335 P.3d 1
Idaho2014Background
- Browns owned 320 acres in Elmore County; Water Rights 61-2188 and 61-7151 decreed in 2000, totaling up to 287 acres on the Brown Property, but neither right used since 1986.
- In 2007, Browns conveyed part of the land to Greenheart by a warranty deed stating property was transferred “with their appurtenances,” while intending the water rights not to transfer.
- Purchase agreement and disclosures labeled water rights as blank or NA; Greenheart later believed land was dry with no water rights, and Greenheart was not informed of potential transfer.
- Greenheart sought tax reclassification to dry grazing in 2007 and later asserted ownership of water rights after a 2012 IDWR record change; Browns discovered possible deed language error in 2012 and filed suit April 5, 2012.
- District court held mutual mistake and quasi-estoppel/waiver supported reformation of the deed to exclude water rights; awarded Browns attorney fees as prevailing party under 12-120(3); Greenheart appeals the decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Statute of limitations on quiet title claim. | Browns argue not barred under 5-224. | Greenheart claims four- or five-year limits apply. | Not barred; accrual at Greenheart’s adverse claim in 2012. |
| Sufficiency of mutual mistake claim. | Browns assert clear, convincing evidence of mutual mistake. | Greenheart contends no pled or proven mutual mistake. | Sufficiently pled and proven; grounds support reformation. |
| Quasi-estoppel/waiver basis for reformation. | Browns rely on Greenheart adopting inconsistent positions to gain windfall. | Greenheart argues no waiver or estoppel issue appealed. | affirmed on grounds of quasi-estoppel and waiver. |
| Ambiguity of the purchase and sale agreement and admissibility of extrinsic evidence. | Browns argue ambiguity allows extrinsic evidence for mutual mistake. | Greenheart contends terms unambiguous; extrinsic evidence not needed. | Contract ambiguous; extrinsic evidence admissible to resolve. |
| Attorney fees on appeal. | Browns seek fees as prevailing party on appeal under 12-120(3). | Greenheart argues inapplicability of 12-120(3) for this transaction. | Affirmed; Browns awarded fees on appeal as prevailing party. |
Key Cases Cited
- Hardy v. McGill, 137 Idaho 280 (Idaho 2002) (standard for reviewing factual findings; supreme review of law)
- Conley v. Whittlesey, 133 Idaho 265 (Idaho 1999) (analysis of standard of review and evidence)
- Harper v. Harper, 122 Idaho 535 (Idaho 1992) (pleading standards and notice requirements)
- Knipe Land Co. v. Robertson, 151 Idaho 449 (Idaho 2011) (ambiguity and extrinsic evidence in contract interpretation)
- Swanson v. Beco Constr. Co., 145 Idaho 59 (Idaho 2007) (contract ambiguity and two reasonable interpretations)
- C & G, Inc. v. Rule, 135 Idaho 763 (Idaho 2001) (contract interpretation and ambiguity)
- Watson v. Watson, 144 Idaho 214 (Idaho 2007) (commercial nature of land transactions; attorney fees)
- VanderWal v. Albar, Inc., 154 Idaho 816 (Idaho 2013) (standard for reviewing factual findings; substantial evidence)