Craig v. Silver Sage Ranch, LLC, 1:22-cv-00115

Background

In 2019, Daniel Craig agreed to purchase Midvale Ranch in Idaho from Renee Baker and Joseph Buermann (owners of Silver Sage Ranch LLC) for $3.3 million.
Craig put up $682,000 in earnest money (designated “non-refundable” in an amendment), which was released early to the sellers to help them purchase another property after multiple closing delays caused by Craig’s financing issues.
After Craig failed to obtain financing, the sale fell through in October 2019, but sellers told Craig they would return unused earnest money after selling the ranch and accounting for any losses.
The sellers later sold the ranch in 2021 but did not repay the earnest money, besides a partial return; communication broke down after Craig’s attorney contacted defendants.
Craig sued seeking the return of the earnest money, alleging breach of contract (including an oral agreement for return), mutual mistake, unjust enrichment, fraud, ICPA violations, and declaratory relief. Defendants moved for summary judgment on all claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Breach of oral contract for return of earnest money	Parties orally agreed to return the money (minus costs) after the ranch sold, in exchange for forbearance of suit.	No enforceable oral contract—barred by statute of frauds, lacks consideration and definiteness.	Denied SJ for defendants; factual issues remain.
Mutual mistake (rescission)	Mutual mistaken belief he would secure financing justifies undoing the contract and returning deposit.	No mutual mistake about the subject matter—only about party’s ability to perform (not grounds).	Granted SJ—no mutual mistake here.
Unjust enrichment	Keeping the nonrefundable deposit would unjustly enrich the sellers, especially with buyer’s litigation delay.	An express contract covers the claim; delay in suing does not constitute recoverable benefit.	Granted SJ—not a viable claim under the facts.
Fraud in the inducement	Sellers misrepresented, or omitted to state, how the nonrefundable earnest money would be handled at no closing.	No duty to disclose; always intended to help return a portion; no evidence they intended to keep all.	Granted SJ—no factual basis for fraud claim.
Violation of Idaho Consumer Protection Act	Transaction was unconscionably one-sided and should offend public conscience.	No knowing unconscionable conduct; parties expected closing, intended to return portion.	Granted SJ—no ICPA violation on the facts.
Declaratory relief (ambiguity of contract)	Conflicting terms in addendum make contract ambiguous—should get interpretation or relief.	Only one reasonable reading: money non-refundable if no closing.	Granted SJ—contract is unambiguous.

Key Cases Cited

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (materiality standard for summary judgment)
Celotex Corp. v. Catrett, 477 U.S. 317 (burden shifting at summary judgment)
Papin v. Papin, 454 P.3d 1092 (consideration requirement under Idaho law)
O’Connor v. Harger Const., Inc., 188 P.3d 846 (mutual mistake and rescission in Idaho)
Weisel v. Beaver Springs Owners Ass’n, Inc., 272 P.3d 491 (burden of proving lack of consideration)
Country Cove Dev., Inc. v. May, 150 P.3d 288 (fraudulent inducement elements in Idaho)
Fenn v. Noah, 133 P.3d 1240 (ICPA applies to investment real estate)
Syringa Networks, LLC v. Idaho Dep’t of Admin., 305 P.3d 499 (definiteness required for contract enforceability)
Knipe Land Co. v. Robertson, 259 P.3d 595 (ambiguity in contracts is a legal question)