Regdab, Inc. v. Graybill, 444 P.3d 323

Regdab, Inc. supplied building materials to a contractor and recorded a mechanic's lien against the Graybills' property for $5,252.99 among other properties.
Regdab sued Borges and the property owners to foreclose the mechanic's liens, seeking principal, interest, costs, and attorneys' fees under several statutes and I.R.C.P. 54(e); the complaint did not state a specific dollar amount of fees in the event of default.
No answer was filed by the Graybills; Regdab moved for and obtained default, and later moved for default judgment including attorneys' fees and costs.
Graybill tendered payment of the principal plus certain costs before entry of default judgment; Regdab refused the tender and returned the check.
The district court denied Graybill's objection under I.R.C.P. 54(e)(4)(B), ruled the rule conflicted with I.C. § 45-513, awarded $8,134.62 in fees and costs, and ordered sale of the property; Graybill appealed and obtained a stay.
The Idaho Supreme Court reviewed whether Rule 54(e)(4)(B)'s pleading requirement for a specific fee amount in default judgments is inconsistent with I.C. § 45-513.

Issue	Plaintiff's Argument (Regdab)	Defendant's Argument (Graybill)	Held
Whether I.R.C.P. 54(e)(4)(B) requires pleading a specific dollar amount for attorney fees in a default-judgment mechanic's lien action under I.C. § 45-513	Rule 54(e)(4)(B) does not apply because § 45-513 mandates attorney fees, making the rule inconsistent with the statute	Rule 54(e)(4)(B) requires a specific dollar amount in the complaint for fees in the event of default; absence of a number precludes fee award	Held: Rule 54(e)(4)(B) applies; § 45-513 does not provide a method to calculate fees, so the rule’s pleading requirement is not inconsistent with the statute; plaintiff must plead a specific amount for default fees
Whether the district court could cure the pleading deficiency by allowing amendment after default	Amendment would have been permitted and would cure the defect; no prejudice to Graybill	Graybill relied on the complaint lacking a fee amount and chose not to defend; amendment after tender and return of payment would prejudice Graybill	Held: Amendment would have prejudiced Graybill; district court erred in allowing fees without a proper pleading
Whether either party is entitled to appellate attorney fees	Regdab sought fees under I.C. § 12-121 on appeal	Graybill sought appellate fees but cited no statutory or rule basis	Held: No appellate fees awarded to either party (Magleby bars appellate fees where § 45-513 applies; Graybill failed to identify proper authority)

Bailey v. Bailey, 153 Idaho 526 (discusses Rule 54(e) consistency with statutes authorizing fees)
Magleby v. Garn, 154 Idaho 194 (explains pleading specific fee amounts for default judgments and limits on appellate fees under § 45-513)
Campbell v. Parkway Surgery Ctr., LLC, 158 Idaho 957 (standard of review for questions of law)
Credit Suisse AG v. Teufel Nursery, Inc., 156 Idaho 189 (mechanic's-lien attorney-fee award characterized as mandatory under § 45-513)
Franklin Bldg. Supply Co. v. Sumpter, 139 Idaho 846 (discusses § 45-513 fee awards in lien foreclosures)
Elec. Wholesale Supply Co., Inc. v. Nielson, 136 Idaho 814 (treats attorney fees as incidental and mandatory in lien enforcement)
Washington Fed. v. Hulsey, 162 Idaho 742 (requirement that a party claiming fees identify the statutory or rule basis)