Burke v. Baugh

CourtIdaho Court of Appeals
DecidedOctober 27, 2025
Docket52429
StatusPublished

This text of Burke v. Baugh (Burke v. Baugh) is published on Counsel Stack Legal Research, covering Idaho Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Burke v. Baugh, (Idaho Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 52429

E. JAMES BURKE, power of attorney for ) DIANE BURKE WALKER, an ) Opinion Filed: October 27, 2025 incapacitated person, ) ) Melanie Gagnepain, Clerk Plaintiffs-Counterdefendants- ) Respondents, ) ) v. ) ) JEFFREY BAUGH and JANICE ) ORMSBY BAUGH, husband and wife, ) ) Defendants-Counterclaimants- ) Appellants. ) )

Appeal from the District Court of the First Judicial District, State of Idaho, Bonner County. Hon. Lamont C. Berecz, District Judge.

Judgment granting summary judgment, affirmed.

Skullnah Legal Service, PLLC; Christine Mellick, Spokane, Washington, for appellants. Christine Mellick argued.

Sandpoint Law, P.C.; D. Toby McLaughlin, Sandpoint, for respondents. Toby McLaughlin argued. ________________________________________________

HUSKEY, Judge This appeal arises from a dispute involving two easements on the property of Diane Burke Walker located in Bonner County, Idaho. Walker’s Power of Attorney (POA), E. James Burke, argues the easements are invalid because of Walker’s incapacity and Jeffery Baugh’s and Janice Ormsby Baugh’s (collectively “the Baughs”) exercise of undue influence over Walker. The Baughs argue Walker, their long-term neighbor, validly granted them the easements and had the mental capacity to do so. We affirm the district court’s judgment granting summary judgment.

1 I. FACTUAL AND PROCEDURAL BACKGROUND The Baughs and Walker both own real property located in Hope, Idaho. As depicted below, Walker’s property has direct access to Lake Pend Oreille, but the Baughs’ property, which is located south of Walker’s, does not.

Aerial view of Walker’s property and the Baughs’ property. Walker primarily used the residence on her property as a vacation home, while the Baughs live in their residence year-round. Because the Baughs were there year-round, they would watch over Walker’s property while she was away and the Baughs and Walker were long-time friends. In early May 2023, friends and family initiated a welfare check on Walker at her home after she stopped responding to phone calls and text messages. Walker, then eighty-four years old, was found alone in her home with no food and was “too weak to walk or even stand up.” Walker was admitted to a skilled nursing facility. Nursing staff kept notes on Walker’s condition throughout May and June, which detail her struggles with mental cognition and physical capabilities. Walker needed assistance with activities of daily living. On multiple occasions, staff entered her room and found Walker on the floor, unable to get up.

2 On June 12, the Baughs drove approximately 140 miles from their home to the nursing facility to see Walker. During their visit, the Baughs had Walker sign documents granting them two easements. The Baughs had Walker’s signature notarized by a notary they found at the facility. The first easement, titled “Easement for Lake Pump and Waterlines,” gave the Baughs permission to construct a pump house on Walker’s property and install a pump to draw water from the lake. The agreement granted both Walker and the Baughs the ability to use the water. The Baughs agreed to pay for initial costs for the infrastructure of the pump, pump house, power service, and waterlines from the lake, while each party would be separately responsible to install, maintain, and repair the service lines to each property. The costs of all future repairs and maintenance for the pump house and pump would be shared equally. The pump house was built and the pump installed. The second easement, titled “Dock Easement,” gave the Baughs permission to construct a dock for shared lake access on Walker’s property. The Baughs agreed to pay for the “initial costs of construction.” The easement included the right for both the Baughs and Walker to dock one boat overnight and for the Baughs to install a boat lift on their side of the dock. After the initial construction, the costs to maintain, improve, repair, or replace the dock were to be shared equally between the Baughs and Walker. Both easements contained provisions that the easements shall run with the land and bind all successor owners of the land, regardless of how title was obtained. At the time the complaint was filed, the dock had not been built. Upon discovering the easements, Burke, Walker’s nephew and POA,1 sent a letter to the Baughs through an attorney. The letter informed the Baughs that Burke was Walker’s POA, and he has been since 2014. The letter asserted that at the time the easements were signed, Walker did not legally possess the mental capacity to grant the easements. The letter requested a return of enclosed “Release of Easements” by September 20. If the easements were released, Burke indicated he would execute a valid easement for the lake pump and waterlines. If the easements were not released, Burke informed the Baughs that he would seek to invalidate the easements due to Walker’s incapacity. The releases were not returned, and Burke filed suit against the Baughs. Therein, Burke sought to have the easements canceled and rescinded on the grounds that: (1) Walker lacked the mental capacity to grant the easements; (2) the easements were the result of undue influence from

1 The document establishing Burke as Walker’s power of attorney does not appear in the record. However, Burke’s status as Walker’s POA is not disputed by the Baughs.

3 the Baughs; (3) enforcement of the easements would be unconscionable; and (4) the easements unjustly enrich the Baughs. Burke served the Baughs with his first discovery request including interrogatories, requests for production, and requests for admission. Approximately two months later and after getting no response, Burke filed a motion for summary judgment. In support of his motion, Burke filed a memorandum and attached three affidavits. The first affidavit was from Dr. Jameson Lontz, Ph.D., a licensed psychologist; the second was from local real estate agent Becky Freeland; and the third was from Burke. Also attached was the property assessment notice of Walker’s property from the Bonner County Assessor, which valued her property at $1,242,015.00. Dr. Lontz is the Executive Director of Blue Mountain Neuropsychological Associates (Blue Mountain). Blue Mountain performs clinical forensic, psychological, and neuropsychological assessments. Dr. Lontz evaluated Walker at the nursing facility in March 2024. In his evaluation, Dr. Lontz noted that Walker had poor orientation to time, often confusing how long she had been at the facility. Regarding the easements, Walker said she remembered signing “some papers,” but couldn’t recall if it was in 2023 or 2024. Later in the same conversation, when asked specifically about June 12, 2023, Walker stated she had “no recollection whatsoever about that date.” Dr. Lontz concluded that, in his expert opinion, Walker was currently incompetent, was incompetent on June 12 (the date she signed the easements), and was not expected to regain competency and therefore will require permanent oversight by Burke, acting as her POA. Becky Freeland, a local real estate agent, evaluated the effect of the easements on Walker’s property. In her affidavit, Freeland explained that those who buy waterfront property want to enjoy their lake access in private. The existence of a shared dock and pump house would defeat that privacy and would devalue Walker’s property by about 50 percent. The Baughs filed a motion requesting additional time to respond to Burke’s discovery request, explaining that staffing issues within the attorney’s office caused the requests not to get logged and thus, counsel was unaware of the requests until the Baughs were served with the motion for summary judgment. That same day, the Baughs also filed a memorandum opposing Burke’s motion for summary judgment.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In Re Estate of Conway
277 P.3d 380 (Idaho Supreme Court, 2012)
Stoddart v. Pocatello School District 25
239 P.3d 784 (Idaho Supreme Court, 2010)
P.O. Ventures, Inc. v. Loucks Family Irrevocable Trust
159 P.3d 870 (Idaho Supreme Court, 2007)
Cameron v. Neal
950 P.2d 1237 (Idaho Supreme Court, 1997)
Cole v. Kunzler
768 P.2d 815 (Idaho Court of Appeals, 1989)
Edwards v. Conchemco, Inc.
727 P.2d 1279 (Idaho Court of Appeals, 1986)
Sanders v. Kuna Joint School District
876 P.2d 154 (Idaho Court of Appeals, 1994)
Dunnick v. Elder
882 P.2d 475 (Idaho Court of Appeals, 1994)
McPheters v. Hapke
497 P.2d 1045 (Idaho Supreme Court, 1972)
Gmeiner v. Yacte
592 P.2d 57 (Idaho Supreme Court, 1979)
Olsen v. Hawkins
408 P.2d 462 (Idaho Supreme Court, 1965)
Heath v. Honker's Mini-Mart, Inc.
8 P.3d 1254 (Idaho Court of Appeals, 2000)
Esser Electric v. Lost River Ballistics Technologies, Inc.
188 P.3d 854 (Idaho Supreme Court, 2008)
Finholt v. Cresto
155 P.3d 695 (Idaho Supreme Court, 2007)
Englesby v. Nisula
576 P.2d 1055 (Idaho Supreme Court, 1978)
Robert Wolford v. Shawn Montee
387 P.3d 100 (Idaho Supreme Court, 2016)
Valiant Idaho v. VP Incorporated
429 P.3d 855 (Idaho Supreme Court, 2018)
Smith v. Smith (In Re Estate of Smith)
432 P.3d 6 (Idaho Supreme Court, 2018)
Berian v. Berberian
483 P.3d 937 (Idaho Supreme Court, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Burke v. Baugh, Counsel Stack Legal Research, https://law.counselstack.com/opinion/burke-v-baugh-idahoctapp-2025.