Jordan v. Powers

CourtIdaho Supreme Court
DecidedAugust 28, 2025
Docket51330
StatusPublished

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

Bluebook
Jordan v. Powers, (Idaho 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF IDAHO

Docket No. 51330-2023

CARL P. JORDAN, an individual, ) ) Plaintiff-Counterdefendant- ) Boise, June 2025 Term Respondent, ) ) Opinion filed: August 28, 2025 v. ) ) Melanie Gagnepain, Clerk AARON POWERS, an individual, ) ) Defendant-Counterclaimant- ) Appellant. ) )

Appeal from the District Court of the Seventh Judicial District of the State of Idaho, Teton County. Alan C. Stephens, District Judge.

The decision of the district court is affirmed in part and reversed in part.

Beard St. Clair Gaffney PA, Idaho Falls; and Spitzer Law, PLLC, Victor, for Appellant. Kathy Spitzer argued.

Holden, Kidwell, Hahn & Crapo, P.L.L.C., Idaho Falls, for Respondent. D. Andrew Rawlings argued.

ZAHN, Justice. This appeal concerns: (1) whether a strip of real property remained subject to a subdivision’s covenants, codes, and restrictions (“CC&Rs”) after the county approved a boundary line adjustment and amended plat that purported to remove the property from the subdivision; and, (2) if the property was subject to the CC&Rs, whether they prevent the owner of real property from constructing a road on his property. Aaron Powers owned a lot (“Lot One”) in the Sorensen Creek Subdivision (“the Subdivision”) and a large undeveloped parcel (“the Adjacent Parcel”) that was adjacent to, but not part of, the Subdivision. He intended to develop the Adjacent Parcel into a new subdivision, but the Adjacent Parcel lacked access to a public road or a privately developed road. To solve that problem, he wanted to construct a road on a sixty-foot-wide strip of land (“the Sixty-Foot Strip”) that was part of Lot One. When Powers approached members of the board of the Sorensen Creek Subdivision Homeowners Association (“HOA”) seeking permission to construct the road, he was told that he would not be permitted to do so. He later applied to Teton County for an adjustment of the boundary line between Lot One and the Adjacent Parcel, which would result in the Adjacent Parcel effectively absorbing the Sixty-Foot Strip. Teton County approved the application, the boundary line was adjusted, and an amended plat of Lot One was recorded. Carl P. Jordan, a homeowner in the Subdivision and a member of the HOA’s board, filed a complaint in district court seeking to prevent construction of the road. He requested declaratory relief that: (1) Powers violated the Subdivision’s CC&Rs by “splitting” Lot One when he secured the boundary line adjustment and amended plat for Lot One; (2) the CC&Rs continued to apply to the entirety of the originally platted Lot One, including the Sixty-Foot Strip; and (3) the CC&Rs prohibited construction of a road on the Sixty-Foot Strip. Jordan also requested injunctive relief preventing Powers from constructing the road. Powers filed a counterclaim that requested a declaratory judgment that the Sixty-Foot Strip was no longer subject to the CC&Rs. Both parties filed cross motions for summary judgment. The district court ruled in favor of Jordan on both motions. The court granted the declaratory relief requested by Jordan and permanently enjoined Powers from constructing the road without first securing an amendment of the CC&Rs “and/or” approval from the HOA. Powers appeals, arguing that the boundary line adjustment and plat amendment approved by Teton County removed the Sixty-Foot Strip from the purview of the CC&Rs. Alternatively, he argues that, even if the CC&Rs apply, they do not restrict his ability to construct the road. We affirm the district court’s declaration that the CC&Rs continue to apply to the Sixty- Foot Strip and its declaration that Powers failed to secure the approval required by the CC&Rs. We reverse the district court’s declaration that the CC&Rs categorically prohibit the construction of a road and its declaration that the boundary line adjustment constituted a “lot split” that violated the CC&Rs. We also vacate the permanent injunction entered by the district court.

2 agricultural purposes. It was not accessible by any public road or any developed private road. Instead, it had been historically accessed through Lot One, across a “two-track” dirt path. In 2020, Powers purchased both Lot One and the Adjacent Parcel from Lohman. He planned to develop the Adjacent Parcel into a fourteen-lot subdivision. Because the Adjacent Parcel has no public road or developed private road access, Powers wanted to construct a road through Lot One. That new road through Lot One would connect the Adjacent Parcel to a public road on the other side of Lot One. If he were permitted to develop that new road passing through Lot One, residents of the new, fourteen-lot subdivision would use it to access the new subdivision. Powers contends that he spoke with homeowners in the Subdivision, including the HOA president, both before and after purchasing the properties, and they “agreed that access” to the Adjacent Property was through Lot One, and “did not raise any concerns with putting a road in for that purpose.” Nevertheless, after the purchase, when he approached members of the HOA board requesting permission to construct the road, Powers was told he would not be permitted to do so. Powers applied to Teton County to amend the plat for Lot One and to adjust the boundary line between Lot One and the Adjacent Property. Approval of the application would shift the boundary between Lot One and the Adjacent Parcel so that Lot One would be smaller (“Amended Lot One”) and the Adjacent Parcel would be larger (“Amended Adjacent Parcel”). The Sixty-Foot Strip would become part of the Amended Adjacent Parcel, which would make the parcel partially adjacent to the public road (along the Sixty-Foot Strip). It is unclear exactly when the application was filed because it and other records associated with Powers’ application are not part of the record on appeal. In early July 2021, Jordan submitted a letter to the County opposing Powers’ application. The County subsequently granted the application. The HOA then submitted a letter in late August 2021 requesting that the County reconsider its approval of the application. The Subdivision argued, in part, that the application should not have been approved because the CC&Rs prohibit construction of the road. The County did not reconsider. Neither the HOA nor any individual homeowner in the Subdivision filed any action under the Local Land Use Planning Act, chapter 65, title 67, Idaho Code, for judicial review of the County’s decision. An amended plat for “Lot 1 Sorensen Creek Subdivision” and a boundary line adjustment were recorded in April 2022. The amended plat is below, with the Amended Lot One depicted in red, the Sixty-Foot Strip depicted

4 CC&Rs, and that Powers had not secured approval for the road from the HOA, as required by the CC&Rs. In the “Factual Background” section of its written order, the district court stated that Powers’ effort to amend the boundary between Lot One and the Adjacent Property “violates the HOA [CC&Rs’] restrictions on lot splitting,” but it did not address the issue in the “Analysis” section of the order. The district court also did not address Jordan’s argument that the CC&Rs categorically prohibit construction of a road on the Sixty-Foot Strip. The district court’s order granted “a temporary restraining order preventing [Powers] from continuing any alterations or improvements upon [the Sixty-Foot Strip] until such time as [Powers] exhausts all possible remedies through the HOA’s processes proscribed [sic] in the [CC&Rs].” The order also stated that Jordan was the prevailing party and awarded him attorney fees and costs “in accordance with court rules,” but failed to cite any statutory or contractual basis for the award of fees. The district court then entered a judgment granting “Injunctive Relief in favor of [Jordan] . . .

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Jordan v. Powers, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jordan-v-powers-idaho-2025.