Beus v. Beus
151 Idaho 235
Idaho2011Background
- Dallas and Doug Beus (sons) and Jerry Beus were beneficiaries and lessee under Lynn Beus's testamentary trust; the trust terminated after Widow Beus's death in 2008.
- Jerry had been farming the trust property under multiple leases, including a 2007 lease running to 2014, with rent and improvement compensation provisions.
- Trustee (John C. Souza) later terminated the 2007 lease effective December 31, 2009, asserting power to terminate at year-end.
- Jerry obtained a 2007 loan secured by a mortgage on the trust property; proceeds paid off prior personal debts and included settlement costs and a small amount to Jerry.
- Dallas and Doug sued for fiduciary removal, declaratory judgments on lease termination, and allocation issues, leading to district court rulings that terminated the lease, denied improvements reimbursement, and allocated the 2007 loan to Jerry’s share.
- The district court remanded on the improvements issue and the Idaho Supreme Court affirmed in part, vacated in part, and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Lease termination right at year end | Beus argued the clause is ambiguous, only permitting end-of-year termination if applicable to first year. | Trustee argues contract allows termination at end of each year; district court so held. | Trustee may terminate at end of 2009; reasonable interpretation |
| Compensation for improvements | Jerry is entitled to improvements made after 2007; maintenance records exist. | No documented improvements after 2007; no entitlement under the lease. | Vacate; remand to determine improvements if made during term |
| Obligation for 2007 loan | Debt should be paid from Jerry's share because loan benefited Jerry individually. | Trust will divide sale proceeds after expenses; loan may be charged to trust assets. | Loan obligation allocated to Jerry's share of sale proceeds |
Key Cases Cited
- J.R. Simplot Co. v. Bosen, 144 Idaho 611 (Idaho 2006) (summary judgment standard and inferences from undisputed facts)
- Hedrick v. West One Bank, Idaho, N.A., 123 Idaho 803 (Idaho 1993) (ambiguity and interpretation of wills and trusts; free review of ambiguity)
- Stanley v. Lennox Indus., Inc., 140 Idaho 785 (Idaho 2004) (credibility and summary judgment procedures; when to assess credibility)
- Farmers Nat'l Bank v. Shirey, 126 Idaho 63 (Idaho 1994) (trial court as trier of fact and inference standards in non-jury matters)