Justia Business Law Opinion Summaries

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

This appeal involves the transfer of the experience rating account for unemployment tax purposes from one employer to another pursuant to Idaho Code section 72-1351A(1)(a). After an investigation, the Department of Labor determined that the experience rating account of Diamond Z Trailer, Inc. (Diamond Z), which ceased operating in the spring of 2010, was transferred to Rule Steel Tanks, Inc. (Rule Steel), which hired the majority of the employees who were laid off by Diamond Z and which commenced marketing and manufacturing the same product that was manufactured by Diamond Z. Rule Steel appealed that determination. Finding no reversible error, the Supreme Court affirmed. View "Rule Steel Tanks, Inc. v. Dept of Labor" on Justia Law

BV Beverage Company, LLC appealed the dismissal of its petition regarding the expiration of its liquor license. Idaho Alcohol Beverage Control (ABC) contended that BV Beverage's interest in its license expired by operation of law when BV Beverage's lessee failed to timely renew. BV Beverage argued that the agency’s procedures deprived it of adequate procedural due process. The district court dismissed BV Beverage's petition because there was no agency action to review; even if there was agency action, the action did not violate procedural due process because BV Beverage had actual knowledge of the expiration date of the liquor license. Finding no reversible error, the Supreme Court affirmed. View "BV Beverage Company v. Idaho Alcohol Beverage Control." on Justia Law

Monsanto, through a wholly owned subsidiary, owns a quartzite mine near Soda Springs. Monsanto and Washington Group International, Inc. (WGI) contracted with each other for WGI to operate the mine. This agreement was memorialized in an agreement set to expire at the end of 2002. A by-product of WGI's operations was silica sand. Silicon International Ore, LLC (SIO) contacted Monsanto about acquiring the sand. SIO presented Monsanto with a proposed contract, but that contract was never executed. However, Monsanto and WGI executed an Addendum to the agreement that authorized WGI to construct and operate a processing facility for silica sand at the quartzite mine and to pay Monsanto royalties for silica that was sold by WGI to a third party. SIO and WGI executed a Master Agreement, under which WGI agreed to provide silica sand to SIO; SIO agreed to pay for the construction of the processing facility for the silica sand; SIO agreed to pay WGI to dry, screen, and bag the silica sand; SIO agreed to pay WGI an additional amount for processed sand; and WGI agreed to load the bagged silica sand onto SIO trucks. Shortly before the First Quarzite Agreement was set to expire, Monsanto and WGI executed a second Quarzite Agreement and addendum. The Second Addendum was almost identical to the First, but provided that WGI would pay Monsanto different amounts for sand based on several considerations and that the "[t]itle to the silica sand sold by SIO shall pass directly from [Monsanto] to SIO upon processing . . . subject to payment." WGI notified SIO that it would no longer be providing SIO with silica sand after the end of the year. After discussions with SIO, SIO was permitted to continue processing and bagging sand through April 29, 2008. SIO dismantled its operations in the quarry and removed its building and equipment. The following year, SIO sued Monsanto and WGI for damages for violating and interfering with an alleged verbal agreement to continue processing silica sand. SIO alleged that it and Monsanto entered into a verbal agreement separate and apart from the Master Agreement for the sale of silica sand. SIO asserted breach of the alleged verbal agreement, breach of the implied covenant of good faith and fair dealing, equitable estoppel, and quasi-estoppel. Monsanto denied SIO's claims and asserted the statute of frauds as an affirmative defense. Against WGI, SIO claimed that WGI breached the covenant of good faith and fair dealing implied into the Master Agreement, and SIO alleged that WGI tortiously interfered with the alleged verbal agreement between SIO and Monsanto. Monsanto and WGI moved to dismiss, which were ultimately granted by the trial court. Finding no reversible error, the Supreme Court affirmed. View "Silicon Int'l v. Monsanto Co." on Justia Law

Black Rock Development, Inc. developed a planned unit development consisting of residential homes and a golf course on the shore of Lake Coeur d'Alene. Black Rock Development recorded covenants, conditions, and restrictions (CC&R's) applicable to the development. The CC&R's created the position of "Declarant," named Black Rock Development as the Declarant, stated the rights of the Declarant, defined the time period that the Declarant would be entitled to exercise those rights, and specified the qualifications for a "Successor Declarant." The golf course in the development was developed and owned by The Club at Black Rock, LLC. The Club conveyed its real property to the Washington Trust Bank in lieu of foreclosure. Black Rock Development also assigned to the Bank all of its rights and interests as the Declarant under the CC&R's. The Bank then assigned the real property and the Declarant rights to West Sprague Avenue Holdings, LLC. West Sprague deeded the real property and assigned the Declarant rights to an entity named The Golf Club at Black Rock, LLC, which was a different entity than The Club. Black Rock Development assigned to The Golf Club any Declarant rights that Black Rock Development may still have retained due to any procedural or substantive defect in the prior assignments. Plaintiffs, who are the owners of at least one lot in Black Rock and are members of the Black Rock Homeowner's Association, Inc., filed this action against The Golf Club seeking a declaratory judgment that it was not qualified to be a Successor Declarant and therefore could not exercise Declarant rights. Both sides moved for summary judgment on the issue of whether The Golf Club satisfied the requirements of being a Successor Declarant under the CC&R's. The district court held that it did. It therefore dismissed the complaint and awarded court costs, including attorney fees, against Plaintiffs. Plaintiffs then appealed. Upon review, the Supreme Court concluded The Golf Club did not qualify as a Successor Declarant; it did not take title to Property for the purpose of sale and development. Because The Golf Club did not qualify as a Successor Declarant, it could not exercise the rights or powers of a Declarant. Therefore, the Supreme Court reversed the district court's judgment, including its award of costs and attorney fees to The Golf Club. View "Sky Canyon Properties, LLC v. The Golf Club at Black Rock, LLC" on Justia Law