State v. Wade Lamonte Peterson, 280 P.3d 184

Peterson appealed a district court denial of his motion for reimbursement of fines, fees, and restitution paid under a felony conviction later vacated on appeal.
In 2003 Peterson was charged with felony possession of a controlled substance and misdemeanors; a lab-delay led to disposition changes and a plea resolving mostly to misdemeanors.
In 2004 Peterson pled guilty to a felony after a sequence of filings; the district court sentenced him and ordered various financial penalties.
In 2010 the Idaho Supreme Court vacated the felony conviction, determining the plea did not encompass all charges; the district court then dismissed the case in 2010/2011.
Peterson paid approximately $520 in costs, fines, and restitution in 2006–2007; he sought reimbursement after the conviction was vacated.
The district court denied the reimbursement motion, finding lack of personal jurisdiction over nonparty agencies and lack of subject matter jurisdiction to amend the final dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court had jurisdiction to hear the reimbursement motion	Peterson argues Rule 60(b) or related rules extend jurisdiction after final judgment.	State contends Jakoski and related rules limit post-judgment jurisdiction for such motions.	District court lacked jurisdiction to hear the motion.
Whether Rule 60(b) applies to restitution-related reimbursement motions	Peterson relies on Mosqueda/Hartwig to treat restitution as civil and potentially within Rule 60(b).	Restitution under I.C. § 37-2732 is not the same as civil relief; no applicable Rule 60(b) basis extends jurisdiction here.	Rule 60(b) does not extend jurisdiction for this reimbursement motion.
Whether the district court had personal jurisdiction over nonparty agencies receiving funds	If funds were not disbursed, or if jurisdiction could be implied, reimbursement should be ordered.	Hooper requires service or submission to jurisdiction over the agencies; absent that, no relief.	District court lacked personal jurisdiction to order refunds from nonparty agencies.
Whether equity or inherent authority could support reimbursement	Peterson invokes equity and the court's inherent authority to grant relief.	Harper/Compton show only exceptional circumstances; none here justify extending jurisdiction.	Equity cannot extend jurisdiction to entertain the merits of the motion.

State v. Jakoski, 139 Idaho 352 (2003) (final judgment limits trial court's jurisdiction to amend or set aside absent a extending rule)
State v. Jensen, 149 Idaho 758 (Ct.App.2010) (restitution proceedings under 19-5304 may differ from 37-2732; timing limits analyzed)
State v. Mosqueda, 150 Idaho 830 (Ct.App.2010) (restitution civil in nature; Rule 60(b) arguments discussed)
State v. Hartwig, 150 Idaho 326 (2011) (civil nature of certain obligations; Rule 60(b) applicability discussed)
State v. Johnson, 152 Idaho 41 (2011) (appeals in sex-offender context; jurisdictional rules for civil actions following dismissal)
State v. Giovanelli, 152 Idaho 717 (Ct.App.2012) (must pursue civil action for certain post-dismissal relief)
Crooks v. Maynard, 112 Idaho 312 (1987) (district court supervisory authority over clerk; limitations on relief)
Hooper v. State, 150 Idaho 497 (Ct.App.2011) (personal jurisdiction over state agencies needed for refund orders)
Curl v. Curl, 115 Idaho 997 (1989) (60(b)(5) limitations; res judicata / collateral estoppel context)
Merrick v. Pearce, 97 Idaho 250 (1975) (illustrates when 60(b)(5) relief applies due to modification of prior judgment)
Stuart v. State, 128 Idaho 436 (Ct.App.1996) (60(b)(5) limitation; Tribe not controlling for relief)