The Idaho Supreme Court reversed a district court's summary judgment ruling in *Cave Bay Community Services v. Lohman*, a property dispute involving easement rights and an option agreement. The court vacated the district court's judgment and remanded the case for further proceedings.
The dispute arose from Morgan Lohman's February 2022 purchase of a 25.8-acre property from Stephen and Melinda Dreher in Kootenai County. During the negotiation process, Lohman discovered that the Drehers' homeowners association, Cave Bay Community Services, Inc., held a permanent easement on 7.31 acres of the land. The property also came with an option agreement that gave Cave Bay the right to purchase the easement land for one dollar within a year of the Drehers paying off their loans on the property.
Despite knowledge of both the easement and the option agreement, Lohman proceeded with the purchase, acquiring the property with all existing encumbrances. The legal complications arose after the sale was completed. Following the property transfer, the Drehers satisfied their outstanding loans on the land, which triggered Cave Bay's option to purchase the easement area.
When Cave Bay attempted to exercise its option to buy the 7.31 acres for the agreed-upon dollar amount, Lohman refused to honor the agreement. This refusal prompted Cave Bay to file a lawsuit seeking to enforce its rights under the option agreement.
Cave Bay's complaint included three distinct legal claims against Lohman: breach of contract, breach of the implied covenant of good faith and fair dealing, and specific performance. The homeowners association focused its legal strategy on seeking summary judgment on the specific performance claim, which would have compelled Lohman to complete the sale of the easement land as originally agreed.
The U.S. District Court for the First Judicial District of Idaho in Kootenai County, presided over by Judge John T. Mitchell, granted summary judgment in favor of Cave Bay. The district court's ruling not only ordered specific performance of the option agreement but also awarded attorney fees and costs to the homeowners association.
Lohman appealed the district court's decision to the Idaho Supreme Court, challenging both the summary judgment ruling and the award of attorney fees. In his appeal, Lohman argued that the lower court had overlooked material facts that remained in dispute, making summary judgment inappropriate. He also contended that Cave Bay had failed to meet the legal standards required for summary judgment.
Summary judgment is a legal procedure that allows courts to resolve cases without a full trial when there are no genuine disputes about material facts and one party is entitled to judgment as a matter of law. For summary judgment to be proper, the moving party must demonstrate that no reasonable jury could find in favor of the opposing party based on the evidence presented.
The Idaho Supreme Court, led by Chief Justice Bevan, concluded that the district court had erred in granting summary judgment. While the full text of the supreme court's reasoning was not available, the court's decision to reverse and remand suggests that disputed material facts remained that required resolution through trial proceedings.
The case highlights the complex legal issues that can arise in real estate transactions involving homeowners associations and easement rights. Easements are legal rights that allow one party to use another's land for a specific purpose, and they typically transfer with the property when it is sold. Option agreements, meanwhile, give one party the right to purchase property under specified terms and conditions.
The dispute also illustrates the importance of due diligence in real estate transactions. While Lohman was aware of both the easement and the option agreement before completing his purchase, his subsequent refusal to honor the option agreement led to expensive litigation.
The case was argued before the Idaho Supreme Court during the November 2025 term, with Dennis Thompson of T & G Attorneys representing Lohman and Jason S. Wing of Lake City Law Group representing Cave Bay. The court issued its opinion on Feb. 9, 2026.
With the case now remanded to the district court, the parties will likely proceed to trial on Cave Bay's claims. The homeowners association will need to prove its breach of contract and specific performance claims, while Lohman will have the opportunity to present his defenses to a jury.
The Idaho Supreme Court's decision demonstrates the high standards required for summary judgment in complex property disputes and emphasizes that material factual disputes must be resolved through the trial process rather than through summary proceedings.