Justia Construction Law Opinion Summaries

In 2002, Defendant David Egan, a business manager for Defendant Foxhollow Construction and Trucking, Inc. (Foxhollow), met with Wayne Johnson of Defendant L.N. Johnson Paving, LLC (Johnson) to discuss a bid for excavation and paving work for a new public high school. Foxhollow wanted to bid on the project but lacked the requisite public works license. Johnson thought its license could cover Foxhollow if the two companies submitted a bid in Johnson's name. Egan submitted a subcontract bid in Johnson’s name to Plaintiff Harris, the general contractor for the school project, and was the successful bidder. Over the course of the business relationship, a contract dispute arose. Harris brought this action, alleging that (1) Foxhollow, Johnson, and another subcontractor breached their subcontracts with Harris. Egan filed a counterclaim for indemnification from Harris. The district court dismissed Foxhollow as a party for lack of proof of notice because there was no indication that Foxhollow was ever served. After a bench trial, the court granted Harris’ motion for "directed verdict" as to Egan’s counterclaim. The court concluded however that Harris failed to prove any of its remaining claims against any of the defendants and therefore was not entitled to relief. The court also awarded fees and costs to Johnson. On appeal to the Supreme Court, Harris argued that the district court: (1) erred in concluding Harris failed to prove contract damages; (2) erred in concluding that no defendant was unjustly enriched; (3) erred in concluding that no defendant is liable for fraud; (4) erred in concluding that Harris was not entitled to indemnity; (5) abused its discretion in denying Harris’ motion to amend findings and conclusion; (6) abused its discretion in granting fees and costs to Johnson; and (7) abused its discretion in denying Harris’ motion for a new trial. Upon review, the Supreme Court affirmed the district court's judgment except for its attorney fee awards, which were vacated. View "Harris, Inc. v. Foxhollow Construction & Trucking, Inc. " on Justia Law

The issue before the Supreme Court in this appeal was the City of Lewiston's rejection of a bid for a public works project on the grounds that the lowest bidder lacked sufficient experience for the project. In 2009, the City of Lewiston (City) advertised for bids to replace the irrigation system at the City golf course. Hillside Landscape Construction, Inc. (Hillside) desired to bid on the project, but prior to doing so it sent a letter to City stating that if City insisted upon having qualifications other than a current Idaho public works license to bid on the project, the City must follow the Category B procedures set forth in the Idaho Code and pre-qualify the bidders. Hillside asked that the qualification of prior experience be removed. City’s attorney denied the request, stating that City’s specifications and bidding process complied with state law. Hillside and four others submitted bids for the project. City notified the bidders that Hillside Landscape Construction submitted the lowest bid but that the company lacked the required experience specified within the bid documents. City awarded the contract to Landscapes Unlimited, the next lowest bidder. Hillside filed a complaint seeking injunctive relief, declaratory relief, and damages. The district court held that City complied with the bidding statutes, vacated a temporary restraining order, denied the motion for an injunction then dismissed Hillside’s complaint. In its review, the Supreme Court found that because the City chose to follow the "Category A" procedures set forth in the Idaho Code rather than the Category B procedures, the district court erred in holding that City could reject the bid on that ground. The Court therefore vacated the judgment of the district court and remanded the case for further proceedings. View "Hillside Landscape Construction, Inc. v. City of Lewiston " on Justia Law

The issue on appeal before the Supreme Court was the grant of summary judgment against Landscapes Unlimited, LLC (LU) in which the district court: (1) applied I.C. 45-508 to postpone LU’s lien claim in golf course property to Hopkins Northwest Fund, LLC’s (Hopkins) deed of trust covering the same, and (2) alternatively apportioned LU’s lien amount. Hopkins filed a complaint in district court seeking to foreclose on its deeds of trust because the borrowers were in default on both promissory notes. Hopkins alleged in the complaint that its interest in the subject properties had priority over LU’s lien claim. LU cross-claimed, alleging that its lien claim was superior to Hopkins’ deeds of trust because LU began work on the project in June 2006 and Hopkins did not record its first deed of trust until August. Accordingly, LU sought to foreclose its lien with respect to the parcels identified in its lien claim. LU filed a motion for summary judgment in December 2008 regarding the validity, superiority, and amount of its lien claim. Hopkins responded that LU’s lien, even if valid, did not have priority over Hopkins’ interest because LU failed to designate what portions of its lien amount are attributed to each parcel or improvement pursuant to I.C. 45-508. LU countered that a single lien claim could be filed, without segregating the amount, when the labor is provided pursuant to a single contract and the work provided amounts to a single improvement. The district court orally ruled that LU’s lien claim on the four parcels at issue was superior to Hopkins’ interest pursuant to I.C. 45-506. Because the Supreme Court found that I.C. 45-508 was inapplicable to LU’s lien claim and that equitable apportionment was not an appropriate alternative remedy where I.C. 45-508 does not apply, the Court vacated the judgment and remanded the case for further proceedings. View "Hopkins Northwest Fund, LLC v. Landscapes Unlimited, LLC " on Justia Law

Plaintiffs Stephen and Marilee Bell hired contractor Defendant Perception Construction Management, Inc. (PCM) to build a log home. The parties' relationship deteriorated, and the Plaintiffs terminated the contract before construction was complete. Plaintiffs refused to pay PCM's final invoices, and PCM filed suit to enforce a lien it placed on the home for the unpaid invoices. Plaintiffs filed multiple counterclaims, including construction defect and breach of contract. PCM prevailed at trial, and the district court found PCM was entitled to damages, prejudgment interest and attorney fees. Plaintiffs appealed, contending that the district court erred by excluding certain evidence relating to their defense against the lien, and in its determination of the monies allegedly owed under the lien. The Supreme Court found that the district court impermissibly excluded Plaintiffs' evidence, and as such, the Court vacated the district court's judgment and remanded the case for further proceedings. View "Perception Construction Management, Inc. v. Bell" on Justia Law