Peterson v. Gentillon

Summary

The Idaho Supreme Court addresses a quiet title dispute involving exchanged parcels of riparian and agricultural land, a center-pivot irrigation easement, and road access rights. The court holds that the statute of limitations did not bar the Partnership’s specific-performance claim concerning property in its possession and concludes that the district court erred in awarding the southern 50-foot strip to the Petersons. The court also remands for further proceedings concerning the width of the road easement and reviews restrictions on irrigation water affecting that easement.

Holdings

1. The five-year statute of limitations in Idaho Code section 5-216 does not bar a claimant who purchased real property and remains in possession from asserting specific performance; the limitations period does not begin to run until the claimant's possession is interrupted.
2. The district court erred in finding that the Partnership failed to establish a resulting trust in the southern 50-foot strip of T-10032.
3. Although the district court could specify the easement's dimensions in a quiet-title judgment, the record did not support defining the Petersons' easement as 30 feet wide.
4. The district court erred by prohibiting the Partnership from intermittently spraying water on the road subject to the Petersons' access easement where the court found that the spraying did not materially impede the Petersons' use of the road.
5. No party was entitled to attorney fees on appeal.

Questions Presented

1. Whether the five-year statute of limitations for actions arising from contracts barred the Partnership's claim for specific performance of the 1998 agreement.
2. Whether the Partnership established a resulting trust in the southern 50-foot strip of T-10032 extending through the BLM Lot.
3. Whether the district court properly defined the Petersons' road-access easement as 30 feet wide.
4. Whether the district court properly prohibited the Partnership from allowing its center pivot to spray water on the road subject to the Petersons' access easement.
5. Whether any party was entitled to attorney fees on appeal.

Disposition

reversed_and_remanded