Rocky Mountain Power v. Stanley K. Jensen, 154 Idaho 549

Idaho Supreme Court reviewed district court’s summary judgment in an eminent domain action by Rocky Mountain Power against Stanley and Catherine Jensen as trustees of the Jensen Family Living Trust.
The Utility sought a perpetual easement and right of way to construct a 150-foot-wide high-voltage transmission corridor through the Jensens’ 640-acre cattle ranch near Malad, Idaho, affecting two parcels and an access road.
An Occupancy Agreement paid the Jensens $215,630, to be deducted from final just-compensation, and set Oct. 10, 2008 as the date of value for fair market valuation.
The Occupancy Agreement waived defenses to the acquisition except the just-compensation claim; if not agreed within 60 days, compensation would be determined by court proceedings.
The district court granted summary judgment, holding the Jensens had not offered competent evidence of just compensation beyond the Utility’s appraisals, and later awarded $162,000 (the amount Owens and Cook valued) as the just compensation already paid under the Occupancy Agreement.
On appeal, the Idaho Supreme Court affirmed, denying additional damages and costs to the Jensens and awarding costs to the Utility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jensens showed a genuine issue of material fact on just compensation	Jensens contended December 4th Letter, June 29th Pseudo-Affidavit, and Answering Brief raised issues of value beyond the appraisals.	Utility argued no admissible evidence supported a higher fair-market value; occupancy payment already set value.	No genuine issue; evidence insufficient to surpass summary judgment.
Whether district court abused its discretion denying reconsideration	New affidavits and statements should create material factual issues.	No new facts established a genuine issue; appraisals remained within the established range.	No abuse of discretion; reconsideration denied.
Whether appraisals and date of value complied with I.C. 7-711 and Occupancy Agreement	Appraisals should reflect higher best use and date of value; occupied funds not final value.	Appraisals supported by competent evidence; date of value consistent with agreement.	No error; district court properly awarded the amount paid under the Occupancy Agreement as just compensation.

Ada Cnty. Hwy. Dist. v. Magwire, 104 Idaho 656 (Idaho 1983) (establishes fair market value standard for eminent domain; excluding listing price evidence)
City of McCall v. Seubert, 142 Idaho 580 (Idaho 2006) (appraisers’ methods; range of values admissible under §7-711)
Ivan H. Talbot Family Trust, 120 Idaho 825 (Idaho 1991) (range of appraisal values; not solely determinative of value)
State ex rel. Rich v. McGill, 79 Idaho 467 (Idaho 1958) (burden on landowner to prove just compensation)
Farr W. Inv. v. Topaz Mktg., 148 Idaho 272 (Idaho 2009) (evidence of listing/asking price not admissible; focus on fair market value)
Blackmore v. Re/Max Tri-Cities, L.L.C., 149 Idaho 558 (Idaho 2010) (discretionary review of reconsideration; reasoned decision required)
Jordan v. Beeks, 135 Idaho 586 (Idaho 2001) (multifactor test for abuse of discretion in reconsideration)
Suitts v. Nix, 141 Idaho 706 (Idaho 2005) (pro se litigants held to same standards as represented parties)