Mary Pandrea v. Kenneth Barrett, 369 P.3d 943

Parcels originally held in a family trust were divided among sisters Kari Clark and Mary Pandrea as tenants in common; disputes arose after dissolution of the trust and clerical deeds.
Pandrea sought partition and initially asked for sale (claiming physical partition would greatly prejudice her), then at trial joined Clark in seeking partition in kind; both parcels were ultimately held as joint one-half interests.
The district court found total property value ~$100,000–$130,000, awarded Pandrea reimbursement for certain improvements (~$33,129 total including cabin remodel), and allocated most other claimed expenses as unsupported.
The court adopted a partition largely based on Pandrea’s proposal: two parcels (≈12.739 acres to Pandrea and ≈10.423 acres to Clark) with an easement across Pandrea’s parcel for Clark’s access.
Pandrea repeatedly sought post-judgment relief: motions to reconsider the partition, to amend her complaint to add claims/parties (including slander of title), and to alter the final decree based on new surveys and alleged prejudice from the easement; the court denied those motions.
Clark sold her awarded parcel to the Barretts, who were substituted as respondents on appeal; the Idaho Supreme Court affirmed the district court’s orders and judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court erred by denying motion to reconsider Partition Order	Pandrea argued the partition (in kind) and related rulings were prejudicial and that newly discovered lien/slander-of-title issues justified reconsideration	Court/Clark argued new claims were not litigated or pled, and reconsideration cannot be used to raise novel causes of action; lien was corrected and caused no prejudice	Denial affirmed; reconsideration was improper to raise new claims and partition was supported by substantial evidence
Whether court abused discretion by denying motion for leave to amend complaint	Pandrea sought to add defendants and new claims (e.g., slander of title, challenges to easement) discovered late in litigation	Court found motion untimely, prejudicial to Clark, raised novel claims, and suggested bad-faith/dilatory conduct	Denial affirmed as within court’s discretion under Rule 15; prejudice and delay justified refusal
Whether court abused discretion by denying motion to reconsider/reopen final judgment (Rule 59(e)/60(b))	Pandrea argued new surveys and affidavit showed the easement greatly diminished value of her parcel, requiring sale instead of partition	Court treated motion as 59(e)/60(b), found no factual mistake, insufficient new evidence, and no basis for relief; easement and value issues were considered earlier	Denial affirmed; trial court reasonably exercised discretion, no grounds for 59(e) or 60(b) relief

Westby v. Schaefer, 157 Idaho 616 (Idaho 2014) (standard for reviewing a district court’s reconsideration motion)
Fragnella v. Petrovich, 153 Idaho 266 (Idaho 2012) (same principle on reconsideration standards)
Fox v. Mountain W. Elec., Inc., 137 Idaho 703 (Idaho 2002) (three-factor test for abuse of discretion review)
Barmore v. Perrone, 145 Idaho 340 (Idaho 2007) (Rule 59(e) denial reviewed for manifest abuse of discretion)
Bowles v. Reade, 198 F.3d 752 (9th Cir. 1999) (discusses required findings when denying leave to amend based on prejudice, bad faith, or futility)
Porter v. Bassett, 146 Idaho 399 (Idaho 2008) (slander of title pleading and trial rights)
Puphal v. Puphal, 105 Idaho 302 (Idaho 1984) (Rule 60(b) mistake must be factual rather than legal)
First Bank & Trust of Idaho v. Parker Bros., 112 Idaho 30 (Idaho 1986) (Rule 60(b) requires showing of good cause and applicable grounds)
Black Canyon Racquetball Club, Inc. v. Idaho First Nat’l Bank, N.A., 119 Idaho 171 (Idaho 1990) (circumstances permitting denial of leave to amend, including prejudice and dilatory conduct)