Douglas Visser v. Auto Alley, LLC, 162 Idaho 1

Douglas was awarded a property (a former wrecking yard) in his 2005 divorce from Vicki; the property was encumbered by a promissory note and deed of trust (the Lapham debt).
Calvin (Douglas’s son) and Vicki operated a wrecking yard (Auto Alley, LLC) on part of the property; Calvin and Vicki were supposed to pay the Lapham debt and taxes instead of rent.
By 2013 taxes were years delinquent and the Lapham debt had ballooned; Douglas paid some taxes and sued for breach of contract and waste. A temporary restraining order and mediation followed.
On Feb. 19, 2014 the parties entered a Stipulated Judgment splitting the property into Lot 1 and Lot 2; Douglas would convey Lot 2 to Vicki ONLY if she fully performed specified obligations (including paying half the Lapham debt by 6/30/2014), and the judgment provided for immediate writ of possession if she failed to make required payments.
Vicki failed to complete the conditions. Douglas moved to enforce the stipulated judgment, seeking writ of possession and quiet title; after hearings the district court granted Douglas’s motion and denied Vicki’s motions (contempt, reconsideration).
On appeal the Idaho Supreme Court affirmed the district court, held Vicki could not challenge the stipulated judgment on ordinary contract grounds, found Douglas did not interfere with performance, and awarded Douglas attorney fees on appeal under the stipulated judgment.

Issue	Plaintiff's Argument (Douglas)	Defendant's Argument (Viss er)	Held
Enforceability of forfeiture/forfeiture clause in the stipulated judgment	Stipulated judgment is binding; enforcement proper under its terms	Forfeiture provision is an unenforceable penalty and the stipulated judgment is not enforceable on that basis	Court refused to reach the substantive contract/penalty challenge because Vicki stipulated to the judgment and did not invoke exceptions that would permit appellate review; claim not considered
Whether Douglas interfered with Vicki’s ability to comply (duty of good faith)	No duty to convey Lot 2 before Vicki fully performed; no interference	Douglas breached duty of good faith by not conveying Lot 2 so Vicki could refinance and pay her share	Court held Douglas had no duty to convey prior to Vicki’s complete performance; substantial evidence supports no interference
Entitlement to attorney fees on appeal	Prevailing party entitled to fees under the Stipulated Judgment	Sought fees/costs but was not prevailing party	Court awarded fees and costs on appeal to Douglas as prevailing party under the judgment

Fagen, Inc. v. Rogerson Flats Wind Park, LLC, 159 Idaho 624, 364 P.3d 1189 (Idaho 2016) (general rule: stipulated judgments are not subject to appellate review except in narrow exceptions)
Jim & Maryann Plane Family Trust v. Skinner, 157 Idaho 927, 342 P.3d 639 (Idaho 2015) (a stipulation is treated like a contract for purposes of interpreting its language)
Guzman v. Piercy, 155 Idaho 928, 318 P.3d 918 (Idaho 2013) (contract principles applied to construe stipulation language)
Mihalka v. Shepherd, 145 Idaho 547, 181 P.3d 473 (Idaho 2008) (distinguishing stipulated judgments from settlement agreements; settlements are treated as new contracts and subject to ordinary contract defenses)
Pinnacle Engineers, Inc. v. Heron Brook, LLC, 139 Idaho 756, 86 P.3d 470 (Idaho 2004) (standard of review for trial court findings of fact)