Safaris Unlimited v. Mike Von Jones
158 Idaho 846
| Idaho | 2015Background
- Safaris Unlimited, a Georgia LLC, operates as HHK's booking agent for big-game hunts; Jones hunted in 2012 in Zimbabwe and was invoiced $26,040 by Safaris Unlimited.
- Jones disputed and did not pay; Safaris Unlimited filed suit for breach of contract seeking $26,040 plus interest; Jones claimed no contract with SU, only with HHK, and asserted offsets.
- Safaris Unlimited portrayed itself as the contract-closer, managing deposits, balances, and trophy fees; HHK was the hunting provider; the parties’ financial arrangement favored SU collecting the client’s payments and passing funds to HHK.
- The district court granted summary judgment to Safaris Unlimited, concluding Jones owed $26,040 and that SU could sue Jones under the ICAA; the court treated trophy-offset defenses as non-meritorious.
- Jones argued the 2012 invoice signature did not establish a contract with SU; he also argued he was entitled to offsets for trophy items from 2010 and 2012 and that SU was acting as a debt collector.
- On appeal, the Idaho Supreme Court vacated the district court's judgment and remanded for further proceedings, awarding costs to Jones but not attorney's fees at this stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Existence of contract between Jones and Safaris Unlimited for 2012 hunt | Jones signed the 2012 invoice, implying SU contract. | Jones had a contract with HHK, not SU; the signature does not prove a contract with SU. | Contract existence disputed; summary judgment improper; remand. |
| Entitlement to offsets for trophy items against amount owed | Offsets for 2012 and 2010 trophy items possible; record supports offsets. | No contractual obligation to deliver or value-shipment of trophies; offsets not proven. | Offsets require contractual basis; remand on offset issues. |
| Suit under Idaho Collection Agency Act (ICAA) applicability | SU acted as collection agent, potentially exempt under ICAA. | SU is not prohibited from collection duties or is exempt; remains undecided. | ICAA applicability unresolved; remand. |
| Whether attorney's fees should be awarded on appeal | Prevailing-party fee entitlement under statutes. | Fees premature; outcome not decided. | Attorney's fees on appeal not decided; remand. |
Key Cases Cited
- Mosell Equities, LLC v. Berryhill & Co., 154 Idaho 269 (Idaho 2013) (breach of contract elements; standard for damages and contract existence)
- Nix v. Elmore Cnty., 346 P.3d 1045 (Idaho 2015) (contract existence as a factual issue for the jury when conflicting evidence exists)
- Bettwieser v. N.Y. Irrigation Dist., 153 Idaho 317 (Idaho 2013) (formation of contract; meeting of minds as mutual intent)
- Arregui v. Gallegos-Main, 291 P.3d 1000 (Idaho 2012) (standard of review for summary judgment; liberal construction in favor of non-movant)
- Lapham v. Stewart, 51 P.3d 396 (Idaho 2002) (summary judgment standard; determine if any genuine issue of material fact exists)
- Spokane Structures, Inc. v. Equitable Inv., LLC, 226 P.3d 1263 (Idaho 2010) (prematurity in attorney's fees determination on appeal)