291 P.3d 399
Idaho2012Background
- Roof collapse at Lakeland True Value Hardware in Rathdrum, Idaho, after 2008 snowfall; Hartford insured Lakeland and advanced partial payments for business personal property and income losses; salvage and storage practices yielded unclear valuation material; Hartford pursued detailed documentation and engaged MD&D for income-loss evaluation; District Court granted summary judgment dismissing Lakeland’s bad-faith claim but allowed breach-of-contract claim to proceed to trial where Hartford prevailed; Lakeland appealed asserting error on summary judgment, evidentiary rulings, jury instructions, special verdict form, and discretionary-cost award.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was summary judgment proper on Lakeland’s bad-faith claim? | Lakeland contends not debatable; disputed facts show insurer delayed payment. | Hartford contends the claim was fairly debatable; delays stemmed from missing information. | Yes, summary judgment affirmed for dismissal of bad faith claim. |
| Were evidentiary rulings and jury instructions proper? | Lakeland argues exclusion of expert Underdown and parol evidence confused the jury. | Hartford asserts rulings supported by rules and cured any harm. | Yes, rulings, instructions, and special verdict form affirmed. |
| Was the jury verdict supported by substantial evidence? | Lakeland asserts insufficient evidence on end-date of Period of Restoration. | Hartford asserts record shows Lakeland failed to provide necessary documentation to compute losses. | Yes, verdict upheld as supported by substantial evidence. |
| Was the district court’s discretionary-cost award proper? | Lakeland argues costs were excessive and misapplied. | Hartford maintains award based on interests of justice given conduct and complexity. | Yes, discretionary-cost award affirmed. |
Key Cases Cited
- Robinson v. State Farm Mut. Auto. Ins. Co., 137 Idaho 173 (2002) (bad-faith elements; not fairly debatable must be proven)
- Anderson v. Farmers Ins. Co. of Idaho, 130 Idaho 755 (1997) (not fairly debatable when denial is due to good-faith mistake)
- Lucas v. State Farm Fire & Cas. Co., 131 Idaho 674 (1998) (not debatable if insurer has reasonably disputable claim)
- Miller v. Belknap, 75 Idaho 46 (1954) (burden on plaintiff to prove right to recover by preponderance)
- Inland Group of Cos., Inc. v. Prov. Wash. Ins. Co., 133 Idaho 249 (1999) (substantial evidence standard on jury verdicts)
- Puckett v. Verska, 144 Idaho 161 (2007) (interests of justice in discretionary costs; exceptional case)
- Beale v. Speck, 127 Idaho 521 (1995) (when exceptional costs justified by case nature)
- Lettunich v. Lettunich, 145 Idaho 746 (2008) (discretionary costs based on conduct and case complexity)
- Great Plains Equip., Inc. v. Nw. Pipeline Corp., 136 Idaho 466 (2001) (discretionary costs framed by interests of justice)
- Lindberg v. Roseth, 137 Idaho 222 (2002) (parol vs extrinsic evidence; contract interpretation)