[23–25] "Unjust enrichment occurs where (1) the plaintiff confers a benefit on the defendant; (2) the defendant appreciates the benefit; and (3) the defendant’s acceptance of the benefit is inequitable without payment to the plaintiff for the benefit’s value." Wadsworth Reese, PLLC v. Siddoway & Co., PC, 165 Idaho 364, 372, 445 P.3d 1090, 1098 (2019) (citing Countrywide Home Loans, Inc. v. Sheets, 160 Idaho 268, 272, 371 P.3d 322, 326 (2016)). "Unjust enrichment is an equitable remedy."
"The determination of whether a party prevailed for purposes of an attorney fee award is a discretionary decision of the trial court." Wadsworth Reese, PLLC v. Siddoway & Co., PC , 165 Idaho 364, 369, 445 P.3d 1090, 1095 (2019) (citing Israel v. Leachman , 139 Idaho 24, 26, 72 P.3d 864, 866 (2003) ). "Accordingly, this Court reviews the district court's determination to deny attorney fees for an abuse of discretion." Id . "As long as the court correctly perceived the issue as one of discretion, acted within the outer boundaries of its discretion, acted consistently with the legal standards applicable to the specific choices available to it, and reached its decision by the exercise of reason, we will not disturb the decision on appeal."
“The determination of whether a party prevailed for purposes of an attorney fee award is a discretionary decision of the trial court.” Allen v. Campbell, 492 F.3d 1084, 1088 (Idaho 2021) (quoting Wadsworth Reese, PLLC v. Siddoway & Co., PC, 445 P.3d 1090, 1095 (Idaho 2019)). Idaho Rule of Civil Procedure 54(d)(1)(B) governs the prevailing part inquiry and provides:
In Idaho, “[u]njust enrichment occurs where (1) the plaintiff confers a benefit on the defendant; (2) the defendant appreciates the benefit; and (3) the defendant's acceptance of the benefit is inequitable without payment to the plaintiff for the benefit's value.” Wadsworth & Reese, PLLC v. Siddoway & Co., 445 P.3d 1090, 1098 (Idaho 2019).
In this case, neither party is the ultimate prevailing party because the dispute will continue to arbitration and ultimately establish a final result after which attorney fees may then be assessed by the district court. See Wadsworth Reese, PLLC v. Siddoway & Co. , 165 Idaho 364, 370, 445 P.3d 1090, 1096 (2019) (explaining that the prevailing party analysis should take place after the case has been fully arbitrated, not simply after a motion to compel has been granted). Thus, it would be premature to award attorney fees at this time.
"[P]arties generally cannot benefit from a contractual attorney fees provision" where the contract is "deemed never to have existed in the eyes of the law." Wadsworth Reese, PLLC v.Siddoway & Co. , PC, 165 Idaho 364, 369, 445 P.3d 1090, 1095 (2019) (internal quotations and citations omitted). We have determined that the parties entered into "an agreement to agree" rather than a legally binding contract.
"As long as the court correctly perceived the issue as one of discretion, acted within the outer boundaries of its discretion, acted consistently with the legal standards applicable to the specific choices available to it, and reached its decision by the exercise of reason, we will not disturb the decision on appeal." Allen v. Campbell , 169 Idaho 125, 129, 492 P.3d 1084, 1088 (2021) (quoting Wadsworth Reese, PLLC v. Siddoway & Co., PC , 165 Idaho 364, 369, 445 P.3d 1090, 1095 (2019) ). The district court denied Amy's request for attorney fees because Amy "failed to provide any authority or argument to support her request for attorney fees."
"This Court reviews rulings on equitable remedies for an abuse of discretion." Wadsworth Reese, PLLC v. Siddoway & Co., PC , 165 Idaho 364, 372, 445 P.3d 1090, 1098 (2019). This Court's four-prong abuse of discretion analysis asks "[w]hether the trial court: (1) correctly perceived the issue as one of discretion; (2) acted within the outer boundaries of its discretion; (3) acted consistently with the legal standards applicable to the specific choices available to it; and (4) reached its decision by the exercise of reason."