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289 P.3d 43
Idaho
2012
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Background

  • Forest Service permit for a cabin and 0.5 acres in Valley County, Idaho, titled to Ron and Dorothy Arnold.
  • Will of Francis Doyle Arnold gave property to Bette Arnold; Bette signed a 1983 permit transfer form naming Ron, Dorothy, Toni, and Steve Snider.
  • Circumstances of signing disputed; Forest Service issued permit in Arnolds’ name due to policy, contrary to claimed joint ownership.
  • Toni claims Ron told her they would jointly own the cabin and permit; district court found Toni had a confidential relationship with Ron.
  • For over 20 years, Arnolds and Sniders shared use and expenses; 2009 Toni confronted Ron; Sniders filed suit seeking half-interest.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Constructive trust proven by clear and convincing evidence Sniders prove trust via joint ownership representations and conduct No clear and convincing proof of constructive trust affirmed; clear and convincing evidence supports constructive trust
Bette’s intent to transfer to both parties Transfer form and witnesses show intent to gift to both Intent was to transfer to Arnolds alone affirmed; district court’s finding of dual intent not clearly erroneous

Key Cases Cited

  • Hettinga v. Sybrandy, 126 Idaho 467 (Idaho 1994) (constructive trust requires clear and convincing evidence)
  • Weitz v. Green, 148 Idaho 851 (Idaho 2010) (review of factual findings preserved when supported by substantial evidence)
  • Davenport v. Burke, 30 Idaho 599 (Idaho 1917) (constructive trust arises from wrongful actions, not intent)
  • Justad v. Ward, 147 Idaho 509 (Idaho 2009) (credibility and weight of witness testimony within trial court)
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Case Details

Case Name: Steven J. Snider v. Ronald D. Arnold
Court Name: Idaho Supreme Court
Date Published: Nov 15, 2012
Citations: 289 P.3d 43; 2012 Ida. LEXIS 215; 153 Idaho 641; 38572
Docket Number: 38572
Court Abbreviation: Idaho
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