and (2) whether the district court erred in its decision regarding the Maglebys' entitlement to post-judgment attorney fees. Upon review, the Supreme Court concluded that I.R.C.P. 54(e)(4) did not limit the Maglebys' fees to the $2,500 pled in their complaint even though defendants did not contest them. The Court vacated the judgments of the district court as they related to attorney fees awards in light of I.C. sec. 12-120(5) and "ITP" and "Jenks." The case was remanded for further proceedings. View "Magleby v. Garn" on Justia Law

Appellant Altrua HealthShare appealed the district court's decision affirming the Idaho Department of Insurance's (Department) determination that Altrua transacted insurance without a certificate of authority. Altrua argued that both the Department and the Ada County district court erred in finding that Altrua was an insurer because Altrua never assumed the risk of paying its members' medical bills. The Department found, and the district court affirmed, that when members make their predetermined monthly payments into the escrow account Altrua operates, the risk of payment shifts from the individual members to the escrow account, and in turn to Altrua. Altrua also contended that the Department's determination that it is an insurer despite the disclaimers in its membership contract to the contrary is an unconstitutional interference with Altrua's right to contract. Upon review, the Supreme Court found that the Department's conclusion that Altrua's membership contract was an insurance contract was clearly erroneous, and reversed the findings. The case was remanded for further proceedings. View "Altrua Healthshare v. Deal" on Justia Law