WATKINS CO., LLC v. Storms
152 Idaho 531
| Idaho | 2012Background
- Watkins filed a ten-count breach/eviction suit against Storms and Burggraf under a 30-year commercial lease for Brownstone in Idaho Falls.
- District court found Storms and Burggraf materially breached by unpaid rent, unjust enrichment from storage, and an unconscionable accelerated rent clause.
- Addendums required 5% of gross sales to rent if higher than base rent and allocated roof maintenance costs.
- Storms' use of an upstairs storage area was disputed; initial $100/month rent was later escalated to $750/month, with the court finding an unwritten, initial agreement of $100/month.
- Court ruled on multiple issues: enforceability of jury-trial waiver, accord and satisfaction defenses, upstairs storage rent, liquidated damages, and awarded no attorney fees; vacated some damages on storage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the district court properly enforce the jury-trial waiver? | Storms argues waiver was modified by demand for jury trial. | Watkins argues waiver remained in effect; no written modification. | Yes; district court correctly enforced the jury-trial waiver. |
| Was there accord and satisfaction regarding three-day rent notices? | Storms contends notices satisfied accord and satisfaction. | Watkins contends no conspicuous full-satisfaction statement. | No accord and satisfaction; notices did not satisfy the four elements. |
| Did IC 55-307(1) apply to upstairs storage rent as a change of lease terms? | Storms contends storage rate change was a tenancy change. | Watkins argues unwritten agreement; district court applied statute. | Statute not applicable to termination/adjustment; vacate damages for storage accordingly. |
| Was the liquidated damages provision recoverable given damages proof? | Watkins sought recovery under liquidated damages for future rent. | Storms contends damages insufficiently proven and provision unenforceable. | Damages not awarded due to lack of present-value proof; provision upheld in result but not awarded. |
| Should either party recover attorney fees on appeal? | Both party seeks fees under I.C. 12-120(3). | Neither party is prevailing on all issues. | No attorney fees awarded on appeal. |
Key Cases Cited
- Kimbrough v. Reed, 130 Idaho 512 (1997) (written contract governs; extrinsic evidence not admissible to vary terms)
- Valley Bank v. Christensen, 119 Idaho 496 (1991) (extrinsic evidence cannot alter unambiguous written contract)
- Ore-Ida Potato Prod., Inc. v. Larsen, 83 Idaho 290 (1961) (mutual consent required to modify contract terms)
- Res. Eng'g, Inc. v. Siler, 94 Idaho 935 (1972) (modification by conduct; implied meeting of minds possible)
- Shore v. Peterson, 146 Idaho 903 (2009) (elements of accord and satisfaction with negotiable instrument)
- W.L. Scott, Inc. v. Madras Aerotech, Inc., 103 Idaho 736 (1982) (present value of damages; discount rate fact-finding)
- Cranney v. Mut. of Enumclaw Ins. Co., 145 Idaho 6 (2007) (present value; damages proof requirements in contract cases)
- Griffith v. Clear Lakes Trout Co., 146 Idaho 613 (2009) (sustaining conclusions of law despite findings of fact; standard of review)
- Harris, Inc. v. Foxhollow Const. & Trucking, Inc., 151 Idaho 761 (2011) (damages proof and calculation standards in contract cases)
- Nampa & Meridian Irr. Dist. v. Mussell, 139 Idaho 28 (2003) (general rule for appellate review of trial court decisions)