Idaho Military Historical Society, Inc. v. Maslen
156 Idaho 624
| Idaho | 2014Background
- IMHS (Idaho Military Historical Society) received title to a PT-23 Fairchild airplane formerly owned by IAHOF; AOI (Aeroplanes Over Idaho) and its president Maslen had been storing the plane in Maslen’s hangar gratuitously for years.
- After IAHOF donated the plane to IMHS in 2008, Maslen/AOI refused to surrender possession and filed an FAA storage/maintenance lien (~$12k) against the aircraft.
- IMHS sued for claim and delivery and related causes; defendants counterclaimed. Discovery issues led to sanctions against defendants. A bench trial resolved possession and lien issues.
- The district court ordered return of the airplane to IMHS, found the FAA lien filed with reckless disregard for its truth, rejected defendants’ counterclaims, and awarded IMHS attorney fees ($73,675) under I.C. § 12-121 and I.R.C.P. 54(e)(1) as sanctions for frivolous defense conduct.
- Defendants appealed, challenging (1) whether IMHS was the prevailing party, (2) the fee award under § 12-121/Rule 54, and (3) entitlement to appellate fees.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Who was the prevailing party? | IMHS: primary dispute was possession and lien; IMHS prevailed on those central issues. | Defendants: IMHS failed on most claims and could’ve obtained the plane by bond; avoiding damages is significant. | IMHS was the prevailing party — court may view prevailing party holistically, not claim-by-claim. |
| Were defendants’ claims/defenses frivolous under I.C. § 12-121 / I.R.C.P. 54(e)(1)? | IMHS: lien and unjust-enrichment claim were without foundation; conduct necessitated suit. | Defendants: had legitimate arguments (avoided large damages; counterclaims not frivolous). | Court upheld fee award — defendants acted with reckless disregard re: lien; key claims frivolous. |
| May district court apportion fees when any triable issue exists? | IMHS: district courts may apportion fees for frivolous portions; Nampa Meridian’s strict bar (no fees if any triable issue) should be narrowed. | Defendants: rely on Nampa Meridian to argue fees improper if any legitimate triable issue existed. | Court retreats from strict Nampa Meridian phrasing and permits apportionment: fees can be awarded for frivolous elements even if some triable issues exist. |
| Are appellate fees recoverable? | IMHS: seeks fees under § 12-121 and appellate rules. | Defendants: appeal raised reasonable, good-faith legal questions. | No appellate fees — appeal not frivolous; parties raised reasonable legal arguments. |
Key Cases Cited
- Lettunich v. Lettunich, 141 Idaho 425 (discretion in determining prevailing party)
- Nampa & Meridian Irr. Dist. v. Washington Fed. Sav., 135 Idaho 518 (discusses limits on awarding § 12-121 fees when legitimate triable issues exist)
- O’Boskey v. First Fed. Sav. & Loan Ass’n of Boise, 112 Idaho 1002 (approves apportioning fees to frivolous portions of defense)
- Shore v. Peterson, 146 Idaho 903 (Rule 54(d) guidance on prevailing party analysis)
- Sun Valley Shopping Ctr. v. Idaho Power Co., 119 Idaho 87 (three-factor abuse-of-discretion test)
- Anderson v. Ethington, 103 Idaho 658 (standard for reviewing frivolous-action findings)
- Trilogy Network Sys. v. Johnson, 144 Idaho 844 (appellate review of prevailing-party determinations)