Val and Laree Westover v. Jase Cundick, 393 P.3d 593

Val and LaRee Westover entered a purchase contract for a family farm in 2007 and recorded a memorandum of the real estate contract; subsequent recorded instruments and a 2012 warranty deed caused Franklin County assessor records to list others (including a trust) as owners.
In March–April 2015 the Westovers granted and recorded an underground right-of-way easement to Rocky Mountain Power and installed equipment after paying for service.
On May 29, 2015 Franklin County Assessor Jase Cundick sent a letter (based on his office’s records) to Rocky Mountain Power and the Westovers asserting the Westovers did not own the property; Rocky Mountain Power threatened to disconnect service unless the issue was corrected.
The Westovers obtained a recorded quitclaim/deed in June 2015 causing assessor records to be updated to show the Westovers as owners; Cundick retracted his letter in December 2015 after continued dispute and mediation.
The Westovers sued Cundick (individually and officially) seeking writs of mandate and prohibition, slander of title, and tortious interference; they later dismissed the tort claims and asked the district court for the extraordinary writs, which the court denied as alternative legal remedies were available.
The Westovers appealed, arguing the district court erred by refusing injunctive relief and by not sua sponte granting relief under Idaho Rule of Civil Procedure 54(c); the Idaho Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court erred in denying writs of mandate/prohibition and injunctive relief preventing assessor from sending letters about ownership	Westover: District court should have granted injunctive relief to prevent further letters harming property rights and commercial relations	Cundick: Extraordinary writs were inappropriate because adequate remedies (including injunctive relief) existed at law; no clear legal duty requiring retraction	Held: No error; writs properly denied because plain, speedy, adequate remedies existed and injunctive relief was an available remedy so extraordinary writs were not warranted
Whether the district court had a duty under I.R.C.P. 54(c) to sua sponte grant injunctive relief not requested in pleadings	Westover: Rule 54(c) and McKay support courts granting relief a party is entitled to even if not demanded, so court should have granted injunction sua sponte	Cundick: Rule 54(c) does not obligate the court to grant relief to a party when the judgment was not rendered in their favor; McKay does not support a duty to sua sponte grant relief	Held: No duty to sua sponte grant relief; Rule 54(c) applies to the party in whose favor judgment is rendered and McKay was misread by Westovers

Butters v. Hauser, 131 Idaho 498 (Idaho 1998) (existence of adequate legal remedy bars issuance of writ of mandamus)
Edwards v. Industrial Comm’n of State, 130 Idaho 457 (Idaho 1996) (same principle regarding writs and adequate remedies)
Wasden ex rel. State v. Idaho State Bd. of Land Comm’rs, 150 Idaho 547 (Idaho 2011) (availability of injunctive relief defeats writ of prohibition)
McKay Constr. Co. v. Ada County Bd. of County Comm’rs, 99 Idaho 235 (Idaho 1978) (discussed in context of potential injunctive relief though did not require sua sponte relief under Rule 54(c))
Fuchs v. State, Dep’t of Idaho State Police, 152 Idaho 626 (Idaho 2012) (party not entitled to attorney fees on issues of first impression)
Lane Ranch P’ship v. City of Sun Valley, 145 Idaho 87 (Idaho 2006) (same rule about first-impression issues and attorney fees)