Byron J. Johnson

This case concerned applications by the Idaho Watersheds Project (IWP) for grazing leases on state endowment public lands, where the State Board of Land Commissioners denied IWP qualified applicant status and lease awards under I.C. § 58-310B based on criteria including impacts on the state and livestock industry. IWP sued, seeking a declaratory judgment that the statute was unconstitutional under Article IX, § 8 of the Idaho Constitution and judicial review of the Board's decisions. The court held that I.C. § 58-310B violates the constitutional requirement that the Board secure the maximum long-term financial return to the schools through public auctions of endowment lands, because the statute impermissibly directs consideration of factors other than that return. The court therefore reversed the trial court's ruling, invalidated the relevant 1996 lease awards, and remanded for new auctions under the procedures of I.C. § 58-310.

propertyenvironment

This case is a criminal appeal in which defendant Byington challenged his convictions on grounds including the validity of a search warrant, the admission of certain seized materials under Idaho Rule of Evidence 403, and the trial court's decision to permit testimony from a prosecution witness disclosed only after jury selection. The Idaho Supreme Court adopted multiple portions of the Court of Appeals opinion upholding the warrant, the sufficiency of the evidence, and sentencing. On the evidentiary issues left for review, the Court held that the trial court did not abuse its discretion in conducting the Rule 403 balancing test and that substantial competent evidence supported the finding of no unfair prejudice from the late-disclosed witness, so the trial court acted within its discretion in allowing the testimony.

criminal lawprocedure

This case involved a personal injury lawsuit brought by Raedean Inama and her daughter after their vehicle was rear-ended by a truck driven by an employee of the defendants' business. The plaintiffs sought damages, and the trial court permitted juror questions, gave instructions directing the jury to disregard tax consequences of any award, excluded certain hearsay testimony from the defendants' vocational expert, and denied discretionary costs. On appeal, the court affirmed the judgment awarding damages to the injured parties and the denial of discretionary costs. The core reasoning was that the trial court's handling of the tax-related jury instructions and expert testimony was proper, that the court made sufficient findings regarding the routine nature of the requested costs under procedural rules, and that constitutional challenges to cost rules were not preserved for review.

torts & liabilityprocedure

This case concerned whether Idaho's system for funding public school facilities complied with the state constitution's mandate under Article IX, § 1 to establish and maintain a thorough system of public, free common schools. Plaintiffs, including school districts and students, alleged deficiencies in providing safe learning environments and sought declarations on equalization of capital expenditures and limits on special levies. The court vacated summary judgment on the safe facilities claim, ruling that the legislature must supply a funding mechanism for such facilities, and remanded for further proceedings to assess compliance. It upheld dismissal of the equalization and levy claims, as well as the denial of the state's requests to add third-party complaints or dismiss certain student plaintiffs, finding those districts not indispensable given the relief sought.

civil rightsprocedure

This case involved a passenger in a vehicle stopped by police due to traffic violations and outstanding warrants for the driver, who was arrested. Officers directed the passenger to leave her purse in the car, then searched the vehicle incident to the driver's arrest and found methamphetamine inside the purse. The trial court denied the passenger's motion to suppress the evidence, relying on New York v. Belton to uphold the search as incident to arrest. The Idaho Supreme Court held that Belton authorizes a search of the passenger compartment and containers within reach of the arrestee but does not permit the search of another occupant's personal property that the passenger was entitled to remove, and it vacated the denial of suppression while remanding for further proceedings.

criminal lawcivil rightsprocedure

This case is a breach of contract and breach of warranty dispute under the Idaho UCC sales provisions arising from J.R. Simplot Company's purchase of specialized equipment from EnviroClear Company, Inc. for use at one of Simplot's plants. After problems with the equipment, Simplot sued; the trial court granted EnviroClear a directed verdict dismissing the claims. The Idaho Supreme Court vacated the judgment and remanded for a new trial, holding that the statute of frauds was satisfied by Simplot's acceptance of and payment for the goods and that Simplot's evidence raised genuine factual questions about whether the performance guarantee and warranty disclaimer in EnviroClear's second revised proposal were part of the parties' agreement. Those credibility and contract-formation issues should have been submitted to the jury instead of being resolved by directed verdict.

business & regulatoryprocedure