Bettwieser v. New York Irrigation Dist.
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Pro se plaintiff Martin Bettwieser brought a breach of contract action against the New York Irrigation District and its directors (collectively, the District). Bettwieser alleged that the District breached an oral contract by not timely providing him with a legal opinion regarding whether he could be excluded from the irrigation district without paying statutory exclusion and filing fees. Following a bench trial, the district court issued findings of fact and conclusions of law, ruling that Bettwieser had failed to demonstrate that he was entitled to relief. Bettwieser appealed, alleging the district court made errors of fact and law during the trial and in its decisions regarding Bettwieser's pre- and post-trial motions. As a preliminary matter, the Supreme Court noted that Bettwieser's briefing was, "at best, difficult to follow. In some cases, it is unclear what issue Bettwieser is attempting to raise. And, even where an issue is identifiable, argument, authority, and legal reasoning are often absent." The Court concluded that the district court's findings of fact and conclusions of law were supported by substantial competent evidence. Bettwieser failed to satisfy the requirements for certification of a class action. The district court was not obligated to consider claims not raised by the pleadings. The district court did not abuse its discretion in denying Bettwieser's motion to disqualify counsel. Bettwieser was not entitled to declaratory judgment because he failed to demonstrate the existence of an actual or justiciable controversy.
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