Kenworth Sales v. Skinner Trucking, 454 P.3d 580

Background:

Kenworth sold three trucks to GE, which leased them to Skinner under TRAC leases (each truck residual value set at $58,051.20; monthly rental $2,357.72).
Skinner returned two trucks in Oct 2015 and the third in Dec 2015; Kenworth paid GE the combined residuals ($174,153.60) and back rent owed on one truck ($7,073.17), then took possession.
Kenworth later invoiced Skinner $55,226.77 (difference between residuals and Kenworth’s appraisal values plus back rent). There was no written agreement requiring Skinner to reimburse Kenworth.
Kenworth sued Skinner for unjust enrichment; at bench trial the district court found Kenworth had conferred no benefit as to the residuals, and that Kenworth was an officious intermeddler as to both residual and back-rent payments; judgment for Skinner.
Skinner sought attorney fees under I.C. § 12-120(3) and § 12-121; the district court denied fees. Both parties appealed; appeals consolidated.
The Idaho Supreme Court affirmed the district court: Kenworth was an officious intermeddler, no unjust enrichment recovery for residuals, and no entitlement to the requested attorney fees on the claimed bases.

Issues:

Issue	Kenworth (Plaintiff) Argument	Skinner (Defendant) Argument	Held
Is the officious intermeddler rule an affirmative defense that must be pled?	Officious intermeddler is an affirmative defense; Skinner failed to plead it timely.	It is not an affirmative defense; it bears on the plaintiff’s prima facie unjust-enrichment case.	Not an affirmative defense; voluntariness of payment goes to the inequity element of unjust enrichment.
Did Kenworth have a “valid reason” (so as not to be an officious intermeddler) for paying GE?	Kenworth paid to keep Skinner, a long‑time customer, in business; that motive justifies payment.	Kenworth’s desire to help a customer is too attenuated to be a valid reason under the doctrine.	Kenworth’s motive to preserve a customer relationship is insufficient; Kenworth was an officious intermeddler.
Did Kenworth confer a benefit on Skinner by paying the lease residuals (first element of unjust enrichment)?	Payment to GE discharged Skinner’s potential obligation and thus conferred a benefit recoverable in restitution.	Under the TRAC lease Skinner owed nothing to GE unless the trucks sold for less than residuals; Kenworth’s payment did not discharge an existing debt.	No benefit as to residuals: payment to GE did not discharge a presently existing obligation of Skinner, so the first element fails.
Was Skinner entitled to attorney fees under I.C. § 12-120(3) or § 12-121?	N/A (Skinner sought fees as prevailing party).	(1) § 12-120(3): Kenworth’s claim arose from a commercial transaction; (2) § 12-121: Kenworth’s suit was frivolous.	§ 12-120(3): denied — no commercial transaction alleged between Kenworth and Skinner. § 12-121: denied — claim was not frivolous; it raised debatable legal issues.

Key Cases Cited

Med. Recovery Servs., LLC v. Bonneville Billing & Collections, Inc., 157 Idaho 395, 336 P.3d 802 (2014) (sets out elements of unjust enrichment in Idaho)
Teton Peaks Inv. Co., LLC v. Ohme, 146 Idaho 394, 195 P.3d 1207 (2008) (discusses officious intermeddler rule barring restitution for volunteers)
Chinchurreta v. Evergreen Management, Inc., 117 Idaho 591, 790 P.2d 372 (1989) (Court of Appeals discussion adopting Restatement description of officious intermeddler)
Simono v. House, 160 Idaho 788, 379 P.3d 1058 (2016) (commercial-transaction/gravamen analysis under I.C. § 12-120(3))
DAFCO LLC v. Stewart Title Guar. Co., 156 Idaho 749, 331 P.3d 491 (2014) (party cannot claim § 12-120(3) fees based on a contract between different parties)