268 P.3d 458
Idaho2012Background
- Farrell, a licensed architect in Michigan, Texas, and New York, began work on Whiteman's West View Condominium project in Idaho in 2003 without Idaho licensure.
- Whiteman and Farrell had an oral partnership/expectation of profit sharing; no written contract setting Farrell's compensation existed initially.
- Farrell obtained Idaho architecture license on February 17, 2004; design plans were prepared before licensure and city review began after licensure.
- Whiteman terminated Farrell in July 2004; construction documents remained incomplete but Farrell's work allowed a bid to proceed.
- District court awarded Farrell damages on remand under unjust enrichment for pre-license costs and quantum meruit for post-license services; total award was $208,690.05.
- Whiteman appealed twice; the Idaho Supreme Court affirmed the remand award and awarded Farrell attorney's fees on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Quantum meruit and quality consideration | Farrell argues quality should augment value owed under quantum meruit. | Whiteman contends quality is not a proper factor for quantum meruit value. | Court allowed quality as an equitable factor; affirmed quantum meruit value. |
| Attorney's fees on appeal | Farrell seeks appellate fees as prevailing party. | Whiteman disputes entitlement to appellate fees. | Farrell entitled to appellate attorney's fees. |
Key Cases Cited
- O'Connor v. Harger Const., Inc., 145 Idaho 904 (Idaho 2008) (equitable remedies are factual balance)
- West Wood Invs., Inc. v. Acord, 141 Idaho 75 (Idaho 2005) (standard for reviewing findings of fact)
- Baker v. Boren, 129 Idaho 885 (Idaho Ct. App. 1997) (reasonable value concept in quantum meruit)
- Peavey v. Pellandini, 97 Idaho 655 (Idaho 1976) (objective measure for value of services)
- Barry v. Pac. W. Constr., Inc., 140 Idaho 827 (Idaho 2004) (no attorney's fees for illegal contract)
- Trees v. Kersey, 138 Idaho 3 (Idaho 2002) (no attorney's fees for illegal transaction)
- Blimka v. My Web Wholesaler, LLC, 143 Idaho 723 (Idaho 2007) (statutory fee shifting for commercial transactions)