## Facts

- Griff, Inc., a bean grower, regularly delivered pinto and pink beans to Curry Bean Co., a bonded agricultural warehouse, for milling and marketing; after sale, Curry would remit the sale proceeds minus a per‑cwt fee.
- In 1996, Griff delivered 39,271.09 cwt. of beans to Curry.
- A dispute arose over whether Curry effectively fixed the sale in 1996 (to cover Curry’s market short position) or instead sold the beans to third parties in 1997, when market prices were lower.
- Evidence at trial supported an inference that Curry altered or falsified records and misled Griff about the timing and nature of the sales.
- Griff sued for breach of contract and later sought punitive damages.

## Issues

1. Whether substantial and competent evidence supported the jury’s findings on when the beans were sold and the market prices used to compute damages.
2. Whether the punitive damages award was legally and constitutionally permissible under Idaho standards for fraud or outrageous conduct and proportionality.
3. Whether attorney’s fees for pursuing payment through the Commodity Indemnity Account Program (CIAP) were recoverable as post-judgment collection fees under Idaho Code § 12‑120(5).

## Decision

- The court affirmed the jury verdict awarding compensatory damages to Griff, holding the verdict was supported by substantial and competent evidence.
- The court affirmed the punitive damages award, concluding the evidence of deceptive conduct justified punishment and the amount fell within due process and Idaho limits.
- The court reversed the award of attorney’s fees tied to Griff’s CIAP proceedings, holding that CIAP pursuit was not an attempt to collect on the civil judgment under Idaho Code § 12‑120(5).

## Legal Principles

- A jury verdict is upheld on appeal if supported by substantial and competent evidence viewed in the light most favorable to the prevailing party; appellate courts do not reweigh evidence or reassess credibility.
- Contract damages based on market values must be proven with reasonable certainty, not mathematical precision; a damages award within the evidentiary range will be sustained.
- Punitive damages may be awarded upon proof of oppression, fraud, malice, or outrageous conduct and must satisfy proportionality and due process constraints.
- Post-judgment attorney’s fees under Idaho Code § 12‑120(5) are limited to efforts to collect or enforce the judgment against the judgment debtor; pursuing a separate statutory indemnity remedy (such as CIAP) is not “collection” activity.

## Conclusion

The Idaho Supreme Court upheld the jury’s compensatory and punitive awards arising from Curry’s deceptive handling of Griff’s beans, but held that attorney work seeking payment from a state-administered indemnity program was not post-judgment collection and therefore could not be shifted under Idaho Code § 12‑120(5).


Griff, Inc. v. Curry Bean Co., 138 Idaho 315, 63 P.3d 441 (Idaho 2003)