Davis v. Blast Properties Inc.

CourtDistrict Court, D. Idaho
DecidedApril 15, 2025
Docket1:21-cv-00218
StatusUnknown

This text of Davis v. Blast Properties Inc. (Davis v. Blast Properties Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Idaho primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Davis v. Blast Properties Inc., (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

MYLES DAVIS, an individual, and JANELLE DAHL, an individual,, Case No. 1:21-cv-00218-BLW

MEMORANDUM DECISION Plaintiffs, AND ORDER

v.

BLAST PROPERTIES, INC. DBA B&B CUSTOM HOMES, an Idaho Corporation; TYLER BOSIER, an individual; BLAST HOLDINGS, LLC, an Idaho Limited Liability Company; and DOES 1-50, inclusive,

Defendants.

INTRODUCTION The Court has before it numerous pretrial motions: Defendants’ Motion to Bifurcate (Dkt. 143), Plaintiffs’ Motion for Judicial Notice (Dkt. 138), Plaintiffs’ Motion in Limine re. Specific Performance (Dkt. 140), several other Motions in Limine (Dkts. 133, 139, 141, and 146), and Defendants’ Motion for Relief from Trial Setting Order (Dkt. 154). The Court’s ruling on each is explained below. BACKGROUND Plaintiffs Myles Davis and Janelle Dahl filed this suit against Defendants Tyler Bosier, Blast Properties, Inc., and Blast Holdings, LLC over a dispute involving a contract for the purchase of land and construction of a home. Plaintiffs bring claims for specific performance, breach of contract, fraud, violation of the

Idaho Consumer Protection Act, fraudulent conveyance, and constructive trust. A seven-day jury trial is scheduled to commence on April 24, 2025. The Court previously granted partial summary judgment to Plaintiffs on the

breach of contract claim, finding that Blast Properties repudiated the contract. Dkt. 33 at 26-36. For relief on that claim, Plaintiffs seek specific performance, as well as damages to be determined by the jury. On the fraud claim, the Court has allowed Plaintiffs to seek punitive damages in addition to general damages. Dkt. 68. The

claims for fraudulent conveyance and constructive trust were added late in the litigation after Plaintiffs identified several insider property transactions allegedly made for little or no consideration. For these claims, Plaintiffs’ proposed remedies

are the avoidance of the transfers, attachment of the properties, an injunction against further disposition by Defendants, appointment of a receiver, and imposition of a constructive trust. Third Am. Compl. at 14, Dkt. 123. ANALYSIS

The present motions raise a variety of issues related to the structure of the trial and the admissibility of disputed evidence. First, Plaintiffs again ask the Court to order specific performance—a request which they mask by making it in the form

of a motion in limine. Dkt. 140. Second, Defendants move to bifurcate the trial to separate evidence regarding the amount of punitive damages from the rest of the proceedings before the jury. Dkt. 143. Third, the parties disagree about whether the

fraudulent conveyance claim should go to the jury. Dkt. 143. Fourth, Plaintiffs ask the Court to take judicial notice of average interest rates for a 30-year fixed rate mortgage, Dkt. 138. Fifth, the parties dispute the admissibility of various pieces of

evidence. Dkts. 139, 141, 146. 1. Timeliness A threshold consideration is that several of Defendants’ responses were late. Pursuant to the trial setting order, the parties’ motions in limine were due by March

24, 2025; responses were due seven days later; and replies were due three days after that. Dkt. 94. Defendants responded to two of Plaintiffs’ motions in limine on March 31, but two other responses were not filed until April 2, apparently due to

an administrative error. Realizing this mistake, Defendants moved for relief from the trial setting order. Dkt. 154. The Court will grant that motion. A court may excuse a missed deadline “if the party failed to act because of excusable neglect.” Fed. R. Civ. P. 6(b)(1)(B).

Excusable neglect is a “somewhat elastic concept and is not limited strictly to omissions caused by circumstances beyond the control of the movant.” Pioneer Inv. Servs. Co. v. Brunswick Assoc. Ltd., 507 U.S. 380, 392 (1993) (internal

quotations omitted). When deciding whether to excuse untimeliness, courts consider all relevant circumstances, including (1) the risk of prejudice; (2) the length of the delay and its potential impact on the proceedings; (3) the reason for

the delay, including whether it was within the party’s reasonable control; and (4) whether the party acted in good faith. Briones v. Riviera Hotel & Casino, 116 F.3d 379, 381 (9th Cir. 1997) (citing Pioneer Inv., 507 U.S. at 395).

Here, first, the risk of prejudice is minimal. Plaintiffs suggest they were disadvantaged because counsel had to rush to file replies within 24 hours to meet the deadlines of the trial setting order. However, the trial setting order provided that reply briefs “shall be filed within 3 days of the date the response is filed.” Dkt.

94 at 2. Because Defendants filed their responses on April 2, Plaintiffs therefore had until April 7 to reply (because April 5 fell on a Saturday). It was Plaintiffs’ choice to rush to file the replies, notwithstanding Defendants’ missed deadline.

Second, the length of the delay was only two days. For this reason, the impact on the proceedings is negligible, particularly because the parties previously agreed to delay the start of the trial by several days. Third, on the other hand, the reasons for the delay are weak. Defense

counsel’s staff member explains that she intended to file all four responses on CM/ECF on March 31 and only realized on April 2 that two of them had not been successfully filed. Apparently, counsel has been on vacation, but he still had a

professional obligation to ensure that all briefing was filed by the deadline—an unfortunate but necessary consequence of scheduling a vacation less than a month before a trial.

Fourth, Defendants have acted in good faith. Defendants clearly made a mistake, and they quickly moved to correct it. Plaintiffs argue that metadata shows that the documents were created on March 31 (the day they were due) but modified

on April 2 before they were submitted. It is not clear, however, why this should impact the Court’s analysis. At the end of the day, the nature and effect of the delay is essentially the same, and the Court will not waste any more of its time over this dispute.

2. Specific Performance Turning to the substance of the motions, the Court begins with Plaintiff’s effort to obtain specific performance. Preliminarily, the Court is skeptical that a

motion in limine is the appropriate vehicle for this request. Nonetheless, Plaintiffs are right that the factual record is sufficiently developed for a decision. In the interest of judicial efficiency, the Court will rule on specific performance now. For the reasons explained below, the Court finds that specific performance would be an

unjust remedy for Defendants’ breach of contract. “There is no right to specific performance.” Kessler v. Tortoise Dev., Inc., 1 P.3d 292 (Idaho 2000). “Specific performance is an extraordinary remedy,”

designed to provide relief only “when legal remedies are inadequate.” Id. Generally, in actions for the breach of a contract for the sale of real property, “[t]he inadequacy of remedies at law is presumed.” P.O. Ventures, Inc. v. Loucks Family

Irrevocable Trust, 159 P.3d 870, 874 (Idaho 2007). For service contracts, however, specific performance is almost never available due to the impracticality of enforcement.

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

Related

Parsons v. Bedford, Breedlove, & Robeson
28 U.S. 433 (Supreme Court, 1830)
Luce v. United States
469 U.S. 38 (Supreme Court, 1984)
Granfinanciera, S.A. v. Nordberg
492 U.S. 33 (Supreme Court, 1989)
Ohler v. United States
529 U.S. 753 (Supreme Court, 2000)
Jesus Briones v. Riviera Hotel & Casino
116 F.3d 379 (Ninth Circuit, 1997)
P.O. Ventures, Inc. v. Loucks Family Irrevocable Trust
159 P.3d 870 (Idaho Supreme Court, 2007)
Smith v. Big Lost River Irrigation District
364 P.2d 146 (Idaho Supreme Court, 1961)
Brown's Tie & Lumber Co. v. Chicago Title Co. of Idaho
764 P.2d 423 (Idaho Supreme Court, 1988)
Suchan v. Rutherford
410 P.2d 434 (Idaho Supreme Court, 1966)
McCandless v. Schick
380 P.2d 893 (Idaho Supreme Court, 1963)
Siegel Mobile Home Group, Inc. v. Bowen
757 P.2d 1250 (Idaho Court of Appeals, 1988)
United States v. Heller
551 F.3d 1108 (Ninth Circuit, 2009)
Kessler v. Tortoise Development, Inc.
1 P.3d 292 (Idaho Supreme Court, 2000)
City of Pomona v. Sqm North America Corp.
866 F.3d 1060 (Ninth Circuit, 2017)
Resolution Trust Corp. v. First American Bank
155 F.3d 1126 (Ninth Circuit, 1998)
Transorient Navigators Co. v. M/S Southwind
788 F.2d 288 (Fifth Circuit, 1986)

Cite This Page — Counsel Stack

Bluebook (online)
Davis v. Blast Properties Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/davis-v-blast-properties-inc-idd-2025.