However, if satisfaction of the judgment is involuntary, the right to appeal is not lost. In re SRBA, 149 Idaho 532, 538 n. 1, 237 P.3d 1, 7 n. 1 (2010) ; Int'l Bus. Machs. Corp. v. Lawhorn, 106 Idaho 194, 197, 677 P.2d 507, 510 (Ct.App.1984). Thus, when a party pays an award to avoid a sheriff's sale, the satisfaction of the judgment is involuntary and the issue is still ripe for judicial review.
"The district court may appoint a special master in any general adjudication and shall specify the special master's powers and duties in the order of reference." In re SRBA , 149 Idaho 532, 536–37, 237 P.3d 1, 5–6 (2010) (citing I.C. § 42–1422 ). Subcases referred to a special master are governed by the Idaho Rules of Civil Procedure (I.R.C.P.), the Idaho Rules of Evidence (I.R.E.); Idaho Code § 42–1411(5) ; and SRBA Administrative Order 1 (AO1).
order of reference may be broad enough to allow a special master to recommend an award of attorney fees. In re SRBA , 149 Idaho 532, 542, 237 P.3d 1, 11 (2010). In In re SRBA , the special master was empowered to "schedule and hear dispositive and nondispositive motions of any party."
"This Court reviews an order denying a motion to alter or amend a judgment for abuse of discretion." In re SRBA, 149 Idaho 532, 542, 237 P.3d 1, 11 (2010). Upon review of the record, we decline to grant relief on either issue.
The Marquettes argue the award of attorney fees was appropriate because it was only a clerical mistake that caused the attorney fees ledger not to be attached to the initial or first amended request for attorney fees; the inclusion of the attorney fee ledger in the second amended request was a supplement to the earlier filing; and neither in the trial court nor on appeal did the Falcks argue they suffered any prejudice as a result of the late filing. The Marquettes rely on In re SRBA, 149 Idaho 532, 544, 237 P.3d 1, 13 (2010), to support their position that the third amended memorandum, which included the appropriate fee ledger, was a supplement to the original memorandum of fees and costs, and thus, was not untimely.
Consistent with the express terms of Rule 6(b), this Court reviews a trial court's decision of whether to grant a motion for enlargement of time for an abuse of discretion. In re SRBA, 149 Idaho 532, 538-39, 237 P.3d 1, 7-8 (2010); see also Wheeler, 100 Idaho at 289, 596 P.2d at 801. When a trial court's discretionary decision is reviewed on appeal, the appellate court conducts a multi-tiered inquiry to determine: (1) whether the lower court correctly perceived the issue as one of discretion; (2) whether the lower court acted within the boundaries of such discretion and consistently with any legal standards applicable to the specific choices before it; and (3) whether the court reached its decision by an exercise of reason.
Therefore, the Supplemental Memorandum was time-barred and fees should not have been awarded on it. For the first time at oral argument, Patricia cited Bedke v. City of Oakley, 149 Idaho 532, 237 P.3d 1 (2010), for the proposition that her Supplemental Memorandum could be properly treated as an amendment to her Original Memorandum. The Bedke decision is inapposite, however, because in Bedke the supplemental memorandum was filed before a final judgment had been rendered on the original memorandum of costs and fees. Bedke was a water law case, which was part of the Snake River Basin adjudication, and had a complex procedural history. In December 2006, a special master granted the City's request for summary judgment and recommended that the Bedkes' claimed water rights be disallowed by the district court. A week later, the City filed its initial memorandum of costs and fees.
Therefore, the Supplemental Memorandum was time-barred and fees should not have been awarded on it. For the first time at oral argument, Patricia cited Bedke v. City of Oakley, 149 Idaho 532, 237 P.3d 1 (2010), for the proposition that her Supplemental Memorandum could be properly treated as an amendment to her Original Memorandum. The Bedke decision is inapposite, however, because in Bedke the supplemental memorandum was filed before a final judgment had been rendered on the original memorandum of costs and fees. Bedke was a water law case, which was part of the Snake River Basin adjudication, and had a complex procedural history. In December 2006, a special master granted the City's request for summary judgment and recommended that the Bedkes' claimed water rights be disallowed by the district court. A week later, the City filed its initial memorandum of costs and fees.
Consistent with the express terms of Rule 6(b), this Court reviews a trial court's decision of whether to grant a motion for enlargement of time for an abuse of discretion. In re SRBA, 149 Idaho 532, 538-39, 237 P.3d 1, 7-8 (2010); see also Wheeler, 100 Idaho at 289, 596 P.2d at 801. When a trial court's discretionary decision is reviewed on appeal, the appellate court conducts a multi-tiered inquiry to determine: (1) whether the lower court correctly perceived the issue as one of discretion; (2) whether the lower court acted within the boundaries of such discretion and consistently with any legal standards applicable to the specific choices before it; and (3) whether the court reached its decision by an exercise of reason.