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Justia Daily Opinion Summaries

Idaho Supreme Court - Civil
April 18, 2020

Table of Contents

Nampa Hwy Dist #1 v. Knight

Civil Procedure, Government & Administrative Law, Real Estate & Property Law, Zoning, Planning & Land Use

Medrain v. Lee

Civil Procedure

COVID-19 Updates: Law & Legal Resources Related to Coronavirus

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NYU law professors Samuel Estreicher and Jonathan F. Harris describe how the COVID-19 pandemic is forcing the United States to confront the problem of unchecked globalization. Estreicher and Harris argue that once the pandemic subsides, U.S. policymakers should, as a matter of national security, mandate that a minimum percentage of essential supplies be manufactured domestically.

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Idaho Supreme Court - Civil Opinions

Nampa Hwy Dist #1 v. Knight

Dockets: 47029, 47071, 47086

Opinion Date: April 17, 2020

Judge: Moeller

Areas of Law: Civil Procedure, Government & Administrative Law, Real Estate & Property Law, Zoning, Planning & Land Use

Nampa Highway District No. 1 (NHD) brought this action seeking to quiet title to a thirty-three-foot-wide strip of land constituting the south half of West Orchard Avenue in Canyon County, Idaho. NHD claimed that a 1941 deed conveyed the land to NHD. Appellants (defendants-below) argued that because the deed was not recorded until 1989, it did not affect their interests pursuant to the “Shelter Rule,” which protected a purchaser with notice if their predecessor in interest was an innocent purchaser. The district court granted summary judgment in NHD’s favor. After review, the Idaho Supreme Court reversed, finding the district court erred in granting summary judgment when there was a genuine issue of material fact as to what a reasonable investigation by Appellants' predecessors in interest would have revealed. The Supreme Court vacated the district court's declaration that NHD was the fee simple titleholder of the right-of-way, and the matter was remanded for further proceedings.

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Medrain v. Lee

Docket: 46819

Opinion Date: April 17, 2020

Judge: Bevan

Areas of Law: Civil Procedure

This case concerned an attempt by Jade Lee and Golden China, LLC, to appeal a magistrate court decision to the district court. The magistrate court awarded Brian Medrain dba Excellence Heating and Cooling (“Medrain”) damages in a breach of contract action against defendants Bing Lee, Jade Lee, and Golden China, LLC. Bing filed a timely pro se notice of appeal to the district court identifying all three defendants as the appellants; however, the notice of appeal was only signed by Bing as the appellant; neither Jade nor the attorney representing the defendants ever signed the notice of appeal. About ten months later the defendants retained new counsel who filed an amended notice of appeal on behalf of all three defendants. Medrain moved to dismiss the appeal. The district court granted Medrain’s motion in part and held that Jade and Golden China, LLC, did not timely appeal the magistrate court’s judgment. Finding no reversible error, the Idaho Supreme Court affirmed.

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