Parkwest Homes v. Julie G. Barnson
154 Idaho 678
| Idaho | 2013Background
- ParkWest sought to foreclose a mechanic’s lien on Barnson’s property; lien based on work performed without initial contractor registration, later registered; MERS held the deed of trust beneficiary interests, with Transnation as original trustee and First American as successor trustee; Residential intervened after trustee’s sale and claimed lien was not valid against it; ParkWest’s prior litigation ParkWest I held lien valid for labor/materials after registration; ParkWest did not name Transnation, First American, or Residential in the foreclosure action; court challenged whether lien survived against later holders who acquired title through a trustee’s sale; issue also whether a 6-month timing and naming requirement under I.C. § 45-510 extinguishes lien as to unnamed parties; district court granted summary judgment for Residential, ParkWest appealed; ParkWest’s appeal asserts lien validity despite intervenor’s interests; this Court ultimately affirmed the district court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether law of the case bars new lien challenges when not party to prior appeal. | ParkWest: law of the case bars new challenges. | Residential: law of the case does not bar new challenges since intervenor wasn’t party in ParkWest I. | Law of the case does not preclude new challenges. |
| Must a lienor name the deed-of-trust trustee within six months to enforce against subsequent title holders? | ParkWest: trustee naming not required for all interests; First American was merely legal title. | Residential: must name trustee to enforce lien against subsequent holders. | Yes; failure to name the trustee loses the lien against subsequent holders. |
| Does a default judgment against Barnson give priority to ParkWest’s lien over Residential’s interest? | ParkWest argues priority under 10-1110 despite trustee’s deed. | Residential argues priority follows the trustee’s deed and acquired interest. | ParkWest’s priority claims fail; debt title flowed via trustee’s deed, not over lien. |
Key Cases Cited
- ParkWest Homes, LLC v. Barnson, 149 Idaho 603 (2010) (ParkWest I; lien validity after contractor registration and compliance with §45-507)
- Palmer v. Bradford, 86 Idaho 395 (1963) (lien enforcement must be timely; otherwise lien lost)
- Willes v. Palmer, 78 Idaho 104 (1956) (must name proper parties within six months or lien lost against unnamed)
- Long v. Williams, 105 Idaho 585 (1983) (title theory; deed of trust passes legal title to trustee)
- Swanson v. Swanson, 134 Idaho 512 (2000) (law of the case doctrine; binds on subsequent litigation between same parties)
- Johnson v. Young, 53 Idaho 271 (1932) (law of the case scope and party-bound principle)
- George W. Watkins Family v. Messenger, 118 Idaho 537 (1990) (interpretation of statutes; legislative intent)
- Idaho Fair Share v. Idaho Pub. Utils. Comm’n, 113 Idaho 959 (1988) (statutory interpretation principles; primary focus on legislative intent)
- J.R. Simplot Co. v. Idaho State Tax Comm’n, 120 Idaho 849 (1991) (statutory interpretation; general principles governing interpretation)