## Facts

- In 1941, Nampa Highway District No. 1 (NHD) received a deed granting a 33-foot-wide strip of land associated with what became West Orchard Avenue in Canyon County, Idaho.
- The 1941 deed was not recorded until 1989; in the interim, adjacent parcels were conveyed without reference to the unrecorded right-of-way.
- NHD filed a quiet title action against current owners and lienholders, including the Knights, the Dominguezes, MERS, and Quicken Loans, asserting ownership of the 33-foot strip.
- Appellants claimed their predecessors purchased the property without notice of NHD’s unrecorded interest and were bona fide purchasers (BFPs); Appellants argued they were protected under the shelter rule through those predecessors.
- NHD argued the roadway’s physical existence provided notice sufficient to defeat BFP status.
- On cross-motions for summary judgment, the district court ruled for NHD and declared NHD owned the strip in fee simple.

## Issues

1. Whether summary judgment was improper because a genuine issue of material fact existed as to whether Appellants’ predecessors were bona fide purchasers and, if so, whether Appellants could claim protection under the shelter rule against NHD’s late-recorded deed.
2. Whether the 1941 instrument conveyed fee simple title to NHD or instead granted only an easement (right-of-way).

## Decision

- The Idaho Supreme Court reversed the grant of summary judgment for NHD and remanded for further proceedings.
- The Court held that bona fide purchaser status (and the shelter rule’s application) turned on disputed, fact-dependent questions about notice and reasonable investigation.
- The Court vacated the district court’s declaration of fee simple ownership, holding the 1941 deed granted only an easement/right-of-way.

## Legal Principles

- Idaho recording law can protect bona fide purchasers from prior unrecorded interests; successors in interest may claim the benefit of a predecessor’s BFP status under the shelter rule.
- Whether a purchaser had notice (actual, constructive, or inquiry) may depend on what a reasonable inspection and investigation would reveal; when reasonable inferences differ, the issue is not suitable for summary judgment.
- The physical presence of a roadway may contribute to inquiry notice but does not, as a matter of law, automatically defeat bona fide purchaser status.
- Deed interpretation governs the nature of the interest conveyed; language granting a right-of-way may create an easement rather than transfer fee simple title.

## Conclusion

The Idaho Supreme Court held that disputed facts about notice and reasonable investigation precluded summary judgment on bona fide purchaser and shelter-rule defenses, and it further held that the 1941 right-of-way deed conveyed only an easement, not fee simple ownership, requiring remand for factfinding and further proceedings.


Nampa Highway District No. 1 v. Knight, 462 P.3d 137 (Idaho 2020)