Justia Real Estate & Property Law Opinion Summaries

Articles Posted in Idaho Supreme Court - Civil
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This case involved a property dispute between neighbors Robert and Debra Talburt and Miles and Leanne Millard in Idaho. The Millards sought to establish their rights to a disputed tract of land and two easements, as well as breach of contract damages for maintenance of a shared well. The Talburts countered by constructing a fence within the roadway easement, stating they were relocating the roadway easement, and locking the pump house for the shared well. The Supreme Court of Idaho affirmed the district court's judgement in favor of the Millards on their claims related to the easements and ordered the Talburts to remove the fence and cease efforts to block access to the shared well. The court also found the Talburts' attempt to relocate the roadway easement to be unlawful, invalid, and void. However, the district court found that the Millards had abandoned their breach of contract claim and failed to establish a right to the disputed property. The Supreme Court also affirmed the district court's award of a portion of the Millards' attorney fees and costs to them. View "Millard v. Talburt" on Justia Law

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This case involves a dispute between Melissa Sanchez, a tenant, and Chris and Jennifer Pickering, her landlords, over the terms of a lease agreement for a mobile home owned by the Pickerings. Sanchez believed the agreement was a lease-to-own contract, while the Pickerings asserted it was a lease with a purchase option contract. After the Pickerings initiated an eviction action due to Sanchez's alleged violations of the agreement, Sanchez caused extensive damage to the home.The Pickerings sued Sanchez for waste, claiming she caused $40,000 in damages and sought treble damages. Sanchez counterclaimed, alleging violation of the Idaho Consumer Protection Act (ICPA), breach of contract, unjust enrichment, and retaliatory eviction. The district court found Sanchez liable for damages to the residence and awarded treble damages. It also determined that there was no deception on the Pickerings' part to sustain Sanchez's ICPA claim, the agreement was unenforceable due to a lack of mutual understanding, and that the Pickerings were unjustly enriched by the $10,000 down payment and offset the Pickerings' damages award by this amount. The remaining claims were dismissed.On appeal, the Supreme Court of Idaho affirmed the district court's decision. The court found substantial and competent evidence supporting the district court's decision that the Pickerings did not engage in a deceptive act under the ICPA. The court also rejected Sanchez's contention that the district court's damages award should have been reduced to reflect an insurance payment received by the Pickerings as Sanchez failed to provide an adequate record for review. Finally, the court upheld the district court's unjust enrichment award, finding that Sanchez had not demonstrated an abuse of discretion. The Pickerings were awarded attorney fees for having to respond to the collateral source issue. View "Pickering v. Sanchez" on Justia Law

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This case arises from a water rights dispute in Idaho. The McConnells sought to transfer their water rights to a new point of diversion on Lee Creek. Their upstream neighbor, Whittaker, protested the application, arguing that the new diversion would infringe upon his water rights. The Idaho Department of Water Resources (IDWR) approved the transfer, finding that it would not injure Whittaker's water rights. The IDWR used the historic confluence of two creeks to make this determination, asserting that if the confluence was above the McConnells’ diversion point, then Whittaker’s upstream water right was already subject to the McConnells’ senior water rights and the transfer wouldn't injure Whittaker's rights.On review, the district court disagreed with IDWR’s use of the historic confluence, instead favoring the modern confluence which was downstream of the McConnells' diversion point. This meant that the transfer would injure Whittaker's water rights.The Supreme Court of the State of Idaho reversed the district court's decision. The Supreme Court held that the West Springs Ditch, which altered the natural flow of the creek and created the modern confluence, was an unauthorized diversion of water. Therefore, the historic confluence should be used in the injury analysis, and the approval of the McConnells’ transfer application would not injure Whittaker’s water rights. The case was remanded for further proceedings in accordance with the Supreme Court's decision. View "Whittaker v. Idaho Department of Water Resources" on Justia Law

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The Supreme Court of the State of Idaho held that the Director of the Idaho Department of Water Resources (IDWR) had the authority under Idaho Code section 42-237a.g. to initiate administrative proceedings to curtail the withdrawal of water from any well during any period where water to fill a water right in said well was not available. The proceedings stemmed from a district court decision involving the adjudication of water rights in the Wood River Valley during an unprecedented drought in 2021. The Director of the IDWR initiated an administrative proceeding to determine whether water was available to fill junior groundwater rights in the aquifer beneath the Bellevue Triangle. After a six-day hearing, the Director issued a Final Order that found water was unavailable to fill the junior rights because pumping from the aquifer was affecting the use of senior surface water rights. The South Valley Ground Water District and Galena Ground Water District challenged the Director's authority to initiate proceedings under Idaho Code section 42-237a.g., arguing that the Director did not comply with the prior appropriation doctrine because the Director had not formally designated an area of common groundwater supply, or determined "material injury" had been sustained by senior surface water rights holders. The Court affirmed in part and reversed in part, ruling that the Director had the authority to initiate administrative proceedings under Idaho Code section 42-237a.g. and that the Director did not violate the prior appropriation doctrine. It held that the Director had the discretion to limit or prohibit the withdrawal of groundwater from any well during any period when water was not available to fill a water right in said well, and was not required to establish an area of common groundwater supply before he is allowed to curtail groundwater pumping. The Court also held that the Director's decision to reject the proposed mitigation plan without a hearing was not properly before the Court on appeal. View "South Valley Ground Water v. Idaho Dept of Water Resources" on Justia Law

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In an appeal from a property dispute in Ketchum, Idaho, the Supreme Court of the State of Idaho affirmed the lower court's judgment, in part, and vacated and remanded the case, in part, for further proceedings. The dispute arose when Trustees Glen Miller and Cynthia Anderson attempted to build a home on a lot they purchased in the Rocking Ranch No. 3 subdivision. The Rocking Ranch No. 3 Property Owners’ Association denied their application to construct the home and asserted several counterclaims to recover unpaid homeowners association (HOA) assessments. The district court granted summary judgment to the Association on Miller and Anderson’s claims and dismissed the Association’s counterclaims. On appeal, the Supreme Court of the State of Idaho affirmed the district court's dismissal of the Association’s counterclaims, concluding that the Association failed to establish its breach of contract counterclaim because it had not established two elements of the prima facie case: breach of the contract and damages resulting from the breach. The Supreme Court of the State of Idaho also vacated and remanded the district court's award of attorney fees to the Association for further proceedings, finding that the Association was not entitled to recover attorney fees for the counterclaims on which it did not prevail. View "Miller v. Rocking Ranch No. 3" on Justia Law

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The Supreme Court of the State of Idaho ruled on a dispute between TCR, LLC, a developer, and Teton County. The developer had sought to record a condominium plat for a planned unit development, but the County refused to do so, arguing that the developer had not submitted final site plans, architectural designs, or landscape drawings for review. The developer filed suit, alleging breach of contract and seeking declaratory and injunctive relief to compel the County to record the condominium plat. The district court granted the developer's motion for summary judgment on its declaratory and injunctive relief claim and denied the County's motion for summary judgment on the same claim. The court also denied all motions to reconsider. The Supreme Court of Idaho affirmed the district court's decision in part, reversed in part, and remanded for further proceedings. The court held that the County's refusal to record the condominium plat violated the Idaho Condominium Property Act and that the County did not have a valid reason for its refusal. The court also found that the district court erred in granting summary judgment to the County on the developer's breach of contract claim, concluding that genuine issues of material fact remained. The case was remanded for further proceedings. View "TCR, LLC v. Teton County" on Justia Law

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The Supreme Court of the State of Idaho affirmed the lower court's judgment dismissing a negligence claim filed by GSN Capital, LLC and Dave Zortman against the Shoshone City & Rural Fire District. GSN's sawmill property was destroyed by a wildfire, and they argued that the Fire District was negligent in not calling for additional aid, not deploying fire units to protect their property, and not performing a mitigation and salvage operation to save part of their property. However, the court concluded that the Fire District did not owe GSN a duty in tort for any of the challenged decisions. The court found that the Fire District did not have custody or control over GSN's property and did not owe a duty to protect individual properties within its territory. The court also held that the Fire District did not undertake any firefighting efforts for GSN until after the fire was contained, and thus did not assume a duty to GSN. View "GSN Capital, LLC v. Shoshone City & Rural Fire District" on Justia Law

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In the case before the Supreme Court of the State of Idaho, the plaintiffs, Dallen and Rachel Worthington, filed an expedited unlawful detainer action against the defendant, Carlene Crazy Thunder, for failure to pay rent. Crazy Thunder requested a jury trial, which was denied by the magistrate court. Following a bench trial, the magistrate court ruled that Crazy Thunder had unlawfully detained the Worthingtons’ property and ordered her to vacate the residence. Crazy Thunder appealed to the district court, arguing she had a right to a jury trial under Idaho’s constitution and Idaho Code section 6313. The district court agreed, concluding that section 6-311A conflicted with section 6-313, and that section 6-311A violated Article I, section 7 of the Idaho Constitution. The Worthingtons then appealed to the Supreme Court of Idaho.The Supreme Court of Idaho held that Idaho Code section 6-311A does not violate the Idaho Constitution. The court reasoned that an action for unlawful detainer is an equitable claim, and under Article I, section 7 of the Idaho Constitution, the right to trial by jury only exists for legal claims, not equitable ones. However, the court also ruled that Crazy Thunder was entitled to a jury trial on her legal claims. The court held that in wrongful detainer cases like this one, when issues of fact are presented by the pleadings, those issues must be tried by a jury, unless such a jury is waived. As such, the Supreme Court of Idaho affirmed the district court’s decision, though on different grounds. The court further ruled that Crazy Thunder, as the prevailing party on appeal, was entitled to costs, but neither party was entitled to attorney fees. View "Worthington v. Crazy Thunder" on Justia Law

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In the State of Idaho, Yellowstone Log Homes, LLC ("Yellowstone") owned a rental property in the City of Rigby that was extensively damaged after BorTek Utilities and Construction, LLC bored through a lateral sewer line connected to the rental property. The City of Rigby had failed to mark the service lateral sewer pipe connected to the rental property prior to the excavation. Yellowstone sued the City of Rigby for both negligence per se and common law negligence for failing to mark the service lateral. The district court granted summary judgment in favor of the City of Rigby, determining that Yellowstone did not have standing under the Idaho Underground Facilities Damage Prevention Act, and even if it did, it failed to prove the City breached any duty owed to it.The Supreme Court of Idaho reversed the district court's grant of summary judgment to the City of Rigby. The court found that while the Act does not explicitly provide a private right of action for "end users" like Yellowstone, it does impose a duty on the City to mark underground sewer lines in a public right-of-way, which it did not do. The court also held that whether the City breached this duty by failing to maintain records of the location of service laterals, failing to adequately mark service laterals, or failing to take other precautions to protect customers’ service laterals within the public right of way are questions of fact for a jury to decide. Thus, the court concluded that the City of Rigby owed Yellowstone a duty to act as a reasonable manager of its property under the circumstances. View "Yellowstone Log Homes, LLC v. City of Rigby" on Justia Law

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In this case, the Supreme Court of the State of Idaho was required to interpret aspects of Idaho’s mechanic’s lien statutes. Datum Construction, LLC, was the general contractor for a commercial construction project, and subcontracted part of the work to Elmore Welding and Steel, who rented equipment from RE Investment Co., LLC, dba Pro Rentals & Sales. Elmore Welding and Steel failed to pay Pro Rentals for the equipment rental, resulting in Pro Rentals filing a mechanic's lien. Datum then purchased a bond and petitioned the district court to release the lien. Pro Rentals did not oppose this petition and the district court released the lien. Datum argued that Pro Rentals had failed to begin proceedings to enforce its claim of lien within six months. The district court granted Datum’s motion to release the bond. Pro Rentals appealed this decision.The Supreme Court of the State of Idaho ruled in favor of Pro Rentals, determining that the district court had erred in applying a six-month statute of limitations from the mechanic’s lien statutes to a bond action. The court held that the bond replaced the lien, and the six-month period to enforce a lien was not applicable once the lien was released. The court determined that the appropriate statute of limitations for an action against the bond was two years under Idaho Code section 5-219. Therefore, the court reversed the district court’s decision to release the bond. View "Datum Construction, LLC v. Re Investment Co." on Justia Law