Larry Monroe Boyle

This case involved Jerry Lockhart's appeal of disciplinary actions (suspension, demotion, and reassignment) imposed by the Idaho Department of Fish and Game after his termination, following proceedings before the Idaho Personnel Commission. The district court dismissed Lockhart's appeal for lack of jurisdiction, finding that under the Administrative Procedure Act the notice should have been filed in Ada County where the hearings occurred, rather than Valley County where he resided. The Idaho Supreme Court reversed, holding that the Personnel System Act specifically provides for filing in the district court of the county where a party resides, making Valley County proper, and that the Department's jurisdictional challenge lacked a reasonable basis in law. The court remanded for a hearing on the merits and awarded Lockhart attorney fees under I.C. § 12-117.

labor & employmentprocedure

This case involved an insurance coverage dispute in which the State of Idaho and Idaho State University sought declaratory relief and reimbursement from Continental Casualty Company under a Board of Education liability policy for costs incurred in defending and settling employment discharge, tort, and civil rights claims in a prior lawsuit. Compass Insurance Company, which also provided coverage, had already paid a portion of the claim and was brought into the action by Continental. The trial court granted summary judgment to the State and ISU, finding coverage, and denied Continental's motion. On appeal, the Idaho Supreme Court identified the key issue as whether the State and ISU were entitled to judgment as a matter of law, emphasizing that only ISU was the named insured under the policy and that the State and Bureau of Risk Management were separate legal entities from ISU, which holds independent status as a body politic and corporate under state law. The court analyzed the policy terms and the universities' constitutional and statutory independence to determine the parties' contractual rights.

business & regulatorycivil rightstorts & liability

In this case, following their 1985 divorce, Marcia Bondy sued Paul Levy to enforce ongoing monthly payments required under a surviving property settlement agreement that characterized the payments as non-modifiable §71 payments for tax purposes. After a prior appeal in Bondy I, the trial court granted Bondy summary judgment for payments due after February 1989, rejecting Levy's arguments for renegotiation due to tax bracket changes, cessation upon remarriage or cohabitation, or frustration of purpose. On appeal, the Idaho Supreme Court reviewed the contract language and determined that section 9.03 was ambiguous as to the parties' intent and the effect of changed circumstances, allowing extrinsic evidence and precluding summary judgment as a matter of law. Dissenting justices contended that the plain language of the agreement controlled without ambiguity.

family lawtaxesprocedure

The case involved the appeal of Kathi L. Winn's conviction for first-degree murder after she poisoned her nine-year-old son by administering a lethal dose of the antidepressant Desipramine in hot chocolate, following her claim that a demon had directed the act. Winn challenged the conviction on multiple grounds, including the admission of autopsy photographs of the unclothed victim, the denial of a change of venue due to pretrial publicity, the exclusion of certain testimony about her mental and physical condition and alleged possession experiences, and the constitutionality of an Idaho statute providing that mental condition is not a defense to criminal charges. The court affirmed the conviction, holding that the trial judge acted within its discretion in admitting the photographs as relevant to the condition of the body and corpus delicti without unfair prejudice outweighing their probative value under I.R.E. 403, that the statutory change did not violate due process or the Eighth Amendment, and that other evidentiary rulings and the venue decision were not erroneous. The core reasoning centered on the trial court's broad discretion in evidentiary matters and the limited role of mental state evidence after the legislative repeal of prior insanity-related provisions.

criminal lawprocedure

In State v. Lavy, the defendant was charged with multiple counts involving the manufacture and possession of methamphetamine and cocaine and later pleaded guilty to one count each of manufacturing and possessing a controlled substance. On appeal, he challenged the trial court's failure to advise him of his right against self-incrimination at the plea hearing and the denial of his post-sentencing motion to withdraw the plea, which he claimed was based on an unfulfilled agreement that the court would retain jurisdiction for 120 days. The Idaho Supreme Court held that the advisement issue could not be raised for the first time on appeal because it did not amount to fundamental error, and it affirmed the denial of the motion to withdraw because the record showed the plea was voluntary with the only bargain being dismissal of other charges and no manifest injustice under the applicable standard. The court noted that sentencing errors in one count and other issues were not dispositive of the appeal's outcome.

criminal lawprocedure

This case involved a dispute over the scope of a statutory appropriation of water from Niagara Springs under I.C. § 67-4308, which authorized the Idaho Department of Parks and Recreation to claim unappropriated spring flow in trust for scenic and recreational uses. Rim View Trout Company, which sought additional water for its commercial fish hatchery, protested the application filed by the Department after the Idaho Department of Water Resources granted it subject to conditions based on an ambiguous reading of the statute. The district court reversed the agency's decision, and the Idaho Supreme Court affirmed, holding that the statute's language is clear and unambiguous in limiting the appropriation to the portion of the springs upstream from existing diversions to the headwaters. The court reasoned that plain statutory text must be applied without resort to rules of construction or policy considerations, and that the specified area protects the described flow for the declared beneficial uses while leaving other waters unaffected. The court also denied attorney fees to Rim View.

environmentproperty

This case concerned whether Haener Bros. and Albert J. Haener Equipment Rentals owed Idaho sales tax on fees charged for renting heavy equipment to Potlatch Corporation and its contractors, who used the equipment to construct, install, repair, and move production machinery at Potlatch facilities. The State Tax Commission assessed the tax after an audit; the Board of Tax Appeals found most rentals exempt under the production exemption in I.C. § 63-3622(d), but the district court reversed that ruling and upheld the assessment (while waiving penalties). The Idaho Supreme Court affirmed, holding that the exemption does not apply because the rented equipment was not used or consumed directly in the production process itself. The court reasoned that tax exemptions must be strictly construed against the taxpayer, that the statutory language and legislative history limit the exemption to items entering into the make-up of goods produced for resale, and that Haener remained the titleholder of the leased equipment.

taxesbusiness & regulatory

The case involved the Idaho Department of Law Enforcement seeking civil forfeiture of a pickup truck, $2,100 in cash, a revolver, and a sawed-off shotgun seized from James Peterson after his arrest for driving under the influence and discovery of cocaine in the vehicle. Peterson was convicted on a reduced charge of cocaine possession, and the magistrate court ordered forfeiture of all items under I.C. § 37-2744. On appeal, the Idaho Supreme Court affirmed forfeiture of the truck and cash, finding by a preponderance of the evidence that they were used to facilitate transportation, possession, or concealment of controlled substances. The court reversed forfeiture of the firearms, ruling that a more specific statute, I.C. § 19-3807, governs their confiscation rather than the general drug forfeiture provisions.

criminal lawprocedurepropertyguns

This products liability case arose when farm worker Larry Watson suffered a severe foot injury from a combine harvester's auger after the seed bridged in the tank, leading him and his wife to sue manufacturer Navistar (International Harvester) and dealer Dokken for negligence in design, manufacture, sale, setup, and inadequate warnings or instructions. A jury awarded damages and apportioned 58.9% negligence to Navistar, 41.1% to Watson, and 0% to Dokken, but post-trial juror affidavits suggested the verdict resulted from an agreement to average the jurors' individual assessments of negligence percentages and damages. The trial court granted a new trial on grounds of improper quotient verdict but denied Navistar's motion for judgment notwithstanding the verdict. On appeal, the Idaho Supreme Court vacated the new-trial order and remanded, holding that the district court had not considered all required factors and standards for determining whether the jury reached an impermissible averaging verdict, while affirming the denial of JNOV and other rulings including Dokken's potential inclusion in any retrial.

torts & liabilityprocedure

The case involved a plaintiff who obtained a judgment on a promissory note against a defendant and later sought attorney fees for post-judgment collection efforts, including debtor examinations. The district court awarded the fees, but the Idaho Supreme Court reversed, holding that I.C. § 12-120(3) does not authorize post-judgment fees because the underlying note merges into the judgment. The court further reasoned that Idaho Rule of Civil Procedure 54(d)(5) limits any cost memorandum to fourteen days after judgment entry, and no statute or rule provides for supplemental fees after that period. The decision vacated the fee award and remanded for an amended judgment.

procedure

In Reid v. Reid, the Idaho Supreme Court reviewed a trial court's modification of a child support order following the divorce of Richard and Vonda Reid, where the father, a self-employed farmer, challenged the calculation of his gross income for support purposes. The court affirmed the order requiring Mr. Reid to pay $317 per month in child support, declining to deduct straight-line depreciation on his farm equipment. The decision was based on the 1989 Child Support Guidelines, which gave the trial court discretion to exclude business expenses it found inappropriate for determining gross income and did not mandate a deduction for straight-line depreciation, unlike subsequent guidelines. The court held that the trial court did not abuse its discretion in this determination or in ordering the father to cover transportation costs with a credit applied.

family law

The case involved David Leslie Card's appeal from his first-degree murder convictions and death sentences for killing Eugene and Shirley Morey outside a convenience store in Nampa, Idaho. Card challenged the constitutionality of Idaho Code § 18-207 abolishing the insanity defense, the "utter disregard for human life" aggravating factor under § 19-2515, limits on post-conviction relief, and the use of a victim impact statement in the presentence report. The Idaho Supreme Court affirmed the convictions and sentences, relying on precedent from State v. Searcy to hold that due process does not require an insanity defense and that the trial court properly found aggravating circumstances outweighing any mitigators.

criminal law

This case involved a nursing home's challenge to the Idaho Department of Health and Welfare's denial of Medicaid reimbursement for costs exceeding an 80th-percentile cap under I.C. § 56-110 and related regulations. The facility argued it had rebutted the presumption of inefficiency by showing efficient operations and uncontrollable costs, but the Department relied solely on the cap to disallow over $47,000. The Idaho Supreme Court held that exceeding the cap creates only a rebuttable presumption, which the facility overcame with evidence of comparable costs and efficient management, and that the Department failed to present independent evidence of inefficiency. The court reversed the district court's affirmance of the agency's decision and remanded for further factual findings on whether the facility was efficiently operated and the extent of justified excess costs.

healthcarebusiness & regulatory

This case involved a divorce action in Idaho between Eileen Maslen and Holbrook Maslen, an airline pilot, where the only community assets were two United Airlines pension plans (a fixed benefit plan and a directed account plan). The magistrate divided the community portion of the pensions equally, calculated that portion by subtracting the value of benefits at the date of marriage from the value at divorce, and ordered a lump-sum distribution for the directed account plan and direct monthly payments for the fixed benefit plan. The district court and Court of Appeals affirmed, and the Idaho Supreme Court also affirmed on review. The court reasoned that under Idaho Code § 32-906, retirement benefits earned during marriage are community property that must be divided substantially equally absent compelling reasons, and the magistrate's calculation and distribution methods complied with established precedent on valuing and awarding such benefits.

family lawproperty

This case involves Richard A. Leavitt, who was convicted of first-degree murder in Idaho and initially sentenced to death. Following a prior reversal by the Idaho Supreme Court for inadequate weighing of mitigating circumstances against the aggravating factor and failure to consider alternative sentences, the district court held a new hearing, reweighed the factors under I.C. § 19-2515(g)(5), and again imposed the death penalty. On appeal, Leavitt challenged the constitutionality of the "exceptional depravity" aggravating circumstance as unconstitutionally vague under the Eighth Amendment, but the court rejected this based on prior limiting constructions from cases like State v. Osborn and precedents such as Walton v. Arizona, which distinguish judge-sentencing from jury-sentencing contexts. The Supreme Court affirmed the conviction and death sentence, determining that the evidence supported the aggravating circumstance and that the sentence was not arbitrary or disproportionate.

criminal law

This case involved members of the Kootenai Indian tribe from Canada, as heirs to Joseph Chiqui, suing attorney James F. Lyons for claims including fraud, negligent misrepresentation, concealment, malpractice, and rescission arising from his handling of their inheritance of trust land interests and the subsequent sale of those interests to a third party. The district court granted summary judgment to Lyons, but the Idaho Supreme Court affirmed in part, reversed in part, and remanded for trial on the remaining issues. The court determined that genuine questions of material fact existed concerning Lyons' alleged dual representation without disclosure or consent, failure to explain the transactions or provide appraisal information, and whether the heirs had sufficient knowledge of the facts constituting fraud to trigger the statute of limitations.

propertyproceduretorts & liability

The case involved a dispute between J.R. Simplot Company and its subsidiaries, including a Canadian affiliate, and the Idaho State Tax Commission over notices of tax deficiency. The Tax Commission had included the foreign subsidiary's worldwide unitary income in calculating Simplot's apportionable Idaho taxable income under state law, even though that income was not taxable under the Internal Revenue Code. On stipulated facts, the district court upheld the Commission's position, but the Idaho Supreme Court reversed. The court held that foreign source income may not be combined into Idaho taxable income for apportionment purposes unless it qualifies as taxable income under I.C. § 63-3022, which incorporates the federal definition from IRC § 63. The decision rested on a step-by-step reading of the statutes requiring taxable income to be determined first before any apportionment under I.C. § 63-3027.

taxesbusiness & regulatory

In State v. Moore, the defendant was charged with lewd conduct with his minor granddaughter and sought to exclude evidence of prior uncharged sexual misconduct involving his daughter and stepdaughter through a motion in limine. The district court denied the motion, ruling the evidence admissible under Idaho Rule of Evidence 404(b) to show a common scheme or plan, motive, lustful disposition, and specific intent. On appeal, the Idaho Supreme Court affirmed, holding that the trial court did not abuse its discretion because the testimony demonstrated a continuing pattern of similar acts directed at young female children in the defendant's household and was relevant to the victim's credibility and corroboration. The court applied a two-part test assessing relevance to a material issue and balancing probative value against unfair prejudice under Rule 403. A dissent argued that the corroboration rationale was no longer valid after the abolition of the mandatory corroboration requirement in sex crime cases.

criminal lawprocedure

This case involved a dispute between Kenneth Burns and Boundary County over the termination of a fixed-base operator and airport manager contract for the county airport. Burns sued for breach of contract, bad faith termination, and violations of due process rights under 42 U.S.C. § 1983, seeking damages including lost profits and emotional distress. The trial court found a breach but awarded only $45 in damages, dismissed the other claims, and granted limited attorney fees solely for obtaining a preliminary injunction under the contract terms and I.R.C.P. 54. The Idaho Supreme Court affirmed, holding that the trial court properly exercised its discretion by considering the litigation results relative to the relief sought and adhering to the contract's fee provisions and procedural rules.

business & regulatoryprocedurecivil rights

In Tanner v. State, Department of Health & Welfare, the Idaho Supreme Court considered an appeal from a magistrate's order terminating Merlin Poppe's parental rights to his two minor children, Sherry and Jimmie Joe, after the Department of Health and Welfare had taken legal custody under the Child Protective Act due to concerns over abuse and neglect. The court affirmed the termination, holding that the magistrate's findings were supported by clear and convincing evidence of Poppe's physical abuse of the children, failure to attend parenting classes or provide financial support, unstable housing, and lack of engagement with reunification efforts despite offers of anger management and other programs. The opinion applied the established "clearly erroneous" standard of review for factual findings in parental termination cases under Idaho law and the Fourteenth Amendment, concluding that termination served the children's best interests.

family law