Justia Commercial Law Opinion Summaries

Daniel Genho and Riverdale Hot Springs, LLC had a dispute over payment for construction work Genho performed at Riverdale Resort. Genho was not a registered contractor at the start of the project but became registered midway through. Riverdale refused to pay Genho and prevented him from retrieving his tools and materials. Genho filed a Mechanic’s and Materialmen’s Lien and sued for breach of contract, unjust enrichment, quantum meruit, conversion, and to foreclose on the lien.The District Court of the Sixth Judicial District of Idaho granted Riverdale’s motion for a directed verdict on the breach of contract claim but denied it on the other claims. The court found that there were two separate transactions: one before and one after Genho became a registered contractor. The court allowed the jury to consider the unjust enrichment, quantum meruit, conversion, and lien foreclosure claims. The jury found in favor of Genho, awarding him $295,568, which was later reduced to $68,681. The district court also awarded attorney fees to Genho.The Supreme Court of Idaho reviewed the case and affirmed the district court’s decision in part and reversed it in part. The court held that equitable remedies are available under the Idaho Contractor Registration Act (ICRA) for work performed after a contractor becomes registered, provided the work is severable from the unregistered work. The court affirmed the denial of a directed verdict on the unjust enrichment, quantum meruit, and lien foreclosure claims but reversed the award of attorney fees for the conversion claim, as it was not based on a commercial transaction. The court also affirmed the award of attorney fees for the foreclosure action under Idaho Code section 45-513. Neither party was awarded attorney fees on appeal. The judgment was vacated and remanded for modification consistent with the opinion. View "Genho v. Riverdale Hot Springs, LLC" on Justia Law

This case arose from a contract for services between Defendant Erik Partin and Plaintiff Cody Schroeder under which Defendant assembled a specialty car engine for Plaintiff. A jury returned a verdict finding that Defendant assembled the engine improperly and breached the agreement which contained a liquidated damages clause. The district court granted Defendant's motion for judgment notwithstanding the verdict (JNOV), holding that no reasonable jury could find the liquidated damages clause to be valid. The court also awarded attorney fees to both parties. Plaintiff appealed the grant of JNOV and the award of attorney fees to Defendant. Upon review of the trial record, the Supreme Court found there was substantial evidence to support the jury's determination that the performance agreement was enforceable. Therefore, the Court vacated the trial court's grant of JNOV and reversed the lower court's order granting attorney fees to the parties. The Court remanded the case for further proceedings, and awarded attorney fees on appeal to Plaintiff.