Idaho Supreme Court
D.L. Evans Bank v. Dean
October 30, 2023
Summary
The Idaho Supreme Court affirmed judgment for D.L. Evans Bank on its action to enforce a prior default judgment. It held that Dean voluntarily submitted to personal jurisdiction by filing a general notice of appearance, that timely orders renewing the original judgment restarted the six-year limitations period, and that Dean could challenge the judgment as void under Rule 60(b)(4) at any time but failed to show that it was void because he had actual notice of the underlying action. The Court also awarded the bank reasonable appellate attorney fees under the commercial guaranty.