Jim & Maryann Plane Family Trust v. Skinner
342 P.3d 639
Idaho2015Background
- Three adjacent parcels in Bear Lake County: north (Evertons), middle (Wallentines), south (Macvicar). Macvicar historically accessed her parcel via a driveway crossing the Everton and Wallentine parcels to State Highway 89.
- In 1998 Macvicar sued for an easement; parties stipulated in 2000 and the district court entered a Judgment granting a roughly ten-foot easement along the west boundary, limiting use of the Wallentine parcel to no more than five feet.
- Subsequent owners: Planes (south parcel) transferred to the Plane Family Trust (Trust) and Skinners bought the Everton and Wallentine parcels; the Trust had notice of the 2000 Judgment when it purchased.
- In 2012 ITD contacted Skinners about an "illegal" driveway but later issued (2013) a permit allowing use of up to five feet of the State right-of-way for ingress/egress to both Skinners and Planes.
- In 2013 the Trust moved under I.R.C.P. 60(b)(4) to void three sentences of the 2000 Judgment (those referencing the State right-of-way and the five-foot limit) to place the full ten-foot easement on Skinners’ land; the district court denied the motion and awarded attorney fees to Skinners.
- The Trust appealed; the Idaho Supreme Court affirmed, denied Rule 60(b)(4) relief, upheld the fee award, and imposed appellate fees on the Trust and its counsel under I.A.R. 11.2.
Issues
| Issue | Plane Trust's Argument | Skinners' Argument | Held |
|---|---|---|---|
| Whether partial voiding of the 2000 Judgment under I.R.C.P. 60(b)(4) was allowed | Trust sought to void three sentences to relocate the full ten-foot easement onto Skinners’ parcels | Such a "surgical" excision would unilaterally reframe the parties’ stipulation and judgment | Denied — court may not selectively void portions to craft a favorable judgment (attempts to "unilaterally craft" are impermissible) |
| Whether the 2000 Judgment was void for lack of personal jurisdiction (State not a party) | Trust argued the judgment affected State right-of-way and so was void without the State as a party | Judgment language merely recognized the access "may be" upon State right-of-way historically and did not purport to impair State rights | Denied — no personal jurisdiction defect; judgment did not grant or impair State easement rights |
| Whether the district court lacked subject-matter jurisdiction because ITD has exclusive control over rights-of-way | Trust contended Title 40 precludes adjudication affecting State right-of-way | District court has jurisdiction to adjudicate private easement claims among owners; the judgment did not affect State’s interest | Denied — court had subject-matter jurisdiction over the easement dispute |
| Whether attorney fees and sanctions were appropriate (district court and on appeal) | Trust argued motion had merit and fees were unwarranted; challenged factual findings | Skinners argued Trust’s motion was frivolous, unreasonable, and without foundation; asked for fees including on appeal | Affirmed — district court did not abuse discretion in awarding fees; appellate fees granted under I.A.R.11.2 against Trust and its counsel |
Key Cases Cited
- McGrew v. McGrew, 139 Idaho 551 (2003) (a party may not void only parts of a judgment in a way that unilaterally crafts a new outcome)
- State, Dep’t of Health & Welfare v. Housel, 140 Idaho 96 (2004) (whether a judgment is void is a question of law and void-judgment inquiry is narrowly construed)
- Guzman v. Piercy, 155 Idaho 928 (2014) (primary objective in interpreting a stipulation/contract is to discover mutual intent from the document language)
- Hartman v. United Heritage Prop. & Cas. Co., 141 Idaho 193 (2005) (court narrowly construes what constitutes a void judgment)
- Cuevas v. Barraza, 152 Idaho 890 (2012) (final judgments generally not subject to collateral attack; Rule 60(b)(4) relief limited to void judgments)