boundary by agreement doctrine (Idaho) · Go Syfert
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boundary by agreement doctrine in Idaho

15 Idaho opinions name it 2 courts 1984–2024 3 in the last five years

The cases below were cited by Idaho courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (14)

CaseFollowedCited
Downey v. Vavoldgreen
idaho · 2007 · cited in 2 Idaho opinions naming this issue, 2009–2014
2 sentences

2014As we explained in Wells v. Williamson, 118 Idaho 37 , 794 P.2d 626 (1990), ‘boundary by acquiescence’ is simply another name attached to the doctrine of boundary by agreement; it is not a separate legal theory.” Downey v. Vavold, 144 Idaho 592, 595-96 , 166 P.3d 382, 385-86 (2007).

2014As we explained in Wells v. Williamson, 118 Idaho 37 , 794 P.2d 626 (1990), ‘boundary by acquiescence’ is simply another name attached to the doctrine of boundary by agreement; it is not a separate legal theory.” Downey v. Vavold, 144 Idaho 592, 595-96 , 166 P.3d 382, 385-86 (2007).

22
Cameron v. Nealgreen
idaho · 1997 · cited in 2 Idaho opinions naming this issue, 1998–2007
2 sentences

2007Under the doctrine of boundary by agreement, however, “[t]he agreement need not be express, but may be implied by the surrounding circumstances and conduct of the parties.” Cameron v. Neal, 130 Idaho 898, 900 , 950 P.2d 1237, 1240 (1997).

2007Under the doctrine of boundary by agreement, however, “[t]he agreement need not be express, but may be implied by the surrounding circumstances and conduct of the parties.” Cameron v. Neal, 130 Idaho 898, 900 , 950 P.2d 1237, 1240 (1997).

22
Johnson v. Newportgreen
idaho · 1998 · cited in 2 Idaho opinions naming this issue, 2001–2023
2 sentences

2023There are two required elements of a boundary by agreement claim: “(1) [T]here must be an uncertain or disputed boundary, and (2) a subsequent agreement fixing the boundary.” Luce, 142 Idaho at 271 , 127 P.3d at 174 ; see also Johnson v. Newport, 131 Idaho 521, 523 , 960 P.2d 742, 744 (1998).

2023There are two required elements of a boundary by agreement claim: “(1) [T]here must be an uncertain or disputed boundary, and (2) a subsequent agreement fixing the boundary.” Luce, 142 Idaho at 271 , 127 P.3d at 174 ; see also Johnson v. Newport, 131 Idaho 521, 523 , 960 P.2d 742, 744 (1998).

12
Hyde v. Lawsongreen
idaho · 1972 · cited in 2 Idaho opinions naming this issue, 1984–2018
2 sentences

2018Thus, "[w]hile Idaho cases do recognize the doctrine of boundary by agreement, an orally agreed upon boundary cannot constitute the actual boundary between two pieces of property unless the true boundary line is 'unknown to the parties and is uncertain or in dispute.' " Berg , 107 Idaho at 444 , 690 P.2d at 899 (quoting Hyde v. Lawson , 94 Idaho 886 , 889, 499 P.2d 1242 , 1245 (1972) ).

2018Thus, "[w]hile Idaho cases do recognize the doctrine of boundary by agreement, an orally agreed upon boundary cannot constitute the actual boundary between two pieces of property unless the true boundary line is 'unknown to the parties and is uncertain or in dispute.' " Berg , 107 Idaho at 444 , 690 P.2d at 899 (quoting Hyde v. Lawson , 94 Idaho 886 , 889, 499 P.2d 1242 , 1245 (1972) ).

12
Norwood v. Stevensgreen
idahoctapp · 1982 · cited in 2 Idaho opinions naming this issue, 1985–1991
2 sentences

1991Broadhead v. Hawley, 109 Idaho 952 , 712 P.2d 653 (Ct.App.1985); Herrmann v. Woodell, 107 Idaho 916 , 693 P.2d 1118 (Ct.App.1985); Norwood v. Stevens, 104 Idaho 44 , 655 P.2d 938 (Ct.App.1982); Wells v. Williamson, 118 Idaho 48 , 794 P.2d 637 (Ct.App.1989) aff'd 118 Idaho 37 , 794 E.2d 626 (1990). 2 .

1991Broadhead v. Hawley, 109 Idaho 952 , 712 P.2d 653 (Ct.App.1985); Herrmann v. Woodell, 107 Idaho 916 , 693 P.2d 1118 (Ct.App.1985); Norwood v. Stevens, 104 Idaho 44 , 655 P.2d 938 (Ct.App.1982); Wells v. Williamson, 118 Idaho 48 , 794 P.2d 637 (Ct.App.1989) aff'd 118 Idaho 37 , 794 E.2d 626 (1990). 2 .

12
Dreher v. Powellgreen
idahoctapp · 1991 · cited in 1 Idaho opinions naming this issue, 2024–2024
2 sentences

2024The application of the doctrine of boundary by agreement raises “a mixed question of law and fact.” Dreher v. Powell, 120 Idaho 715, 717 , 819 P.2d 569, 571 (Ct. App. 1991).

2024The application of the doctrine of boundary by agreement raises “a mixed question of law and fact.” Dreher v. Powell, 120 Idaho 715, 717 , 819 P.2d 569, 571 (Ct. App. 1991).

11
FLYING ELK INVESTMENT, LLC v. Cornwallgreen
idaho · 2010 · cited in 1 Idaho opinions naming this issue, 2023–2023
2 sentences

2023Flying Elk Inv., LLC v. Cornwall, 149 Idaho 9, 13 , 232 P.3d 330, 334 (2010).

2023Flying Elk Inv., LLC v. Cornwall, 149 Idaho 9, 13 , 232 P.3d 330, 334 (2010).

11
Hindmarsh v. Mockgreen
idaho · 2002 · cited in 1 Idaho opinions naming this issue, 2023–2023
2 sentences

2023Res judicata, or claim preclusion, “bars not only subsequent relitigation of a claim previously asserted, but also subsequent relitigation of any claims relating to the same cause of action which were actually made or which might have been made.” Hindmarsh v. Mock, 138 Idaho 92, 94 , 57 P.3d 803, 805 (2002).

2023Res judicata, or claim preclusion, “bars not only subsequent relitigation of a claim previously asserted, but also subsequent relitigation of any claims relating to the same cause of action which were actually made or which might have been made.” Hindmarsh v. Mock, 138 Idaho 92, 94 , 57 P.3d 803, 805 (2002).

11
Luce v. Marblegreen
idaho · 2005 · cited in 1 Idaho opinions naming this issue, 2023–2023
2 sentences

2023There are two required elements of a boundary by agreement claim: “(1) [T]here must be an uncertain or disputed boundary, and (2) a subsequent agreement fixing the boundary.” Luce, 142 Idaho at 271 , 127 P.3d at 174 ; see also Johnson v. Newport, 131 Idaho 521, 523 , 960 P.2d 742, 744 (1998).

2023There are two required elements of a boundary by agreement claim: “(1) [T]here must be an uncertain or disputed boundary, and (2) a subsequent agreement fixing the boundary.” Luce, 142 Idaho at 271 , 127 P.3d at 174 ; see also Johnson v. Newport, 131 Idaho 521, 523 , 960 P.2d 742, 744 (1998).

11
Weitz v. Greengreen
idaho · 2010 · cited in 1 Idaho opinions naming this issue, 2019–2019
2 sentences

2019See Weitz, 148 Idaho at 860 , 230 P.3d at 752 .

2019See Weitz, 148 Idaho at 860 , 230 P.3d at 752 .

11
O'Malley v. Jonesgreen
idaho · 1928 · cited in 1 Idaho opinions naming this issue, 2009–2009
2 sentences

2009“Boundary by agreement or acquiescence has two elements: (1) there must be an uncertain or disputed boundary and (2) a subsequent agreement fixing the boundary.” Downey v. Vavold, 144 Idaho 592, 595 , 166 P.3d 382, 385 (2007). “[A]n agreement may be presumed to arise between adjoining landowners where such right has been definitely defined by erection of a fence or other monument on the line followed by such adjoining landowners treating it as fixing the boundary for such length of time that neither ought to be allowed to deny the correctness of its location.” Edgeller v. Johnston, 74 Idaho 35

2009“Boundary by agreement or acquiescence has two elements: (1) there must be an uncertain or disputed boundary and (2) a subsequent agreement fixing the boundary.” Downey v. Vavold, 144 Idaho 592, 595 , 166 P.3d 382, 385 (2007). “[A]n agreement may be presumed to arise between adjoining landowners where such right has been definitely defined by erection of a fence or other monument on the line followed by such adjoining landowners treating it as fixing the boundary for such length of time that neither ought to be allowed to deny the correctness of its location.” Edgeller v. Johnston, 74 Idaho 35

11
Edgeller v. Johnstongreen
idaho · 1953 · cited in 1 Idaho opinions naming this issue, 2009–2009
2 sentences

2009“Boundary by agreement or acquiescence has two elements: (1) there must be an uncertain or disputed boundary and (2) a subsequent agreement fixing the boundary.” Downey v. Vavold, 144 Idaho 592, 595 , 166 P.3d 382, 385 (2007). “[A]n agreement may be presumed to arise between adjoining landowners where such right has been definitely defined by erection of a fence or other monument on the line followed by such adjoining landowners treating it as fixing the boundary for such length of time that neither ought to be allowed to deny the correctness of its location.” Edgeller v. Johnston, 74 Idaho 35

2009“Boundary by agreement or acquiescence has two elements: (1) there must be an uncertain or disputed boundary and (2) a subsequent agreement fixing the boundary.” Downey v. Vavold, 144 Idaho 592, 595 , 166 P.3d 382, 385 (2007). “[A]n agreement may be presumed to arise between adjoining landowners where such right has been definitely defined by erection of a fence or other monument on the line followed by such adjoining landowners treating it as fixing the boundary for such length of time that neither ought to be allowed to deny the correctness of its location.” Edgeller v. Johnston, 74 Idaho 35

11
Morrissey v. Haleygreen
idaho · 1993 · cited in 1 Idaho opinions naming this issue, 2009–2009
2 sentences

2009“Boundary by agreement or acquiescence has two elements: (1) there must be an uncertain or disputed boundary and (2) a subsequent agreement fixing the boundary.” Downey v. Vavold, 144 Idaho 592, 595 , 166 P.3d 382, 385 (2007). “[A]n agreement may be presumed to arise between adjoining landowners where such right has been definitely defined by erection of a fence or other monument on the line followed by such adjoining landowners treating it as fixing the boundary for such length of time that neither ought to be allowed to deny the correctness of its location.” Edgeller v. Johnston, 74 Idaho 35

2009“Boundary by agreement or acquiescence has two elements: (1) there must be an uncertain or disputed boundary and (2) a subsequent agreement fixing the boundary.” Downey v. Vavold, 144 Idaho 592, 595 , 166 P.3d 382, 385 (2007). “[A]n agreement may be presumed to arise between adjoining landowners where such right has been definitely defined by erection of a fence or other monument on the line followed by such adjoining landowners treating it as fixing the boundary for such length of time that neither ought to be allowed to deny the correctness of its location.” Edgeller v. Johnston, 74 Idaho 35

11
Lindgren v. Martingreen
idaho · 1997 · cited in 1 Idaho opinions naming this issue, 1998–1998
2 sentences

1998On appeal, “[a] trial court’s findings of fact in a court-tried case will be liberally construed on appeal in favor of the judgment entered, in view of the trial court’s role as trier of fact.” Lindgren v. Martin, 130 Idaho 854, 857 , 949 P.2d 1061, 1064 (1997).

1998On appeal, “[a] trial court’s findings of fact in a court-tried case will be liberally construed on appeal in favor of the judgment entered, in view of the trial court’s role as trier of fact.” Lindgren v. Martin, 130 Idaho 854, 857 , 949 P.2d 1061, 1064 (1997).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Wells v. Williamson green
idaho · 1990
2 sentences

2014As we explained in Wells v. Williamson, 118 Idaho 37 , 794 P.2d 626 (1990), ‘boundary by acquiescence’ is simply another name attached to the doctrine of boundary by agreement; it is not a separate legal theory.” Downey v. Vavold, 144 Idaho 592, 595-96 , 166 P.3d 382, 385-86 (2007).

2014As we explained in Wells v. Williamson, 118 Idaho 37 , 794 P.2d 626 (1990), ‘boundary by acquiescence’ is simply another name attached to the doctrine of boundary by agreement; it is not a separate legal theory.” Downey v. Vavold, 144 Idaho 592, 595-96 , 166 P.3d 382, 385-86 (2007).

31991–2014
Trappett v. Davis green
idaho · 1981
2 sentences

1998Trappett v. Davis, 102 Idaho 527 , 633 P.2d 592 (1981). 130 Idaho 898, 901 , 950 P.2d 1237, 1240 (1997).

1998Trappett v. Davis, 102 Idaho 527 , 633 P.2d 592 (1981). 130 Idaho 898, 901 , 950 P.2d 1237, 1240 (1997).

31985–1998
HUSKINSON v. Nelson green
idaho · 2012
2 sentences

2023From there, the district court, again quoting Huskinson v. Nelson, 152 Idaho 547 , 550–51, 272 P.3d 519 , 522–23 (2012), set out the legal requirements of the boundary by agreement doctrine 13 and explained how the existence of a long-established fence creates two presumptions satisfying those requirements: A boundary by agreement requires two things: (1) an uncertain or disputed legal boundary and (2) an agreement between neighboring landowners as to what will be the boundary.

2023From there, the district court, again quoting Huskinson v. Nelson, 152 Idaho 547 , 550–51, 272 P.3d 519 , 522–23 (2012), set out the legal requirements of the boundary by agreement doctrine 13 and explained how the existence of a long-established fence creates two presumptions satisfying those requirements: A boundary by agreement requires two things: (1) an uncertain or disputed legal boundary and (2) an agreement between neighboring landowners as to what will be the boundary.

12023–2023
Berg v. Fairman green
idaho · 1984
2 sentences

2018Thus, "[w]hile Idaho cases do recognize the doctrine of boundary by agreement, an orally agreed upon boundary cannot constitute the actual boundary between two pieces of property unless the true boundary line is 'unknown to the parties and is uncertain or in dispute.' " Berg , 107 Idaho at 444 , 690 P.2d at 899 (quoting Hyde v. Lawson , 94 Idaho 886 , 889, 499 P.2d 1242 , 1245 (1972) ).

2018Thus, "[w]hile Idaho cases do recognize the doctrine of boundary by agreement, an orally agreed upon boundary cannot constitute the actual boundary between two pieces of property unless the true boundary line is 'unknown to the parties and is uncertain or in dispute.' " Berg , 107 Idaho at 444 , 690 P.2d at 899 (quoting Hyde v. Lawson , 94 Idaho 886 , 889, 499 P.2d 1242 , 1245 (1972) ).

12018–2018
Broadhead v. Hawley neutral
idahoctapp · 1985
2 sentences

1991Broadhead v. Hawley, 109 Idaho 952 , 712 P.2d 653 (Ct.App.1985); Herrmann v. Woodell, 107 Idaho 916 , 693 P.2d 1118 (Ct.App.1985); Norwood v. Stevens, 104 Idaho 44 , 655 P.2d 938 (Ct.App.1982); Wells v. Williamson, 118 Idaho 48 , 794 P.2d 637 (Ct.App.1989) aff'd 118 Idaho 37 , 794 E.2d 626 (1990). 2 .

1991Broadhead v. Hawley, 109 Idaho 952 , 712 P.2d 653 (Ct.App.1985); Herrmann v. Woodell, 107 Idaho 916 , 693 P.2d 1118 (Ct.App.1985); Norwood v. Stevens, 104 Idaho 44 , 655 P.2d 938 (Ct.App.1982); Wells v. Williamson, 118 Idaho 48 , 794 P.2d 637 (Ct.App.1989) aff'd 118 Idaho 37 , 794 E.2d 626 (1990). 2 .

11991–1991
Wells v. Williamson neutral
idahoctapp · 1989
2 sentences

1991Broadhead v. Hawley, 109 Idaho 952 , 712 P.2d 653 (Ct.App.1985); Herrmann v. Woodell, 107 Idaho 916 , 693 P.2d 1118 (Ct.App.1985); Norwood v. Stevens, 104 Idaho 44 , 655 P.2d 938 (Ct.App.1982); Wells v. Williamson, 118 Idaho 48 , 794 P.2d 637 (Ct.App.1989) aff'd 118 Idaho 37 , 794 E.2d 626 (1990). 2 .

1991Broadhead v. Hawley, 109 Idaho 952 , 712 P.2d 653 (Ct.App.1985); Herrmann v. Woodell, 107 Idaho 916 , 693 P.2d 1118 (Ct.App.1985); Norwood v. Stevens, 104 Idaho 44 , 655 P.2d 938 (Ct.App.1982); Wells v. Williamson, 118 Idaho 48 , 794 P.2d 637 (Ct.App.1989) aff'd 118 Idaho 37 , 794 E.2d 626 (1990). 2 .

11991–1991
Herrmann v. Woodell green
idahoctapp · 1985
2 sentences

1991Broadhead v. Hawley, 109 Idaho 952 , 712 P.2d 653 (Ct.App.1985); Herrmann v. Woodell, 107 Idaho 916 , 693 P.2d 1118 (Ct.App.1985); Norwood v. Stevens, 104 Idaho 44 , 655 P.2d 938 (Ct.App.1982); Wells v. Williamson, 118 Idaho 48 , 794 P.2d 637 (Ct.App.1989) aff'd 118 Idaho 37 , 794 E.2d 626 (1990). 2 .

1991Broadhead v. Hawley, 109 Idaho 952 , 712 P.2d 653 (Ct.App.1985); Herrmann v. Woodell, 107 Idaho 916 , 693 P.2d 1118 (Ct.App.1985); Norwood v. Stevens, 104 Idaho 44 , 655 P.2d 938 (Ct.App.1982); Wells v. Williamson, 118 Idaho 48 , 794 P.2d 637 (Ct.App.1989) aff'd 118 Idaho 37 , 794 E.2d 626 (1990). 2 .

11991–1991
Downing v. Boehringer green
idaho · 1960
2 sentences

1984As has been stated, “Where the location of a true boundary line between coterminous owners is known to either of the parties, or is not uncertain, and is not in dispute, an oral agreement between them purporting to establish another line as the boundary between their properties constitutes an attempt to convey real property in violation of the statute of frauds ... and is invalid.” Gameson v. Remer, supra at 791, 537 P.2d at 633 ; Downing v. Boehringer, 82 Idaho 52 , 349 P.2d 306 (1960).

1984As has been stated, “Where the location of a true boundary line between coterminous owners is known to either of the parties, or is not uncertain, and is not in dispute, an oral agreement between them purporting to establish another line as the boundary between their properties constitutes an attempt to convey real property in violation of the statute of frauds ... and is invalid.” Gameson v. Remer, supra at 791, 537 P.2d at 633 ; Downing v. Boehringer, 82 Idaho 52 , 349 P.2d 306 (1960).

11984–1984
Gameson v. Remer green
idaho · 1975
2 sentences

1984As has been stated, “Where the location of a true boundary line between coterminous owners is known to either of the parties, or is not uncertain, and is not in dispute, an oral agreement between them purporting to establish another line as the boundary between their properties constitutes an attempt to convey real property in violation of the statute of frauds ... and is invalid.” Gameson v. Remer, supra at 791, 537 P.2d at 633 ; Downing v. Boehringer, 82 Idaho 52 , 349 P.2d 306 (1960).

1984As has been stated, "Where the location of a true boundary line between coterminous owners is known to either of the parties, or is not uncertain, and is not in dispute, an oral agreement between them purporting to establish another line as the boundary between their properties constitutes an attempt to convey real property in violation of the statute of frauds ... and is invalid." Gameson v. Remer, supra at 791, 537 P.2d at 633 ; Downing v. Boehringer, 82 Idaho 52 , 349 P.2d 306 (1960).

11984–1984

Statutes the citing opinions construe

ID § Idaho Code § 12-121 (9) ID § Idaho Code § 6-202 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

ID 15 (1984–2024) UT 4 (1979–2025) OR 3 (1983–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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