Ada Co Prosecuting Atty v. William Scott Demint, 161 Idaho 342

Background

DeMint was stopped for traffic violations; a search of his vehicle uncovered controlled substances, paraphernalia, and cash. Ada County initiated an in rem forfeiture action under I.C. § 37-2744(d)(1) against DeMint's vehicle, possessions, and $9,415.64 seized from his bank account.
Ada County obtained a warrant, seized the bank funds (received as a cashier's check), and proceeded to trial in district court (bench trial).
Evidence presented: DeMint had three large deposits prior to arrest, multiple large cash withdrawals the month before arrest roughly matching the amount of meth found, was unemployed at arrest, made a small restaurant purchase from the account the day he allegedly met his supplier in Ogden, and made jail calls instructing others to withdraw/transfer his account funds and expressing concern funds might be seized.
The district court granted DeMint's motion for directed verdict/involuntary dismissal, finding Ada County failed to prove the bank funds were more likely than not used or intended for use in drug trafficking; the court emphasized gaps such as lack of tracing and failure to eliminate other income sources.
Ada County appealed, arguing the district court applied a stricter standard than the required preponderance of the evidence.
The Court of Appeals held the district court misapplied the preponderance standard, found the evidence sufficient, vacated the forfeiture judgment, and remanded for further proceedings; costs on appeal awarded to Ada County (no attorney fees).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ada County proved by a preponderance that the seized bank funds were used or intended for use in connection with drug trafficking	Evidence (large deposits, withdrawals matching drug quantity, jail calls directing transfers, unemployment, purchase tied to supplier meeting) makes it more likely than not the funds were drug-related	County failed to trace funds, did not eliminate alternative income sources, and proof contained "holes" insufficient under the burden	Court of Appeals: District court applied too strict a standard; the presented evidence was sufficient under the preponderance standard—vacated and remanded
Whether district court applied proper procedural label for directed verdict in bench trial	County: substance of ruling should be reviewed under involuntary dismissal/substantial-evidence test	DeMint: district court's grant of directed verdict stands as judgment against plaintiff	Court: bench-trial ruling treated as involuntary dismissal; review uses substantial-evidence test; district court erred in its application of the burden
Whether failure to make explicit findings under I.R.C.P. 52 requires reversal	County: did not raise error on appeal	DeMint: no explicit challenge noted	Court: noted rule violation but neither party raised it; appellate court inferred findings from district court's stated reasons
Appropriate remedy following erroneous application of burden	County: vacate judgment and remand	DeMint: affirm dismissal	Court: vacated judgment and remanded for further proceedings; awarded costs to Ada County

Key Cases Cited

Durrant v. Quality First Marketing, Inc., 127 Idaho 558 (recognizing that in a bench trial the correct motion is involuntary dismissal)
Conley v. Whittlesey, 133 Idaho 265 (standard of appellate review for findings and conclusions from bench trials)
Hibbler v. Fisher, 109 Idaho 1007 (involuntary dismissal reviewed under substantial-evidence test)
General Auto Parts Co., Inc. v. Genuine Parts Co., 132 Idaho 849 (definition of substantial evidence that could support a verdict)
Chamberlin v. George, 63 Idaho 658 (deference to trial court findings supported by substantial evidence)
Staggie v. Idaho Falls Consol. Hosps., Inc., 110 Idaho 349 (appellate review: defer to factual findings, freely review legal conclusions)
In re Beyer, 155 Idaho 40 (definition of preponderance of the evidence)