The Idaho Supreme Court reversed a district court's summary judgment ruling in a real estate contract dispute between buyers Patrick and Meghan McLaughlin and sellers Sharelynn and Jason Moore, remanding the case for further proceedings.
The case, *McLaughlin v. Moore* (Idaho 2025), centers on the enforceability of a residential real estate purchase and sale agreement after the sellers attempted to back out of the deal following the contract signing. The court issued its opinion Dec. 23, 2025.
According to the court's opinion, the Moores offered to sell their condominium to the McLaughlins. After the parties agreed on a price and signed the residential real estate purchase and sale agreement, the Moores contacted the McLaughlins to inform them that they no longer intended to proceed with the sale.
The district court had granted summary judgment against the McLaughlins on their specific performance claim, ruling that specific performance was not available because the buyers did not tender the full purchase price at closing. The First Judicial District Court of Bonner County ruled on both the specific performance claim and the sellers' statute of frauds defense.
The Idaho Supreme Court reversed the summary judgment on specific performance, finding that genuine issues of material fact existed regarding whether the buyers had properly tendered performance under the contract terms. The court also affirmed the district court's dismissal of the statute of frauds defense, determining that the property description in the purchase agreement was sufficiently definite to satisfy Idaho Code 55-1526.
The case has been remanded to the district court for further proceedings consistent with the Supreme Court's opinion.
