McOmber v. Thompson

CourtIdaho Supreme Court
DecidedJuly 22, 2025
Docket50980
StatusPublished

This text of McOmber v. Thompson (McOmber v. Thompson) 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
McOmber v. Thompson, (Idaho 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF IDAHO Docket No. 50980

JONATHAN & ANGELA MCOMBER, ) husband and wife, ) ) Plaintiffs-Appellants, ) Boise, April 2025 Term ) v. ) Opinion Filed: July 22, 2025 ) SHANE & KERI THOMPSON, ) Melanie Gagnepain, Clerk husband and wife, ) ) Defendants-Respondents. )

Appeal from the District Court of the Seventh Judicial District, State of Idaho, Madison County. Steven W. Boyce, District Judge.

The decisions of the district court are affirmed in part, reversed in part, and remanded.

Beard St. Clair Gaffney, PA, Idaho Falls, for Appellants Jonathan & Angela McOmber. John M. Avondet argued.

Kirton McConkie, Boise, for Respondents Shane and Keri Thompson. Jon T. Simmons argued.

_____________________

MEYER, Justice. This appeal arose after Jonathan McOmber 1 purchased a home that he later realized was in 0F

worse condition than he expected when he bought it. After Jonathan and his wife, Angela, began remodeling their new home, they discovered dry rot, mold, and other damage from water intrusion in various parts of the home, which caused them to spend more money on repairs than they anticipated. When ice dams formed on the roof during the winter after they purchased the home, the McOmbers discovered that the roof leaked and was not professionally installed. During a kitchen remodel, Jonathan discovered that the previous owner had rewired parts of the kitchen, in a way that was not up to his standards.

1 As we discuss below, the McOmbers both initiated a lawsuit against the Thompsons; however, the district court dismissed Angela McOmber from two of the claims. The McOmbers did not appeal that decision. For ease of reference, when we discuss claims that involve only Jonathan McOmber, we will refer to “Jonathan,” and when we discuss a claim that involves both Angela and Jonathan, we will refer to “the McOmbers.”

1 When Jonathan purchased the home, he relied on the sellers’ disclosures about the home’s condition and did not order an independent property inspection. As sellers, Shane and Keri Thompson completed a disclosure form and answered “yes” to questions about damage from water intrusion, with the explanation “drainage problem that was fixed.” They answered “no” in response to questions about the roof leaking. Although the Thompsons indicated on the disclosure form that there had been damage from mold, dry rot, and water intrusion in the home, the McOmbers felt misled. The McOmbers filed an action against the Thompsons for breach of duty to disclose/fraud, common law fraud, and breach of contract, among other claims. They later sought to add a claim for constructive trust, which the district court denied. Both parties moved for summary judgment. The district court granted summary judgment in the Thompsons’ favor and awarded attorney fees to the Thompsons based on a provision in the Real Estate Purchase and Sale Agreement (“REPSA”). The McOmbers filed a motion for reconsideration, which the district court denied. The McOmbers now appeal the district court’s decisions to this Court. For the reasons discussed below, we affirm. I. FACTUAL AND PROCEDURAL BACKGROUND On December 31, 2019, Jonathan McOmber purchased a home in Rexburg, Idaho, from Shane and Keri Thompson (the “Property”). As part of the sale, the Thompsons completed a Seller’s Property Condition Disclosure Form (“disclosure form”). The disclosure form contained various questions about the condition of the Property. In a section marked “Moisture & Drainage Conditions,” the Thompsons marked “yes” in response to a question about past water intrusion or moisture related damage to the Property, including inside the home. In the remarks section, they wrote “[d]rainage problem that was fixed.” The Thompsons marked “yes” in response to a question about whether they had remediated, repaired, or fixed any problems on the Property created by water intrusion or mold, and wrote “drainage problem that was fixed” in the remarks section for that question. The Thompsons marked “no” in response to questions about current mold-related problems inside the Property. With respect to questions about the roof, they marked “no” to a question about the roof leaking and indicated the roof had been installed in 2012. The disclosure form did not ask questions about electrical work on the Property. Both parties signed and initialed the disclosure form as part of the closing. After closing, Jonathan and his wife began an extensive remodel of the Property. During the first winter they owned the Property, in 2020, ice dams formed on the roof and caused water

2 intrusion inside the home. When the McOmbers began remodeling the interior of the home, they discovered mold, dry rot, and other damage from water intrusion in various parts of the home. The McOmbers filed an action against the Thompsons, in which they alleged that the Thompsons failed to disclose property defects before closing and, as a result, committed fraud and breached the REPSA. During the litigation, Angela McOmber was dismissed as a party plaintiff from the breach of duty to disclose/fraud claim and the breach of contract claim because she was not a party to the REPSA. The McOmbers’ claim for unjust enrichment was dismissed in its entirety. The district court’s decision dismissing Angela McOmber from certain claims and dismissing the unjust enrichment claim were not appealed by the McOmbers. A. The McOmbers’ motion for leave to amend the complaint. The McOmbers later sought leave to amend their complaint to add a claim for constructive trust. The district court determined that a constructive trust claim was not applicable under the circumstances of this case and denied the McOmbers’ motion. The McOmbers now appeal the district court’s decision to deny their motion for leave to amend the complaint, arguing that the district court erred when it denied their motion. B. The motions for summary judgment. Both parties then moved for summary judgment on the remaining claims. The district court granted summary judgment in the Thompsons’ favor, finding that Idaho’s Property Condition Disclosure Act (“Disclosure Act”) only requires sellers to disclose known property defects. The district court determined that the Thompsons complied when they completed the disclosure form and answered “yes” to questions related to damage from mold, dry rot, and water intrusion and when they answered “yes” to questions related to remediation or repairs to property damaged by mold, dry rot, and water intrusion. The district court rejected Jonathan’s argument that the Thompsons’ answer stating “drainage problem that was fixed” was misleading because the Thompsons still answered “yes” to questions about water intrusion. The court noted that the Thompsons’ answers on the disclosure form put Jonathan on notice that more investigation may be needed. Because the Thompsons answered “yes” on the disclosure form, the district court determined that Jonathan could not establish a claim for duty to disclose/fraud, and the McOmbers could not establish their common law fraud claim because they could not establish that the Thompsons made a false statement of fact. As the breach of contract claim was also based on

3 allegations that the Thompsons made false or misleading statements on the disclosure form, the district court determined summary judgment on that claim was appropriate because Jonathan could not establish that the Thompsons breached the REPSA. The McOmbers filed a motion for reconsideration combined with a motion to alter or amend the judgment, in which they asked the district court to correct its characterization of the evidence and reverse its decision on summary judgment. The district court did correct an erroneous statement that there was no evidence of ice dams before Jonathan purchased the Property but determined that fact did not require reversal.

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McOmber v. Thompson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcomber-v-thompson-idaho-2025.