Just's, Inc. v. Arrington Construction Co.

583 P.2d 997, 99 Idaho 462, 1978 Ida. LEXIS 436
CourtIdaho Supreme Court
DecidedJune 30, 1978
Docket12078
StatusPublished
Cited by76 cases

This text of 583 P.2d 997 (Just's, Inc. v. Arrington Construction Co.) 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
Just's, Inc. v. Arrington Construction Co., 583 P.2d 997, 99 Idaho 462, 1978 Ida. LEXIS 436 (Idaho 1978).

Opinions

BAKES, Justice.

In 1972 defendant respondent Arrington Construction Company and the City of Idaho Falls entered into a contract for the renovation of a five and one-half block portion of the downtown Idaho Falls business area in accordance with Project No. 4B-42, of Local Improvement District (LID) No. 42. The work to be done included the removal and replacement of all streets and sidewalks; the location, removal and replacement of all sewer and water lines; the removal and replacement of electrical services; the removal and replacement of light and traffic control systems; and the addition of trees, shrubs, and other beautification devices. The contract required the defendant to take certain precautions to limit the disruption to the businesses within the area to be renovated. The plaintiff appellant Just’s, Inc., operated a retail business in leased premises located within the renovation area.

The plaintiff brought this action alleging in Count I of its complaint that it was a third party beneficiary of the contract and that its business had been damaged by the defendant’s failure tó complete the project in a timely manner and to provide continuous access to plaintiff’s business as required by the terms of this contract. The second count of the complaint alleged similar damage because of the defendant’s negligent performance of the contract. The district court initially denied the defendant’s motion to dismiss Count I, ruling that the plaintiff was a. third party beneficiary of the contract. However, when the district court later learned that the plaintiff was a lessee and not an owner of property within the LID, it dismissed Count I. After denying defendant Arrington’s motion for summary judgment on Count II, the negligence issue was tried to a jury, which returned a verdict in favor of the defendant. On appeal, plaintiff assigns as error the dismissal of Count I of its complaint, and as to the trial of Count II, the refusal to admit certain items into evidence and the giving of certain jury instructions.

I

Absent a manifested intent to the contrary, construction contracts between a contractor and a public body are not generally considered as being for the benefit of third parties, but as being for the benefit of the public entity in the performance of its public duties and the contractor. Davis v. [464]*464Nelson-Deppe, Inc., 91 Idaho 463, 424 P.2d 733 (1967) (highway construction contract). However, if the provisions of a contract additionally express an intention to benefit third parties, the fact that a public body is a party to the contract does not ipso facto deny such intended third party beneficiaries the right to enforce the terms of the contract. See, e. g., Bush v. Upper Valley Telecable Co., 96 Idaho 83, 524 P.2d 1055 (1974); Yellowstone Pipe Line Co. v. Grant Construction Co., 95 Idaho 794, 520 P.2d 249 (1974). The ascertainment of the contracting parties’ intent requires a careful review of the contract documents and the circumstances surrounding the contract’s formation. Stewart v. Arrington Construction Co., 92 Idaho 526, 446 P.2d 895 (1968).

The test which must be satisfied before a third party may enforce the terms of a contract between a private contractor and a public body was clearly set forth in the Arrington case:

“In order to recover as a third party beneficiary, it is not necessary that the individual be named and identified as an individual although that is usually sufficient; a third party may enforce a contract if he can show he is a member of a limited class for whose benefit it was made. [Citation omitted]. The class may be limited either by a narrow description of the injuries to be guarded against and the damages to be paid [citation omitted], or by a similar description of the class to be protected. [Citations omitted].” 92 Idaho at 532, 446 P.2d at 901 (1968).

Application of this test to the instant case raises two issues: (1) Was the contract between the City of Idaho Falls and the defendant, particularly the provisions requiring the defendant to take specified measures to lessen the disruption to the businesses in the area, for the benefit of a limited class? (2) If so, is the plaintiff a member of that class?

II

At the outset it is important to note that the contract involved in this case is not the typical public works contract, but a contract for the construction of improvements in a local improvement district (LID). Improvements made pursuant to an LID are generally financed in whole or in part by special assessments imposed on the property within the district and benefited by the improvements. See I.C. § 50-1717 (repealed in 1976). See generally, Butler v. City of Blackfoot, 98 Idaho 854, 574 P.2d 542 (1978). Though not precisely stated, it is evident from the affidavit of Charles J. Just, president and chief executive officer of the plaintiff, that special assessments for the expenses of the improvements made pursuant to this contract have been or will be levied against the property which the plaintiff leases and that “through the provision of its lease, currently being renegotiated, [plaintiff] will be paying the expenses of such improvements directly.”

The essence of the theory justifying special assessments in connection with an LID as a means of financing all or part of such public improvements is that the improvements confer special benefits to the property within the LID. This principle has been summarized as follows:

“Laws recognize a distinction between public improvements which benefit the entire community, and those local in their nature which benefit particular real property or limited areas. The property benefited is usually required to pay the expense of the latter. A local improvement is a public improvement which, although it may incidentally benefit the public at large, is made primarily for the accommodation and convenience of the inhabitants of a particular locality, and which is of such a nature as to confer a special benefit upon the real property adjoining or near the improvement.” 14 E. McQuillin, The Law cf Municipal Corporations § 38.-11 (3d ed.rev.vol.1970).
“The foundation of the power to lay a special assessment or a special tax for a local improvement of any character . is the benefit which the object of the assessment or tax confers on the owner of the abutting property, or the owners of property in the assessment or special [465]*465taxation district, which is different from the general benefit which the owners enjoy in common with the other inhabitants or citizens of the municipal corporation.
“Special assessment or special taxation, therefore, is lawful and constitutional only when founded upon special benefits accrued from the improvement for which the tax or assessment is laid.” Id., § 38.02.

Accord, C. Rhyne, Municipal Law, § 29-3 (1957).

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Bluebook (online)
583 P.2d 997, 99 Idaho 462, 1978 Ida. LEXIS 436, Counsel Stack Legal Research, https://law.counselstack.com/opinion/justs-inc-v-arrington-construction-co-idaho-1978.