Maynard v. Nguyen
274 P.3d 589
| Idaho | 2011Background
- Maynard rented a trailer from the Nguyens under a lease providing title transfer after three years of $500 monthly rent; rent default triggered loss of rights.
- Maynard was jailed in Nov 2008 and upon returning discovered her belongings removed and trailer re-rented.
- Maynard filed ICPA action on May 7, 2009 seeking damages and penalties; defendants were served but failed to answer or appear timely.
- Default judgment was entered around Sept 2, 2009 after a separate June 25, 2009 order of default; damages hearing occurred July 14, 2009.
- Nguyens moved to set aside the default under I.R.C.P. 60(b)(1) & (6), asserting unique and compelling circumstances and a meritorious defense.
- District court granted relief on Dec 7, 2009, and case was appealed; Supreme Court affirmed, remanding for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court erred in granting Rule 60(b) relief | Maynard argues no meritorious defense and no unique circumstances | Nguyens contend district court acted within discretion promoting merits | No abuse; relief affirmed |
| Meritorious defense present for abandonment/forfeiture | Maynard asserts abandonment as defense | Nguyens argue abandonment improper; defense misconstrued | District court properly recognized a meritorious defense (forfeiture under lease) |
| Did letter to judge constitute appearance triggering three-day notice | Maynard’s counsel should have disclosed; letter not appearance | Letter evidenced defense; triggered notices | Letter supported appearance and three-day notice requirement was implicated |
| Proper grounds for 60(b)(6) relief under unique circumstances | Relief not justified by attorney conduct | Attorney conduct created unique circumstances warranting relief | Unique and compelling circumstances existed; relief affirmed |
Key Cases Cited
- Waller v. State, Dep't of Health & Welfare, 146 Idaho 234 (Idaho 2008) (abuse of discretion standard for Rule 60(b) decisions; merits-based analysis)
- Ponderosa Paint Mfg., Inc. v. Yack, 125 Idaho 310 (Ct.App.1994) (merits defense requirement in 60(b) relief)
- Dawson v. Cheyovich Family Trust, 149 Idaho 375 (Idaho 2010) (60(b)(6) relief; discretionary review; consistency with pleadings)
- Hopkins v. Troutner, 134 Idaho 445 (Idaho 2000) (wide latitude under 60(b)(6); attorney conduct and professional standards)
- Newbold v. Arvidson, 105 Idaho 663 (Idaho 1983) (appearance and three-day notice principles in default contexts)
- Riverside Development Co. v. Ritchie, 103 Idaho 515 (Idaho 1982) (contractual right of reentry and forfeiture under lease; three-day notice)