Justia Contracts Opinion Summaries

The defendant was charged with felony possession of a controlled substance and two related misdemeanors. He and the prosecution entered into a plea agreement under which he would plead guilty to the felony, the misdemeanors would be dismissed, and he would receive a suspended sentence with probation, provided he complied with certain conditions. The agreement included a clause stating it would be “null and void” if the defendant failed to appear for his presentence appointment or sentencing without good cause. After entering his guilty plea, the defendant failed to appear for both the presentence appointment and sentencing, leading to his arrest on a bench warrant.Following these events, the District Court of the Second Judicial District, Nez Perce County, determined that the “null and void” clause released the State and the court from their obligations under the plea agreement, but held that the defendant remained bound by his guilty plea. The court imposed a sentence inconsistent with the plea agreement and did not allow the defendant to withdraw his plea. The Idaho Court of Appeals affirmed the district court’s judgment.On review, the Supreme Court of the State of Idaho held that the district court erred in its interpretation of the “null and void” clause. The Supreme Court concluded that, under general contract principles, the clause rendered the entire plea agreement unenforceable by either party upon breach, not just by the State. The court further held that, under Idaho Criminal Rule 11(f)(4), once the plea agreement was rendered unenforceable and the court declined to be bound by its terms, the defendant was entitled to an opportunity to withdraw his guilty plea. Because the district court failed to provide this opportunity, the Supreme Court vacated the judgment of conviction and remanded the case for further proceedings. View "State v. McGarvey" on Justia Law

A builder sued a homebuyer in a Utah state district court for failing to pay some charges for his home's construction; the homebuyer counterclaimed, alleging that the construction was defective. Shortly before the Utah state court rendered a judgment, the homebuyer sued the builder in an Idaho state district court, seeking to void the builder's allegedly fraudulent transfer of a ranch and appurtenant water shares in Franklin County, Idaho. The homebuyer also filed and recorded the Utah judgment in Franklin County, creating a lien on all of the builder's currently owned and after-acquired real property located there. The builder reversed the transfer, and therefore the ranch became subject to the lien. However, the homebuyer continued to prosecute the fraudulent-transfer action, and did not request a writ of execution. A few months later, the builder declared bankruptcy. In a settlement agreement, the bankruptcy trustee agreed to lift the automatic stay on the homebuyer's fraudulent-transfer action, and also abandoned the ranch from the bankruptcy estate. The homebuyer's judgment lien was not discharged in the builder's bankruptcy, but apparently all in personam causes of action were discharged. The fraudulent-transfer action was repeatedly delayed, and after five years from the entry of the Utah judgment, the homebuyer's lien expired. The homeowner had never attempted to renew the judgment, and had never requested a writ of execution from the Idaho district court. The builder then moved for summary judgment; the homebuyer filed a cross-motion for summary judgment, arguing that he was entitled to a writ of execution. The Idaho district court granted the builder's motion for summary judgment, denied the homebuyer's motion for summary judgment. Upon review, the Supreme Court concluded that the district court properly granted summary judgment in favor of the builder because no relief could be granted based on the expired lien, and because there was no timely request of a writ of execution for the Utah judgment. View "Grazer v. Jones" on Justia Law