Boyne USA, Inc. v. Spanish Peaks Development, LLC, 292 P.3d 432

Boyne USA, Inc. sued SPD, LMH, SPH and others for breach of contract over a 15-acre Lone Peak land transfer and sought specific performance.
A complex web of transfers/assignments connected Peak Agreement, Southfork Agreement, SPH, SPD, LMH and SPH’s purchase from Boyne, with Dolan and Blixseth managing multiple entities.
The Peak Agreement required Boyne to perform four steps, including not challenging the U.S. land exchange, paying for a survey, transferring 25 acres under the Southfork Agreement, and paying half the Lone Peak value; the court later found Boyne fulfilled the first three obligations.
SPD allegedly breached by demanding Boyne transfer of additional land; SPH/SPD later argued Boyne sold rather than exchanged the 25 acres, and Boyne faced claims of deceit and abuse of the legal process.
The District Court awarded Boyne specific performance, and attorney fees; the jury awarded damages for abuse of process and deceit; SPD and LMH appealed, and LMH’s purchase status was reviewed for good-faith intent.
The Montana Supreme Court affirmed the district court’s judgment with a minor modification, upheld specific performance, addressed damages, and remanded for appellate fees determination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether specific performance was proper for the Peak Agreement	Boyne fulfilled key duties; anticipatory breach allowed enforcement	Boyne breached by misdirecting the 25 acres transfer and nonpayment	Yes; specific performance affirmed with adjustments
Whether Boyne exchanged 25 acres as required by the Southfork Agreement	Transfer to SPH satisfied the exchange requirement with SPH as the proper recipient	25 acres were to be transferred to SPD, not SPH	Exchanged; assignment showed SPD transferred rights to SPH; district court properly found exchange occurred
Whether Boyne's partial nonpayment bars enforcement due to anticipatory breach	SPD repudiation excused further performance; anticipatory breach allows enforcement	Nonpayment prevents specific performance unless contract fully performed	Held that anticipatory breach excused payment; specific performance proper
Whether damages for abuse of the legal process and deceit are supported	SPD/LMH engaged in abusive litigation and deceived Boyne to extract concessions	Damages were speculative or unsupported	Substantial evidence supported $600,000 in damages; affirmed
Whether attorney fees on appeal were properly awarded	Peak Agreement entitles prevailing party to fees on appeal	Fees must be tied to motions properly captioned under rules	Affirmed entitlement to appellate fees; remanded to determine reasonable amounts

Pastimes, LLC v. Clavin, 364 Mont. 109 (2012 MT) (clear error standard for findings of fact; correctness for conclusions of law)
Eschenbacher v. Anderson, 34 P.3d 87 (2001 MT) (antagonistic performance avoided when repudiation occurs; useless acts doctrine)
Chamberlin v. Puckett Constr., 921 P.2d 1237 (1996 MT) (anticipatory breach defining when extra terms are required)
Naylor v. Hall, 651 P.2d 1010 (1982 MT) (purchaser in good faith liable to perform contract)
Kiely Constr. L.L.C. v. City of Red Lodge, 312 Mont. 52 (2002 MT) (loss of investment value due to delay; future value damages)
Frisnegger v. Gibson, 598 P.2d 574 (1979 MT) (recovery limits for damages in contract cases)
Seltzer v. Morton, 336 Mont. 225 (2007 MT) (substantial credible evidence standard for jury verdicts)
Moody v. Northland Royalty Co., 951 P.2d 18 (1997 MT) (substance over caption; motion characterization)
Varano v. Hicks, 285 P.3d 592 (2012 MT) (standard of review for legal conclusions)
Tripp v. Jeld-Wen, Inc., 112 P.3d 1018 (2005 MT) (abuse of discretion standard for attorney fees)