Nampa Highway District No. 1 v. Knight
Idaho Supreme Court
462 P.3d 137 (2020)
- Written by Eric Miller, JD
Facts
In 1941, Nampa Highway District No. 1 (NHD) (plaintiff) obtained a right-of-way deed to a strip of land on either side of a road. However, NHD did not record the deed until 1989. In the interim, adjacent parcels of land were conveyed by deeds that did not mention the right-of-way. Later, NHD brought suit against relevant property owners, including Brian and Lisa Knight and Manuel and Maria Dominguez (collectively, the property owners) (defendants) to quiet title to the strip of land conveyed in 1941. The property owners argued that their predecessors in interest were innocent bona fide purchasers—i.e., purchasers who had no reason to know about the right-of-way deed—thus invoking the protection of the shelter rule, which extended bona-fide-purchaser status to subsequent owners. NHD argued that the shelter rule did not apply because the very existence of the road put the property owners’ predecessors on constructive notice of the likelihood of a right-of-way. The trial included no explanation for NHD’s nearly 48-year delay in recording the right-of-way deed. The district court granted summary judgment in favor of NHD. The property owners appealed to the Idaho Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Moeller, J.)
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