The Idaho Supreme Court reversed a district court's summary judgment ruling in *McLaughlin v. Moore*, allowing buyers to pursue specific performance of a residential real estate purchase agreement after sellers attempted to withdraw from the signed contract.
The case arose when Sharelynn and Jason Moore offered to sell their condominium to Patrick and Meghan McLaughlin. After the parties agreed on a price and signed the residential real estate purchase and sale agreement (REPSA), the Moores contacted the McLaughlins to inform them they no longer intended to complete the sale.
The dispute centered on two key legal issues: whether specific performance was available to the buyers despite not tendering the full purchase price at closing, and whether the purchase agreement was enforceable under Idaho's statute of frauds.
In the district court proceedings in Bonner County, Senior District Judge Barbara Buchanan and District Judge Susie Jensen granted summary judgment in favor of the Moores on the specific performance claim. The trial court ruled that the McLaughlins could not seek specific performance because they had not tendered the full purchase price at the scheduled closing.
On appeal, the McLaughlins challenged this decision, arguing that specific performance should remain available as a remedy. The Idaho Supreme Court agreed, finding that the district court erred in granting summary judgment on this issue.
The Moores mounted a cross-appeal, contending that the entire purchase agreement was unenforceable under Idaho's statute of frauds due to what they claimed was an inadequate property description in the REPSA. The statute of frauds requires certain contracts, including real estate agreements, to contain sufficient written descriptions of the property being sold.
However, the Idaho Supreme Court rejected the Moores' statute of frauds defense. Writing for the court, Justice Meyer held that under Idaho Code section 55-1526, the REPSA contained a sufficient description of the condominium to satisfy the statutory requirements. The court affirmed the district court's dismissal of this defense.
The ruling represents a significant victory for the McLaughlins, who have been seeking to enforce the original purchase agreement since the Moores' attempted withdrawal from the sale. Specific performance is an equitable remedy that compels a party to fulfill their contractual obligations rather than simply paying monetary damages.
In real estate transactions, specific performance is often the preferred remedy for buyers because each piece of property is considered unique under the law. Unlike other goods that can be easily replaced, real estate cannot typically be substituted, making monetary damages an inadequate remedy for breach of contract.
The case highlights the binding nature of signed real estate purchase agreements in Idaho. Once parties have agreed on essential terms and executed a written contract, sellers cannot unilaterally withdraw from the transaction without facing potential legal consequences.
The Idaho Supreme Court's decision sends a clear message about the enforceability of real estate contracts in the state. Property sellers who sign purchase agreements and then attempt to back out due to changed circumstances or better offers face the risk of being compelled to complete the original transaction.
The court's analysis of Idaho Code section 55-1526 also provides guidance for practitioners regarding property description requirements in real estate contracts. The ruling suggests that condominium descriptions in standard REPSAs typically meet the statute of frauds requirements, even when sellers later claim the descriptions are inadequate.
Representation in the case was handled by Evans Craven & Lackie, PS from Spokane, Washington, for the McLaughlins, with Christopher J. Kerley presenting oral arguments. The Moores were represented by Ramsden, Marfice, Ealy & De Smet LLP from Coeur d'Alene, with Jack A. Mosby arguing their position.
The case was heard during the Idaho Supreme Court's Coeur d'Alene September 2025 term, with the opinion filed on December 23, 2025. The docket number is 51858.
With the case now remanded to the district court for further proceedings, the McLaughlins will have another opportunity to pursue their specific performance claim. The district court will need to reconsider the issues surrounding the buyers' failure to tender the full purchase price and determine whether specific performance remains an appropriate remedy under the circumstances.
The remand also means the litigation will continue, potentially leading to additional proceedings to resolve the underlying dispute over the condominium purchase. The McLaughlins' ultimate success will depend on how the district court applies the Idaho Supreme Court's guidance on remand and whether any other defenses to specific performance remain viable.