Axelrod v. Reid Limited Partnership
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In this case, David W. Axelrod, as Trustee of the David W. Axelrod Family Trust, and Reid Limited Partnership (RLP), along with Michael Reid, an individual, were neighboring landowners in Teton County, Idaho. Axelrod purchased a parcel of land in 2003 that was not accessible by road. Reid, who owned and operated an organic dairy farm nearby, leased land adjacent to Axelrod's parcel. Axelrod had two options for building an access road: build along two easements provided in his deed or build onto an existing dirt road that came through the RLP property. Reid preferred Axelrod to build onto the existing dirt road, which Axelrod did in 2004. However, in 2011, the relationship between Axelrod and Reid began to sour, leading to a series of disputes and legal actions.
The District Court of the Seventh Judicial District, State of Idaho, Teton County, initially concluded that Axelrod did not have an express easement for use of the RLP Easement, but he did have an easement by estoppel. The parties then executed a settlement agreement and stipulated to dismiss the suit. However, disagreements over the implementation of the settlement agreement led to further litigation. The district court granted Axelrod's motion for summary judgment, concluding that Reid, as the nonmoving party, had failed to properly support any assertion of fact or address the assertions of fact in Axelrod’s motion for summary judgment.
On appeal, the Supreme Court of the State of Idaho affirmed the district court's grant of summary judgment against Reid individually and affirmed the district court’s judgment dismissing RLP’s counterclaims for conversion and violation of the implied covenant of good faith and fair dealing. The Supreme Court also affirmed the judgment of the district court on Axelrod’s breach of contract claim and the judgment of the district court refusing to allow amendment of the pleadings to add Reid Family Limited Partnership (RFLP) as a party. However, the Supreme Court vacated the judgment of the district court dismissing RLP’s trespass claim and remanded for further proceedings. The Supreme Court also vacated the attorney fee award as against RLP and remanded for determination of an appropriate fee award at the conclusion of the proceedings.
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