The Idaho Supreme Court recently ruled that two real estate purchase agreements (PSAs) between Ryan and Aaryn Schuster and Benjamin Milbrath were invalid and unenforceable. This decision affects the Schusters and other buyers involved in the Harrison Heights condominium development in Bonner County, Idaho. The ruling emphasizes the importance of clear and complete terms in real estate contracts.
The case, Ryan Schuster and Aaryn Schuster v. Benjamin Milbrath, was filed under docket number 52545. The court's ruling, issued on September 24, 2026, came after a trial in which the district court found that the PSAs lacked essential terms and therefore could not be enforced. The Schusters sought specific performance, meaning they wanted the court to require Milbrath to fulfill the contract terms, but the court denied this request.
The dispute began in 2020 when Milbrath started developing the Harrison Heights subdivision, which included duplex-style condominiums. The Schusters, who are real estate agents, entered into a PSA for one of the units, intending to use it as a personal residence and investment property. They later executed additional PSAs for two more units on behalf of other clients.
However, the PSAs were found to be incomplete. The agreements referenced plans and specifications for the construction of the units but did not include any actual plans or detailed descriptions of the materials and finishes to be used. The district court determined that the lack of these essential terms meant there was no meeting of the minds between the parties, which is necessary for a valid contract.
In its ruling, the Idaho Supreme Court affirmed the district court's judgment, stating, "The PSAs omit material terms; therefore, they are not valid and enforceable contracts." The court also noted that the Schusters' appeal regarding a bond requirement was moot since the PSAs were invalid.
This ruling has significant implications for real estate transactions in Idaho, as it underscores the necessity for clear and complete contracts. Buyers and sellers must ensure that all material terms are included in their agreements to avoid disputes and potential legal challenges.
As a result of the court's decision, Milbrath is considered the prevailing party and is entitled to recover attorney fees and costs associated with the case. The district court had awarded him nearly $150,000 in attorney fees, which the Schusters contested but ultimately did not succeed in overturning.
The ruling also raises questions about the future of the Harrison Heights condominium project. With the invalidation of the PSAs, Milbrath may need to navigate new agreements with potential buyers, which could affect the project's timeline and financial viability.
Looking ahead, the Schusters have the option to appeal the decision further, although it is unclear whether they will pursue that route. The case serves as a reminder for all parties involved in real estate transactions to ensure that their contracts are comprehensive and legally binding.
In summary, the Idaho Supreme Court's ruling highlights the critical importance of including all necessary terms in real estate contracts. Buyers and sellers must be diligent in ensuring that their agreements are clear and complete to avoid complications and legal disputes in the future.