Printcraft Press, Inc. v. Sunnyside Park Utilities, Inc.
153 Idaho 440
| Idaho | 2012Background
- Dispute concerns SPU sewage system limitations and Printcraft’s use of the system in Sunnyside Industrial Park.
- Printcraft moved into the park in 2006 under a ten-year sublease after a 2004 acquisition; SPU, Beck, and Woolf allegedly knew of the system’s limitations but did not disclose them.
- SPU disconnected Printcraft in December 2006 for alleged violations of IDAPA 58.01.03.004.03; Printcraft sued for breach of contract, fraudulent nondisclosure, and fraud, seeking damages and punitive damages.
- At trial, the jury awarded Printcraft $990,000 for fraudulent misrepresentation; district court denied JNOV; SPU moved for relief under Rule 60(b) based on newly discovered evidence.
- District court granted a new trial on damages under Rule 60(b); on appeal, the district court’s 60(b) ruling is reversed, but the denial of JNOV as to duty to disclose and damages is affirmed; attorney fees denial below affirmed.
- Printcraft cross-appealed on several points including punitive damages and attorney fees; the Supreme Court affirms in part and reverses in part.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court abused 60(b) discretion | Defendants showed unique circumstances warranting relief | New evidence undermines damages and supports relief | 60(b) relief abused; reversed on this ground |
| Whether there was a duty to disclose | Printcraft and Sowards third prong applied to create duty | No duty to disclose under Sowards prongs | Duty to disclose under third prong established; substantial evidence supports breach |
| Whether damages were supported by substantial evidence | Damages linked to nondisclosure and relocation costs | Damages offset by Printcraft’s own conduct and alternative outcomes | Damages supported by substantial and competent evidence; JNOV denied |
| Whether punitive damages could/should be submitted or awarded | Punitive damages appropriate for fraud claims | Punitive damages not properly considered due to trial posture | District court did not abuse in declining to submit punitive damages; cross-appeal rejected |
| Attorney fees on appeal | Entitled to fees as prevailing party | No commercial transaction between parties supports §12-120(3) fees | Fees not awarded below or on appeal; affirmed. |
Key Cases Cited
- Eby v. State, 148 Idaho 731 (Idaho, 2010) (standard for Rule 60(b) abuse of discretion; factual review delegated to trial court)
- In re Estate of Bagley, 117 Idaho 1091 (Idaho Ct. App. 1990) (unique and compelling circumstances standard for Rule 60(b))
- Miller v. Haller, 129 Idaho 345 (Idaho, 1996) (unique and compelling circumstances for Rule 60(b))
- Dawson v. Cheyovich Family Trust, 149 Idaho 375 (Idaho, 2010) (application of Rule 60(b) standards to discretionary determinations)