Pocatello Hospital, LLC v. Quail Ridge Medical Investor, LLC
157 Idaho 732
| Idaho | 2014Background
- Ground Lease (1983) ties Portneuf Hospital (PMC) as lessor to Quail Ridge as lessee for 4.25 acres in Pocatello; rent equals 15% of land value with initial value $15,000/acre ($9,562.50/year).
- Rent adjustments were to occur every three years based on fair market value, with a parties’ written determination or arbitration if no agreement.
- Despite several transfers and estoppel certificates, annual rent remained $9,562.50 for years prior to 2007; IHC and Sterling never adjusted rents as scheduled.
- PMI (later Quail Ridge) bought the building and assumed the Lease in 2001, with a 2001 Estoppel Certificate stating rent was $9,562.50 and a personal guarantee by Preston.
- PMC acquired the property in 2009 and sought rent adjustment under 1.3(b); PMC I held declaratory relief and concluded 2010–2012 rent should be $148,500 based on current land value, totaling $416,812.50, which Quail Ridge was obligated to pay.
- PMC II sought breach of contract and breach of guarantee; district court granted summary judgment for PMC; Quail Ridge appeals on res judicata/claim and issue preclusion grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res judicata barred the contract and guarantee claims | Quail Ridge: prior dismissal in PMC I bars current claims | PMC: claims ripened after declaratory judgment; not barred | No; ripeness/previous dismissal was not final; res judicata does not apply |
| Whether the district court properly granted summary judgment for PMC | Quail Ridge disputes adequacy of evidence and preclusion | PMC showed clear entitlement to adjusted rents; no genuine fact issue | Yes; summary judgment proper; liability for 2010–2012 rents affirmed |
| Whether attorney fees and costs were properly awarded on appeal | Quail Ridge contests fees as unfounded | PMC prevailed; fee provisions independent basis; discretionary costs converted to fee | Yes; fees awarded on appeal to PMC |
| Whether either party is entitled to additional appellate fees | Each party seeks fees | PMC is prevailing; §12-120(3) and lease provisions authorize | PMC awarded appellate fees; Quail Ridge denied |
Key Cases Cited
- Ticor Title Co. v. Stanion, 144 Idaho 119 (Idaho 2007) (preclusion and res judicata framework in Idaho)
- Stoddard v. Hagadone, 147 Idaho 186 (Idaho 2009) (elements and application of collateral estoppel/issue preclusion)
- Hindmarsh v. Mock, 138 Idaho 92 (Idaho 2002) (definition and application of res judicata principles)
- Berkshire Invs., LLC v. Taylor, 153 Idaho 73 (Idaho 2012) (ripeness and final judgment requirements for res judicata)
- Gaige v. City of Boise, 91 Idaho 481 (Idaho 1967) (ripeness and justiciability limits on litigation)
- Duthie v. Lewiston Gun Club, 104 Idaho 751 (Idaho 1983) (ripeness/justiciability principles in preclusion analysis)
- Davidson v. Wright, 143 Idaho 616 (Idaho 2006) (unripe claims and litigation progression considerations)
- Nat'l Ro-Tile Corp. v. Loomis, 82 Idaho 65 (Idaho 1960) (foundational res judicata principles in Idaho)