On January 25, 2023, the Court issued a substitute opinion in Easterling v. HAL Pacific Properties. The decision, which was decided 3-2, provides insights into the Court’s views on statutory interpretation and construction. It also addresses actions that fall within Idaho’s catch-all statute of limitations, Idaho Code § 5-224.
The facts. The case concerns landlocked parcels owned by the Easterlings. The Easterlings sued an adjacent landowner, Hal Pacific Properties (“HAL”), claiming an easement by necessity over HAL’s property. The trial court mostly ruled in the Easterlings’ favor on summary judgment and at a bench trial. The trial court rejected HAL’s affirmative defense that the Easterlings’ claims were barred by the statute of limitations set forth in Idaho Code § 5-224, and held that the Easterlings were entitled to an easement by necessity over HAL’s property and set the location and width of the easement. HAL appealed.
The issues. The decision largely centered on whether the catch-all statute of limitations of Section 5-224 applies to an easement by necessity claim. Section 5-224 provides: “An action for relief not hereinbefore provided for must be commenced within four (4) years after the cause of action shall have accrued.” HAL argued that a plain reading of the statute requires its application to an easement by necessity claim, while the Easterlings argued the statute was inapplicable because the claim cannot be time barred. If Section 5-224 does apply to an easement by necessity claim, the issue turned to the accrual of the claim.