Justia Business Law Opinion Summaries

Wanooka Farms, Inc. was a closely held family farming corporation. During the course of negotiations over the a split of the corporation (to avoid certain tax consequences), two appraisals were done. The appeal before the Supreme Court in this matter was an appeal of a bench trial in which the district court found that the fair value of shares in Wanooka equaled $3,344 per share. Finding no reversible error in the trial court's finding, the Supreme Court affirmed. View "Wagner v. Wagner" on Justia Law

McAdams, LLC sought to hold Peter Cintorino and Tim and Kimberly Resler liable on their personal guarantees of a promissory note made by Fawnwood, LLC, in favor of JBM, LLC. The district court granted summary judgment in favor of Cintorino and the Reslers holding that McAdams, LLC was prohibited from filing a collection action in Idaho because its assignor, JBM Company, LLC, was prohibited from filing suit in Idaho under either Idaho’s Assumed Business Name Act (“IABNA”) or Idaho’s Uniform Limited Liability Company Act (“IULLCA”). JBM, LLC, McAdams, and McAdams, LLC collectively appealed the district court’s dismissal of the claims against Cintorino. The McAdams group’s opening brief focused exclusively on whether the district court erred in concluding that McAdams, LLC was prohibited from filing suit in Idaho. Therefore, the Supreme Court limited its analysis to that issue, and reversed: McAdams, LLC was entitled to pursue its claim against Cintorino to enforce the promissory note and his personal guarantee of the same. View "McAdams, LLC v. Cintorino" on Justia Law

In 2013, plaintiff Fagen, Inc. filed this lawsuit seeking to recover damages for work it had done in the construction of a wind park located in Bingham County. It named as defendants Lava Beds Wind Park, LLC; Exergy Development Group of Idaho, LLC; and XRG Development Partners, LLC (collectively “Defendants”); and Tabor Wind Farms, LLC. The district court entered an order dismissing Plaintiff’s claims against Tabor pursuant to a stipulation of those parties. Plaintiff then filed an amended complaint against the remaining defendants, alleging causes of action to foreclose a mechanic’s lien, to recover damages for breach of contract, and to recover damages in quantum meruit. Plaintiff moved for summary judgment seeking a judgment against Lava Beds and Exergy Development for breach of contract. In opposition to that motion, defendants filed two affidavits, which merely contained vague and conclusory allegations. The district court denied defendants’ motion to continue the hearing on summary judgment. During the hearing, Plaintiff stated that it withdrew its claim to foreclose a mechanic’s lien and its claims against XRG, which resolved these Defendants’ motion for summary judgment. Defense counsel admitted that Lava Beds and Exergy Development had breached their contract with Plaintiff, but he argued that one of the affidavits showed a need for further discovery at least as to the issue of damages. The court took the motion for summary judgment under advisement, then granted Plaintiff’s motion. It held that the conclusory affidavits submitted by Defendants were insufficient to create a genuine issue of material fact precluding summary judgment. On the same date, the court entered an order granting Defendants’ motion for summary judgment. Lava Beds and Exergy Development's motion for reconsideration was denied, and they appealed. Finding no reversible error, the Supreme Court affirmed the trial court's decision. View "Fagen v. Lava Beds Wind Park" on Justia Law

This case was an appeal of an amended judgment awarding damages for breach of contract, court costs, and attorney fees in connection with a contract to construct five wind farms. Because the parties had stipulated to that portion of the judgment regarding the damages for breach of contract, those issues were not subject to appellate review. Because the only challenge to the award of attorney fees was raised for the first time on appeal, the Supreme Court did not consider it. The Court therefore affirmed the amended judgment and the award of costs and attorney fees on appeal. View "Fagen v. Rogerson Flats Wind Park" on Justia Law

Appellant Charles DeGroot and DeGroot Farms, LLC appealed the district court's grant of summary judgment on its claims against Standley Trenching, Inc. d/b/a Standley & Co., relating to the construction and installation of a manure handling system at the DeGroot dairy. Beltman Construction, Inc., d/b/a Beltman Weldling and Construction, was the general contractor for the project. Beltman subcontracted with Standley for the installation of the manure handling equipment. J. Houle & Fils, Inc. manufactured the manure handling equipment installed at the DeGroot dairy. Because of maintenance problems with the manure handling equipment, DeGroot initiated litigation against Standley and Houle. DeGroot then initiated litigation against Beltman. Beltman brought a third party complaint against Standley. Standley counterclaimed against DeGroot for amounts due for parts and services. The district court granted Standley summary judgment on its counterclaim, granted Standley summary judgment on DeGroot's claims, and granted Standley summary judgment on Beltman's third party complaint. DeGroot appealed. Finding no reversible error, the Supreme Court affirmed. View "DeGroot v. Standley Trenching, Inc." on Justia Law

This appeal stemmed from the failure of Tamarack Resort, which was owned, developed, and operated by Tamarack Resort, LLC. The Resort was slated as a year-round community, complete with cross-country and downhill skiing, a championship golf course, hotel and conference facilities, retail shopping, restaurants, and lounges. Tamarack planned to offer a panoply of real estate options, including custom homes, condominiums, townhomes, chalets, and cottages. Construction at the Resort began in 2003. Housing units were built and sold, hotel facilities were developed, and by 2006, the ski areas, golf course, retail shops, and restaurants were up and running. In 2004, Tamarack hired Teufel Nursery as its landscape developer. Teufel provided landscaping services at the Resort from 2004 until early 2008. This appeal centered the priority of liens as between Teufel Nursery's mechanics lien and Credit Suisse's mortgages. The district court held that while Teufel had a valid and enforceable lien, it was inferior to Credit Suisse’s mortgages. On appeal, Teufel argues that such holding was in error and that the district court also erred in calculating Teufel's lien amount, interest, and attorney fees. Finding no error, the Supreme Court affirmed. View "Credit Suisse v. Teufel Nursery" on Justia Law

Appellant Edged in Stone, Inc. (EIS) sought damages for breach of contract, breach of warranty, breach of implied covenant of good faith and fair dealing, negligence and unjust enrichment when a skid loader it purchased experienced mechanical problems. The district court dismissed all of EIS's claims except breach of contract and unjust enrichment. Later, the district court entered a judgment in favor of Northwest Power Systems, LLC (NWPS), dismissing EIS's remaining claims and awarded NWPS attorney's fees and costs. EIS appealed to the Supreme Court, arguing arguing that the district court erred in granting summary judgment to NWPS. After careful consideration of the trial court record, the Supreme Court found no reversible error and affirmed that court's grant of summary judgment. View "Edged In Stone v. NW Power Systems" on Justia Law

Medical Recovery Services, LLC (MRS), a licensed collection agency, appeals from the district court’s order affirming default judgments entered by the magistrate court. Each Respondent’s account indebtedness was assigned to MRS. MRS filed suit to recover payment from each Respondent and also sought $350 in attorney fees from each, based on a contractual provision. None of the Respondents answered the complaints filed by MRS, so MRS filed for default judgments to be entered in each case. The magistrate court entered default judgments as to all Respondents but granted attorney fees in amounts less than the $350 that MRS was requesting under the contracts. MRS asserted that the magistrate erred in awarding attorney fees in the amount of the principal owed by the Respondents for medical services, as opposed to $350, which was the minimum amount that each Respondent contracted to pay. Finding no reversible error, the Supreme Court affirmed the district court. View "Medical Recovery Services v. Strawn" on Justia Law

Appellant Farmers National Bank (FNB) appealed the district court's grant of declaratory judgment in favor of Green River Dairy, LLC, and four commodities dealers: Ernest Carter, Lewis Becker, Jack McCall, and Hull Farms (Sellers). FNB argued the district court misinterpreted I.C. 45-1802 (a statutory lien provision) and as a result, erred in granting Sellers a priority lien on collateral securing a loan previously made by FNB. Upon review, the Supreme Court agreed with FNB about the misinterpretation and vacated the district court's grant of declaratory judgment in favor of the Sellers. View "Farmers Nat'l Bank v. Green River Dairy" on Justia Law

American West Enterprises appealed a district court's grant of summary judgement to Case New Holland, Inc. (CNH) in its effort to recover the cost of a remanufactured tractor engine CNH sold to a local seller that American West purchased. The district court dismissed American West's claim of implied warranty because there was no privity between American West and CNH. The district court also rejected American West's claims that it was an intended third party beneficiary of a contract between CNH and Pioneer and that Pioneer was an agent of CNH. American West appeals. The district court denied CNH's request for attorney fees and costs below. CNH cross-appealed. Finding no error, the Supreme Court affirmed all but the denial of attorney fees. The case was remanded to the district court for finding costs and fees in favor of CNH. View "American West Ent. v. CNH, LLC." on Justia Law