Idaho Case Commentaries

Khalsa v. Ridnour: Arbitration Finality, Implied Contractual Compliance-with-Law Terms, and Fee-Shifting for Merit-Based Vacatur Appeals

Date: Feb 11, 2026

Khalsa v. Ridnour: Arbitration Finality, Implied Compliance-with-Law Terms, and Attorney Fees for Appeals that Repackage Merits Challenges as “Exceeded Powers” I. Introduction Khalsa v. Ridnour...

Specific Performance Is a Remedy, Not a Stand-Alone Cause of Action; Breach Must Be Established Before Summary Judgment Grants Specific Performance

Date: Feb 10, 2026

Specific Performance Is a Remedy, Not a Stand-Alone Cause of Action; Breach Must Be Established Before Summary Judgment Grants Specific Performance I. Introduction In Cave Bay Community Services,...

Comparative Negligence and Pre-Injury “Mitigation” Cannot Reduce Damages for Constructive Fraud, Fiduciary Breach, or Unjust Enrichment

Date: Feb 8, 2026

Comparative Negligence and Pre-Injury “Mitigation” Cannot Reduce Damages for Constructive Fraud, Fiduciary Breach, or Unjust Enrichment I. Introduction Camp Magical Moments, Cancer Camp for Kids,...

Article IX, Section 1 Sets a Floor, Not a Ceiling: Idaho Upholds the Parental Choice Tax Credit and Applies Pragmatic Relaxed Standing

Date: Feb 7, 2026

Article IX, Section 1 Sets a Floor, Not a Ceiling: Idaho Upholds the Parental Choice Tax Credit and Applies Pragmatic Relaxed Standing Case: Committee to Protect and Preserve v. State (Supreme Court...

State v. Borek: Rule 503 Requires Proof of Treatment-Directed “Confidential Communications”; PMP and Pharmacy Dispensing Records Not Privileged

Date: Feb 5, 2026

State v. Borek: Rule 503 Requires Proof of Treatment-Directed “Confidential Communications”; PMP and Pharmacy Dispensing Records Not Privileged Introduction In State v. Borek (Idaho Feb. 4, 2026),...

State v. Smith: Exigent Circumstances Permit Warrantless Cellphone Seizure (with Probable Cause) to Prevent Imminent Destruction of Digital Evidence Pending a Prompt Search Warrant

Date: Feb 5, 2026

State v. Smith: Exigent Circumstances Permit Warrantless Cellphone Seizure (with Probable Cause) to Prevent Imminent Destruction of Digital Evidence Pending a Prompt Search Warrant 1. Introduction In...

Continuing Jurisdiction to Enforce Custody Orders Despite IRFLP 816 Noncompliance; Mandamus Barred by Available Appeal

Date: Feb 3, 2026

Continuing Jurisdiction to Enforce Custody Orders Despite IRFLP 816 Noncompliance; Mandamus Barred by Available Appeal Case: Baiz v. Magistrate Division Court: Supreme Court of Idaho Date: February...

State v. Barritt: Controlled-Environment Drug-Dog Certification Suffices for Probable Cause Despite Low Field “Hit Rate”

Date: Feb 1, 2026

State v. Barritt: Controlled-Environment Drug-Dog Certification Suffices for Probable Cause Despite Low Field “Hit Rate” 1. Introduction In State v. Barritt (Idaho Jan. 29, 2026), the Idaho Supreme...

Post-Judgment Fee Orders: Untimely Reconsideration Does Not Toll the Appeal Deadline, and a Later “Fee Judgment” Is Not a New Final Judgment

Date: Jan 24, 2026

Post-Judgment Fee Orders: Untimely Reconsideration Does Not Toll the Appeal Deadline, and a Later “Fee Judgment” Is Not a New Final Judgment 1. Introduction In Medical Recovery Services, LLC v. Wood...

Idaho Reaffirms the Common-Law Ban on Unreasonable Restraints on Alienation and Adopts the Restatement (Third) Utility-vs-Harm Test

Date: Jan 23, 2026

Idaho Reaffirms the Common-Law Ban on Unreasonable Restraints on Alienation and Adopts the Restatement (Third) Utility-vs-Harm Test Case: Smallwood v. Little (Idaho Supreme Court, Jan. 22, 2026) |...

Rule 54 Attorney-Fee Waiver: A Timely Memorandum Must Cite and Analyze the Fee Statute; a Complaint Reference or Later Supplement Cannot Cure

Date: Jan 21, 2026

Rule 54 Attorney-Fee Waiver: A Timely Memorandum Must Cite and Analyze the Fee Statute; a Complaint Reference or Later Supplement Cannot Cure I. Introduction In York v. Kemper Northwest, Inc. (Idaho...

Crookham v. County of Canyon: LLUPA “Affected Person” Standing Displaces Idaho’s Self-Imposed Lujan-Style Standing Test

Date: Jan 17, 2026

Crookham v. County of Canyon: LLUPA “Affected Person” Standing Displaces Idaho’s Self-Imposed Lujan-Style Standing Test 1. Introduction In Crookham v. County of Canyon (Idaho Jan. 16, 2026), the...

Vacatur of Custody Orders Eliminates Any Controlling Custody Schedule; Remand Requires New Temporary Orders and a Complete Best-Interests Analysis (Raber v. Raber)

Date: Jan 16, 2026

Vacatur of Custody Orders Eliminates Any Controlling Custody Schedule; Remand Requires New Temporary Orders and a Complete Best-Interests Analysis Case: Raber v. Raber (Supreme Court of Idaho, Jan....

Adverse Medical-Debt Credit Reporting Is Commercial Speech; Idaho Patient Act Preconditions to “Extraordinary Collection Actions” Survive First and Fourteenth Amendment Facial Challenges

Date: Jan 11, 2026

Adverse Medical-Debt Credit Reporting Is Commercial Speech; Idaho Patient Act Preconditions to “Extraordinary Collection Actions” Survive First and Fourteenth Amendment Facial Challenges Introduction...

State v. Frandsen: Text Exhibits Must Be Redacted for Unnoticed 404(b) “Other Acts” Even When Admitted for a Non-Hearsay Purpose; Prior Acquaintance Alone Does Not Establish Juror Bias

Date: Jan 9, 2026

State v. Frandsen: Text Exhibits Must Be Redacted for Unnoticed 404(b) “Other Acts” Even When Admitted for a Non-Hearsay Purpose; Prior Acquaintance Alone Does Not Establish Juror Bias Court: Supreme...

Idaho Code § 55-3211 Makes HOA Short-Term Rental Bans Property-Based Unless the Affected Owner Expressly Consents in Writing

Date: Jan 8, 2026

Idaho Code § 55-3211 Makes HOA Short-Term Rental Bans Property-Based Unless the Affected Owner Expressly Consents in Writing Introduction North Henry's Lake Homeowners Association, Inc. v. Bryan...

Stasiewicz v. South Henry’s Lake Outlet HOA / Henry’s Lake Village: Limits on Sua Sponte Res Judicata and “Mootness” Dismissals Under I.R.C.P. 12(b)(1)

Date: Jan 8, 2026

New Idaho Rule: Courts May Not Raise Res Judicata Sua Sponte, and Rule 12(b)(1) “Mootness” Dismissals Cannot Decide Intertwined Merits—Especially Where a Restrictive Easement Leaves Effectual Relief...

Compensable Consequences in Idaho: Recurrent Injury Remains Compensable Absent Proof of Rash or Deliberate Disregard

Date: Jan 8, 2026

Compensable Consequences in Idaho: Recurrent Injury Remains Compensable Absent Proof of Rash or Deliberate Disregard Introduction Miklos v. L&W Supply Corporation (Idaho Supreme Court, Jan. 6, 2026)...

TEDRA Grants District Courts Broad Subject-Matter Jurisdiction to Decide Declaratory Rights in Estate Assets Despite Ongoing Probate

Date: Jan 7, 2026

TEDRA Grants District Courts Broad Subject-Matter Jurisdiction to Decide Declaratory Rights in Estate Assets Despite Ongoing Probate Introduction Nelson v. Wylie (Idaho Supreme Court, January 6,...

Jurisdiction Requires a Timely Petition Identifying the Operative Agency Order (Superseding Methodology Orders Must Be Appealed)

Date: Jan 3, 2026

Jurisdiction Requires a Timely Petition Identifying the Operative Agency Order (Superseding Methodology Orders Must Be Appealed) Case: City of Idaho Falls v. IDWR Court: Supreme Court of Idaho Date:...

Previous Next