2026-09-09 · Idaho · Courts

What happened. On 10 September 2025 the Idaho Supreme Court decided Vintage II, LLC v. Teton Saddleback Vistas Homeowners Association, Inc., Docket No. 51455², and reversed a district court's conclusion that a recorded subdivision master plan created restrictive covenants binding roughly 640 acres of Teton County land.¹ It also rejected the finding that the master plan effected a common-law dedication of open space to the public. Justice Moeller wrote; Chief Justice Bevan and Justices Brody, Zahn and Meyer concurred.

This is the Idaho Supreme Court's first word on whether a master plan — as distinct from a recorded declaration or a plat — can independently burden land. The answer, absent unmistakable restrictive language, is that it cannot.

How a quiet-title win became a loss

Vintage II, LLC holds a 359.48-acre parcel and a 40-acre parcel, taken by warranty deed in October 2014. Christine Holding holds a 241.26-acre parcel, deeded to her by Vintage in July 2021. In September 2021 both sued the association to quiet title under Idaho Code § 6-401³, seeking a declaration that their land was unencumbered by three recorded instruments: the First Declaration (Instrument No. 173855, recorded 4 January 2006), the First Restated Declaration (No. 174673, 8 February 2006), and the First Amendment (No. 239244, 15 December 2015).

They largely won that argument. The district court (Seventh Judicial District, Teton County, Senior District Judge Alan C. Stephens) found the First Declaration lacked an express description of the property to be encumbered, and that the First Restated Declaration created an ambiguity about what it was meant to encumber. That the covenants are void was never challenged on appeal.

The master plan the district court reached for

The plaintiffs' prayer, however, asked the court to declare that the association had no interest in the subject property. Because a recorded master plan was referenced in both owners' deeds and had been admitted at trial, the district court held it had to weigh that document too.

Treating the question as one of first impression, the district court turned to a Delaware Court of Chancery decision, New Castle County v. Pike Creek Recreational Services, LLC, 82 A.3d 731 (Del. Ch. 2013), and concluded that the master plan bound the land because it set limits on the number of lots, average lot size, acreage dedicated to roads and acreage preserved as open area. The Supreme Court affirmed that admitting the master plan into evidence was within the court's discretion — and then reversed everything built on it.

1. Vintage II, LLC v. Teton Saddleback Vistas HOA, Inc., Docket No. 51455 (Idaho, Sept. 10, 2025) (slip opinion) ↩
2. Vintage II, LLC v. Teton Saddleback Vistas HOA, docket record (CourtListener) ↩
3. Idaho Code § 6-401, action to quiet title (Idaho State Legislature) ↩