Anderson v. Michel

In Anderson v. Michel, 88 Idaho 228, 398 P.2d 228 (1965), the Court stated, "Except under special circumstances, no fiduciary obligations exist between a buyer and seller of any property." 88 Idaho at 236-37, 398 P.2d at 232-33. In Mitchell, the Court gave examples of situations where a fiduciary relationship may arise, and held that an arm's length transaction between the parties would not qualify: "Mitchell argues that . . . a relationship of trust and confidence existed in this case for two reasons: (1) Mitchell trusted Barendregt, and (2) as parties to a contract, Mitchell and Barendregt were obliged to act in good faith toward one another. The law of contracts is clear that neither of these facts is sufficient to establish a relationship of trust and confidence from which the law will impose fiduciary obligations between Mitchell and Barendregt. Examples of relationships from which the law will impose fiduciary obligations on the parties include when the parties are: members of the same family, partners, attorney and client, executor and beneficiary of an estate, principal and agent, insurer and insured, or close friends. All the evidence presented in this case shows that Mitchell and Barendregt shared none of these relationships, but were parties who entered into an agreement at arms length." Id. at 844, 820 P.2d at 714.