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

This case concerned the Idaho Department of Health and Welfare's effort to recover the unpaid balance of Medicaid payments made to Hildor Knudson from the estate of her surviving spouse, Lionel Knudson, after a marriage settlement agreement had converted most of their community property into separate property to qualify Hildor for benefits. The Court held that Idaho Code § 56-218(1) authorized recovery from a surviving spouse's estate when the recipient's own estate was insufficient, but federal Medicaid law under 42 U.S.C. § 1396p(b) preempted recovery from Lionel's separate property and limited it to any community property accumulated after the agreement. The Court reasoned that the state statute's plain language and legislative intent permitted charging the surviving spouse's estate for the balance, while federal restrictions on "assets" and "estate" definitions excluded pre-agreement transmuted property, even under later amendments that did not apply retroactively. The case was remanded for further proceedings to determine if any recoverable community property existed.

healthcarefederal powerfamily lawproperty

In State v. Muraco, the defendant was charged with lewd conduct with a minor child under sixteen and challenged the trial court's pretrial ruling allowing the State to introduce evidence of his 1988 Nevada felony conviction for lewdness with a minor, both to impeach his credibility under Idaho Rule of Evidence 609 and for other purposes under Rule 404(b). The trial court admitted the evidence after a hearing, provided limiting instructions to the jury, denied the defendant's requested confabulation instruction, and imposed a unified life sentence with ten years fixed. On review, the Idaho Supreme Court affirmed the conviction and sentence, holding that the prior conviction was relevant to credibility under the framework from State v. Bush and Ybarra because it fell into an intermediate category of offenses, that the trial court did not abuse its discretion in finding the probative value outweighed prejudice, and that the defendant's remaining claims regarding jury instructions and sentencing lacked merit.

criminal lawprocedure

This case concerned the suppression of evidence seized after a warrantless entry into a residence triggered by 911 hang-up calls traced to the address. The trial court suppressed the statements and physical evidence on the ground that the deputy lacked justification to enter. On appeal, the Idaho Supreme Court vacated the suppression order and remanded for further proceedings. The court reasoned that the traced 911 calls gave officers a valid purpose to respond, and the deputy’s observation of a straw and lighter recognized as drug packaging created reasonable suspicion supporting a Terry stop at the doorway, permitting entry to continue the investigation under the Fourth Amendment. The defendant raised no claim under the Idaho Constitution.

criminal lawprocedure

This case involved a dispute over the nonrenewal of a public school teacher's half-time contract for the 1992-93 school year in Idaho Falls School District No. 91. The teacher, Julie Rhoades, challenged the district's attempt to end her employment after one year, arguing that proper procedures under Idaho Code § 33-514 were not followed by the board of trustees. The Idaho Supreme Court held that because the board failed to take the required action to notify the teacher of nonrenewal, she must be treated as having been reemployed for the 1993-94 school year as a half-time employee. The court reasoned that the statute mandates specific board action for nonrenewal, and failing to act equates to reemployment to give effect to the legislative requirements, though relief was limited to one year due to the timing of the lawsuit. The case was remanded for calculation of compensation.

labor & employmentprocedure

This case concerned the accrual of prejudgment and postjudgment interest on an indemnification award after Searle Brothers deposited funds with the court clerk to satisfy a judgment arising from contaminated seed wheat sales and settlements by Rosalia Producers. The trial court ruled that the deposit constituted a valid satisfaction under Idaho Code § 10-1115, stopping prejudgment interest on the date of deposit and limiting postjudgment interest accordingly, even after a remand to add prejudgment interest. On appeal, the Idaho Supreme Court affirmed, holding that the deposit effectively satisfied the judgment and applied precedents from Mitchell v. Flandro to determine that interest ceased accruing upon satisfaction rather than continuing until a later amended judgment. The court rejected arguments for using nunc pro tunc orders or equitable exceptions to extend interest accrual, emphasizing that the deposit met statutory requirements for release and satisfaction. It also declined to address attorney fees requests due to procedural noncompliance with appellate rules.

procedure

This case involved a boundary dispute between adjacent landowners, the Johnsons and the Newports, over property in Power County, Idaho, where an old fence built over sixty years ago did not align with the true property line as determined by a 1995 survey. The Johnsons sued to quiet title based on the old fence as the boundary, while the Newports counterclaimed for recognition of the true line. The trial court ruled in favor of the Johnsons, finding an implied boundary agreement, and the Idaho Supreme Court affirmed this decision. The court reasoned that the long existence and recognition of the fence as a boundary, combined with the parties' and predecessors' exclusive use of the land on their respective sides and the prior uncertainty of the true boundary, supported a presumption of implied agreement under Idaho law.

property

This case involved an independent action under Idaho Rule of Civil Procedure 60(b) by Barbara Davis to set aside a 1993 quiet title decree obtained by her half-sister Carol Parrish, who had served process by publication and defaulted Davis in a suit claiming sole ownership of inherited property. The trial court granted summary judgment for Parrish on grounds including res judicata, untimeliness, and insufficient proof of fraud on the court. The Idaho Supreme Court held that the action was not barred by res judicata and was brought within a reasonable time after Davis learned of the decree, but affirmed dismissal because Parrish's statements did not rise to the level of fraud on the court, which requires more than misrepresentation between parties or to obtain jurisdiction. The court reasoned that the alleged inaccuracies in Parrish's filings did not constitute tampering with the judicial process sufficient to undermine the integrity of the court's institutions.

propertyprocedure

This case arose after a jury awarded compensatory and punitive damages to Jennifer Fish and her parents in a personal injury lawsuit stemming from a multi-vehicle accident involving a school bus. As the prevailing party, Fish sought costs including expert witness fees, travel, lodging, and photocopying, which the trial court granted in part as a matter of right but denied as discretionary costs under Idaho Rule of Civil Procedure 54(d)(1)(D) on the ground that the expenses were not exceptional. Fish appealed the denial, arguing that the trial court failed to properly define exceptional or make item-by-item findings. The Idaho Supreme Court affirmed, holding that the trial court correctly perceived the issue as discretionary, acted within the applicable legal standards by finding the costs necessary and reasonable but not exceptional in the context of a serious personal injury case, and reached its decision through an exercise of reason supported by express findings.

proceduretorts & liability

The case Allen v. Dunston involved a dispute over whether the Allens had a contractual right to an easement for a well on property in which Dunston held a life estate. The court held that no contract existed because the parties' communications did not demonstrate a meeting of the minds, as they left open whether a lease or easement would be used and required consent from a third party that was never obtained. It also rejected claims based on estoppel and implied-in-fact contract due to lack of clear representations or inferred agreements. The court remanded the case to the trial court to determine whether Dunston was unjustly enriched.

propertyprocedure

The case involved Trudy Deen, whose driver's license was suspended after she refused an evidentiary blood alcohol test following a traffic stop. The magistrate judge upheld the suspension, but the district judge reversed it; the Idaho Supreme Court reinstated the suspension. The court reasoned that the officer had reasonable and articulable suspicion to stop Deen based on her activating her turn signal but failing to turn at three intersections, indicating inattentive driving in violation of traffic laws, and that this met the 'legal cause' standard under the relevant statute. The stop occurred around midnight, adding to the objective basis for concern about public safety.

criminal lawprocedure

This case involved a worker's compensation claim by Jose Luis Reyes against Kit Manufacturing Company for aggravation of his preexisting bilateral carpal tunnel syndrome due to his job duties installing floors in trailers. The Industrial Commission denied benefits, finding that the condition was not compensable because it was preexisting and the aggravation was not caused by an accident as required by Idaho law. The Idaho Supreme Court affirmed this decision, reaffirming its prior ruling in Nelson v. Ponsness-Warren Idgas Enterprises that compensation for aggravation of a preexisting condition requires proof of an accident aggravating the condition. The court based its reasoning on the applicable workers' compensation statutes, which do not impose liability on the last employer for preexisting occupational diseases without such an accident, and principles of stare decisis.

labor & employment

This case involved a minor patient, John Doe, suing a hospital for negligent hiring and supervision after a respiratory therapist, Fred Garcia, sexually molested him following Garcia's termination from the hospital. The trial court granted summary judgment to the hospital, but the Idaho Supreme Court reversed, holding that genuine issues of material fact existed regarding the hospital's negligence. The court reasoned that the hospital failed to adequately investigate Garcia's prior termination from another facility for molesting a patient, which could have been revealed through his personnel file, and that the hospital's Employee Assistance Program counselor had a duty to disclose Garcia's admitted sexual propensities to other hospital staff despite confidentiality policies. The decision focused on foreseeability and duty in the context of pre-termination conduct, while noting that the abuse occurred after Garcia's employment ended.

torts & liabilityhealthcarelabor & employment

In this death penalty case, Timothy Alan Dunlap pled guilty to first-degree murder and was sentenced to death in 1992; his direct appeal was affirmed, but his prior counsel had not filed a state post-conviction relief application within the 42-day deadline under Idaho Code § 19-2719(4). After new counsel was appointed in federal habeas proceedings, they discovered the omission and filed a petition almost two years late alleging ineffective assistance, which the trial court dismissed for lack of jurisdiction. The Idaho Supreme Court vacated the dismissal and remanded for further proceedings, holding that Dunlap presented a prima facie showing he did not know and could not reasonably have known about the failure to file until new counsel was appointed. The court further concluded that filing the petition within 42 days after that appointment satisfied the requirement to assert such claims within a reasonable time after they are known or reasonably could have been known.

criminal lawprocedure

Karen Zaleha sued her husband's former law firm and its shareholders for tort damages including civil conspiracy, negligence, emotional distress, tortious interference, and loss of consortium, based on the firm's actions against her husband such as termination, contesting unemployment benefits, and intervening in bankruptcy. The trial court granted summary judgment to the defendants, and the Idaho Supreme Court affirmed, holding that the defendants owed no duty to Karen because their conduct was directed solely at her husband and any injury to her was indirect. The court also upheld the award of attorney fees to the defendants and noted that loss of consortium claims must be pursued in conjunction with the injured spouse's action to avoid duplication and inconsistency.

torts & liabilityprocedurefamily law