The Supreme Court affirmed the judgment of the district court ruling in favor of Plaintiff on his claim that Defendants failed to pay him for work he performed on their residence, holding that there was no merit to Defendants’ assignments of error on appeal. Specifically, the Court held (1) the district court did not err in finding that Plaintiff was entitled to recover under the theory of unjust enrichment when a contract existed between the parties and Plaintiff had a statutory remedy of foreclosure on his construction lien; (2) there was evidence to support the unjust enrichment recovery; and (3) the district court did not err in denying Defendants’ motion to transfer venue. View "Bloedorn Lumber Co. v. Nielson" on Justia Law

The Supreme Court held that Ariz. Rev. Stat. 45-108 does not require the Arizona Department of Water Resources (ADWR) to consider unquantified federal reserved water rights when it determines whether a developer has an adequate water supply for purposes of the statute. This case stemmed from the ADWR’s 2013 adequate water supply approving Pueblo Del Sol Water Company’s application to supply water to a proposed development in Cochise County. The superior court vacated ADWR’s decision, concluding that the agency erred in determining that Pueblo’s water supply was “legally available” because ADWR was required to consider potential and existing legal claims that might affect the availability of the water supply, including the Bureau of Land Management’s unquantified federal water right. The Supreme Court vacated the superior court’s decision and affirmed ADWR’s approval of Pueblo’s application, holding that ADWR is not required to consider unquantified federal reserved water rights under its physical availability or legal availability analysis. View "Silver v. Pueblo Del Sol Water Co" on Justia Law

The Supreme Court held that the circuit court did not err when it found that an automobile graveyard was a lawful nonconforming use because the use began prior to the enactment of the county’s zoning ordinances and had not been discontinued. The Acting Zoning Administrator of Price William County determined that the use of one parcel as an automobile graveyard was not a lawful nonconforming use. The Prince William County Board of Zoning Appeals (BZA) upheld the Administrator’s denial of the non-conforming use verification for the parcel. The circuit court reversed the BZA’s decision, finding that the use of the parcel as an automobile salvage business operation predated the zoning ordinances of Prince William County and that the pre-existing lawful nonconforming use was never abandoned or discontinued. The Supreme Court affirmed, holding that the lawful nonconforming use of the parcel as an automobile graveyard was not terminated by discontinuance of the use. View "Prince William Board of County Supervisors v. Archie" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant’s complaint for writs of prohibition and procedendo against Darke County Court of Common Pleas Judge Jonathan P. Hein, holding that Appellant was not entitled to either writ. In his complaint, Appellant asked for a writ of procedendo directing Judge Hein to vacate an order confirming the sale of property at a foreclosure sale. The court of appeals dismissed the procedendo claim as seeking the wrong form of relief. The Supreme Court affirmed, holding that procedendo was inappropriate because Appellant sought to undo a court order rather than to compel the judge to issue a ruling. As to the request for a writ of prohibition, the Supreme Court held that even if Appellant had sought to undo the confirmation order through a writ of prohibition, that request would be moot because the court of appeals had already vacated the confirmation order. Lastly, Appellant had an adequate remedy at law by way of appeal. View "State ex rel. Sponaugle v. Hein" on Justia Law

The Supreme Court affirmed the district court’s finding that Mark Haik lacked standing to challenge a change application that sought to add acreage to accommodate a private water system and the court’s denial of Haik’s motion to amend his petition, holding that the district court did not err or abuse its discretion. Haik, who wanted water for his undeveloped canyon lots, challenged a change application that would add acreage to accommodate a water system that would serve ten homes in Little Cottonwood Canyon. After the State Engineer approved the application, Haik filed petition seeking a trial de novo of the State Engineer’s order. Haik also moved for leave to amend. The district court dismissed Haik’s petition, concluding that it lacked jurisdiction because Haik lacked standing where the change application did not directly impact Haik’s property or his water rights. The court also denied Haik’s motion to amend. The Supreme Court affirmed, holding (1) Haik lacked standing because he was not aggrieved by an order of the State Engineer; and (2) Haik’s motion to amend was properly denied because Haik did not attach a proposed amended petition and any amendment would be futile. View "Haik v. Jones" on Justia Law

At issue before the South Carolina Supreme court was the propriety of the grant of partial summary judgment in a condemnation action. The court of appeals affirmed the circuit court's ruling that the landowner, David Powell, was not entitled to compensation for any diminution in value of his remaining property due to the rerouting of a major highway which previously was easily accessible from his property. South Carolina Department of Transportation (SCDOT) condemned a portion of Powell's 2.5 acre property in connection with its upgrade to U.S. Highway 17 Bypass (the Bypass) near the Backgate area of Myrtle Beach. His unimproved parcel, located on the corner of Emory Road and Old Socastee Highway, was originally separated from the Bypass by a power line easement and a frontage road; access to that major thoroughfare was via Emory Road, which intersected with the Bypass. Because Powell's property was zoned "highly commercial," his easy access to the Bypass significantly enhanced its value. The Supreme Court reversed and remanded for a new trial. The record contained evidence the condemnation of Powell's property, the closure of the intersection, and the curving of the frontage road over the condemned parcel were all integrally connected components of the project, creating a material issue of fact as to which of these acts was a direct and proximate cause of the taking, thus rendering summary judgment improper. Employing the clear language of our just compensation statute, the Court held that a jury should have been permitted to hear evidence on the diminution in value to the remaining property. View "SCDOT v. Powell" on Justia Law

The Supreme Court affirmed the district court’s denial of Appellant’s petition for a writ of mandate requesting that the court compel the Flathead County Treasurer to issue him a tax deed or appear and show cause why it should not do so, holding that a writ of mandate was inappropriate because Appellant had an adequate remedy at law. Flathead County purchased a tax lien on certain property after the property taxes became delinquent. When the owner and occupant did not redeem the property within the redemption period the County assigned the tax lien to a limited liability company (LLC), of which Appellant was a member. The Flathead County Treasurer subsequently allowed the owner to redeem the property. When the County Treasurer declined to issue a tax deed to the LLC, Appellant filed his petition for a writ of mandate arguing that the County Treasurer had a statutory duty to issue the tax deed. The district court denied the petition. The Supreme Court affirmed, holding that the district court correctly determined that Appellant was not entitled to a writ of mandate because a quiet title action provided Appellant with an adequate remedy in the ordinary course of law. View "O'Brien v. Krantz" on Justia Law

The Guild appealed the district court's order of forfeiture to the United States of seven ancient Cypriot coins and eight ancient Chinese coins, which were imported into this country by the Guild. The Fourth Circuit affirmed and held that the district court properly determined that the government had satisfied its burden under 19 U.S.C. 2610 with respect to the coins at issue in these forfeiture proceedings. Therefore, the burden shifted to the Guild to prove that the coins were somehow not subject to being forfeited to the United States. The court held that the district court did not abuse its discretion by requiring the Guild to present expert evidence that was particularized to the fifteen defendant ancient coins; the district court did not improperly discount expert testimony regarding the circulation patterns of ancient Cypriot and Chinese coins; and the district court did not improperly reject and discount another expert's particularized evidence about the ancient Cypriot coins. The court rejected the Guild's contention that the Customs regulation promulgated and codified at 19 C.F.R. 12.104 irreconcilably conflicted with 19 U.S.C. 2601(2), and the Guild's claims of discovery errors. Finally, the district court's conclusion in the Strike Opinion and Order did not violate the Guild's due process rights. View "United States v. Ancient Coin Collectors Guild" on Justia Law

Merrill Chance, a landowner in Osage County, Oklahoma, sued the government to void a lease and various permits that allow Great Southwestern Exploration, Inc. (GSE) to drill for oil and gas beneath his property. He also sought damages from GSE for trespassing on his property. The district court ruled that under 28 U.S.C. 2401(a), Chance’s claims against the government were untimely. Thus, the district court concluded it lacked subject-matter jurisdiction to hear Chance’s claims and dismissed them. It also dismissed Chance’s claims against GSE. While the Tenth Circuit agreed Chance’s claims against the government were untimely, it heeded a warning by the Supreme Court to beware of “profligate use of the term ‘jurisdiction.’” In light of this, the Tenth Circuit found the district court wrongly concluded it lacked subject-matter jurisdiction over Chance’s claims against the government; the claims should have been dismissed for failing to state a claim. The Court affirmed the district court’s judgment declining to exercise supplemental jurisdiction over Chance’s claims against GSE. View "Chance v. Zinke" on Justia Law

The Ninth Circuit affirmed the district court's grant of summary judgment for King County in an action to quiet title to a rail corridor that the Surface Transportation Board had railbanked under the Trails Act. As a preliminary matter, the panel held that it had jurisdiction under 28 U.S.C. 1331 because plaintiffs' state law claim necessarily turned on some construction of federal law that was actually disputed, substantial, and capable of resolution in federal court without disrupting any congressionally approved federal-state balance. The panel also held that plaintiffs lacked Article III and statutory standing to challenge King County's interest in the Corridor because they have no property interests in the Corridor; King County owns the portion of the Corridor adjacent to the Hornish Property in fee; the Trails Act preserved the railroad easement and created a new easement for trail use, both of which were conveyed to King County; and the centerline presumption did not apply in this case. The panel also held that the district court properly granted summary judgment to and quieted title in King County where King County possessed the railroad easement and recreational easement, and the easement's width adjacent to the Non-Hornish Plaintiffs' properties was 100 feet. Finally, the panel denied plaintiffs' motion to supplement the record. View "Hornish v. King County" on Justia Law