Background - Jakobson granted a deed of trust to Washington Mutual securing a line of credit; one day later he quitclaimed the property to CMJ Properties, LLC (CMJ). - The deed of trust and credit agreement expressly stated a maturity date of August 9, 2037. - Jakobson defaulted on the credit line in May 2010, filed bankruptcy later in 2010, and Chase (assignee of the deed) terminated the credit line on April 6, 2011 and obtained relief from the bankruptcy stay but did not foreclose. - CMJ sued in June 2016 to quiet title, arguing the five-year statute of limitations to foreclose had run; CMJ moved for default judgment after Chase failed to appear. - The district court entered default but denied default judgment, concluded the statutory limitations period had not run because the instrument stated a maturity date, and dismissed CMJ’s quiet title claim; CMJ appealed. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---:|---| | Whether court must treat CMJ's allegation that >5 years passed since maturity as admitted after default | Allegation is factual and therefore admitted under I.R.C.P. 8(b)(6) | Court may reject legal conclusions dressed as facts; maturity date is a legal question requiring instrument analysis | Court: Not admitted; maturity date is a legal conclusion and court must interpret the instruments despite default | | When the 5-year foreclosure statute of limitations (I.C. § 5-214A) begins to run if borrower defaults/acceleration occurs | Acceleration/default triggered a new maturity date and started the 5-year limitations period (i.e., after 2011) | The statute looks to the maturity date stated in the instrument; absent a contractual clause changing maturity on acceleration, the stated maturity controls | Court: Statute begins to run from the stated maturity date (08/09/2037); acceleration did not change it | | Whether a successor-in-interest with knowledge of an unsatisfied mortgage can quiet title after limitations has run | CMJ: successor with knowledge may quiet title if statute has run (relying on Trusty v. Ray) | Chase: argues limitations not run; also default issues | Court: Moot because limitations not run; did not decide the Trusty issue | | Entitlement to attorney fees on appeal under I.C. § 12-121 | CMJ sought fees as prevailing party | Chase sought fees as prevailing party and argued CMJ’s suit was frivolous | Court: Neither entitled; Chase prevailed on appeal (costs to Chase) but statute’s "frivolous" standard not met; CMJ not prevailing party | ### Key Cases Cited PacifiCorp v. Idaho State Tax Comm’n, 153 Idaho 759, 291 P.3d 442 (Idaho 2012) (standard of review for legal conclusions) State v. Hart, 135 Idaho 827, 25 P.3d 850 (Idaho 2001) (statutory interpretation principles) Baughman v. Wells Fargo Bank, N.A., 162 Idaho 174, 395 P.3d 393 (Idaho 2017) (holding stated maturity date controls § 5-214A; acceleration does not change maturity absent contractual language) Holladay v. Lindsay, 143 Idaho 767, 152 P.3d 638 (Ct. App. 2006) (default admits factual allegations) Martinez v. Carrasco, 162 Idaho 336, 396 P.3d 1218 (Idaho 2017) (effects of default; need to set aside default to participate fully) Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (legal conclusions need not be accepted as true) Papasan v. Allain, 478 U.S. 265 (U.S. 1986) (same) J.R. Simplot Co. v. Bosen, 144 Idaho 611, 167 P.3d 748 (Idaho 2006) (court need not address immaterial issues the trial court did not rely on) * Trusty v. Ray, 73 Idaho 232, 249 P.2d 814 (Idaho 1952) (discussed regarding successor-in-interest quiet title theory)