Belk v. Martin, 136 Idaho 652

Summary

The Idaho Supreme Court reviewed a judgment reforming a farm lease to correct a unilateral mistake in the stated rental amount. The court held that extrinsic evidence was admissible because the defendant knew of the mistake, affirmed reformation of the lease, upheld prejudgment interest, and dismissed a quasi-estoppel defense. Attorney fees and costs on appeal were awarded to the respondents.

Holdings

1. Extrinsic evidence is admissible to show that a written contract contains a unilateral mistake when the other party knew of the mistake and the writing does not reflect the parties' true intent.
2. A written agreement may be reformed when one party made a unilateral mistake and the other party knew of the mistake, even when the mistake resulted from negligence.
3. Martin did not establish quasi-estoppel because the record did not show an agreed multi-year lease or that he suffered a severe disadvantage by changing his crop plans.
4. The district court did not abuse its discretion by awarding prejudgment interest without an offset for interest that might have been earned on disputed funds because Martin failed to provide an adequate appellate record showing error.
5. The respondents, as the prevailing parties, were entitled to attorney fees and costs on appeal under Idaho Code section 12-120(3) and Idaho Appellate Rule 41.

Questions Presented

1. Whether substantial and competent evidence supported the finding that Martin knew of the lessors' unilateral mistake in the lease's rental provision.
2. Whether the district court properly admitted extrinsic evidence and denied Martin's motion in limine.
3. Whether the district court properly reformed the lease based on the lessors' unilateral mistake and Martin's knowledge of that mistake.
4. Whether Martin established a quasi-estoppel defense.
5. Whether the district court abused its discretion by awarding prejudgment interest without offsetting interest that could have been earned on disputed funds.
6. Whether either party was entitled to attorney fees on appeal.

Disposition

affirmed