Idaho Case Commentaries

Bypassing Batson Step One in Idaho: State v. Buck Clarifies Hernandez Mootness and Affirms Broad Trial-Court Discretion

Date: Oct 2, 2025

Bypassing Batson Step One in Idaho: State v. Buck Clarifies Hernandez Mootness and Affirms Broad Trial-Court Discretion Introduction In State v. Buck, the Idaho Supreme Court affirmed the conviction...

Master Plans Are Not Self-Executing: Idaho Supreme Court Holds Deed-Referenced Master Plans Are Relevant but Do Not Create Restrictive Covenants or Public Dedications Without Clear, Express Language

Date: Sep 11, 2025

Master Plans Are Not Self-Executing: Idaho Supreme Court Holds Deed-Referenced Master Plans Are Relevant but Do Not Create Restrictive Covenants or Public Dedications Without Clear, Express Language...

No-Modification Means No-Modification: Idaho Supreme Court Clarifies Grandfathered Lake Encroachments, Procedures, and Abatement Enforcement

Date: Sep 6, 2025

No-Modification Means No-Modification: Temporary Post‑1974 Changes Defeat Grandfathered Lake Encroachment Permits; § 58‑1306 Procedures Inapplicable; Administrative Abatement Requires Judicial...

Limiting Anderson’s First‑Filed Rule: District Courts Need Not Defer to the Industrial Commission on Idaho Code § 72‑209(3) “Willful or Unprovoked Physical Aggression” — Dominguez Partially Overruled

Date: Sep 5, 2025

Limiting Anderson’s First‑Filed Rule: District Courts Need Not Defer to the Industrial Commission on Idaho Code § 72‑209(3) “Willful or Unprovoked Physical Aggression” — Dominguez Partially Overruled...

Row v. State: Shinn Is Not a Trigger for Successive State Post‑Conviction Relief and Rule 44.2 Does Not Create a Right to Effective Post‑Conviction Counsel

Date: Sep 5, 2025

Row v. State: Shinn Is Not a Trigger for Successive State Post‑Conviction Relief and Rule 44.2 Does Not Create a Right to Effective Post‑Conviction Counsel Introduction In Row v. State, the Idaho...

Fraud Scienter Clarified and Disclosure Act Accrual Fixed at Closing: The Idaho Supreme Court’s Dual Holdings in VanRenselaar v. Batres

Date: Sep 5, 2025

Fraud Scienter Clarified and Disclosure Act Accrual Fixed at Closing: The Idaho Supreme Court’s Dual Holdings in VanRenselaar v. Batres Introduction In VanRenselaar v. Batres, the Idaho Supreme Court...

Closing a Deed‑Reserved Highway Connection Is a Compensable Taking: Idaho Supreme Court Clarifies Substantial Impairment and Deed‑as‑Contract Enforcement

Date: Sep 4, 2025

Closing a Deed‑Reserved Highway Connection Is a Compensable Taking: Idaho Supreme Court Clarifies Substantial Impairment and Deed‑as‑Contract Enforcement Introduction In Bear Crest Limited LLC v....

County Plat Changes Cannot Strip CC&Rs: Idaho Supreme Court Clarifies Applicability, Road Construction, and Injunction Specificity in Jordan v. Powers

Date: Aug 31, 2025

County Plat Amendments Cannot Remove Land from CC&Rs; Roads Are Not Categorically Barred but Require Design Committee Approval Case: Jordan v. Powers, Supreme Court of Idaho (Aug. 28, 2025)...

Riverside Reaffirmed: Idaho Supreme Court Confirms Bench-Trier May Resolve Conflicting Inferences at Summary Judgment; No “Rent Substitution” Credit for Affiliate-Funded Construction Absent Proof

Date: Aug 31, 2025

Riverside Reaffirmed: Bench-Trier Summary Judgment and the Limits of “Rent Substitution” under a Triple‑Net Lease Introduction In Erie Properties, LLC v. Global Growth Holdings, Inc., the Idaho...

State v. McGuire: Idaho Supreme Court Clarifies Dual “Duty” Standards—Broad for Felony Battery on Officers, Narrow (Lawfulness-Dependent) for Resisting; Burden-Shifting Misconduct Cured by Prompt Judicial Intervention

Date: Aug 31, 2025

State v. McGuire: Idaho Supreme Court Clarifies Dual “Duty” Standards—Broad for Felony Battery on Officers, Narrow (Lawfulness-Dependent) for Resisting; Burden-Shifting Misconduct Cured by Prompt...

“Tax Debt = Debt”: The Idaho Supreme Court Requires Tax-Relief Firms to Obtain Collection-Agency Licences — Comment on Wall & Associates, Inc. v. Idaho Department of Finance (2025)

Date: Aug 25, 2025

“Tax Debt = Debt”: The Idaho Supreme Court Requires Tax-Relief Firms to Obtain Collection-Agency Licences Commentary on Wall & Associates, Inc. v. Idaho Department of Finance, 174 Idaho ___ (2025) 1....

“Mission-Based Use” as a Religious Purpose: Idaho Supreme Court Broadens the Scope of the § 63-602B Property-Tax Exemption

Date: Aug 25, 2025

“Mission-Based Use” as a Religious Purpose: Idaho Supreme Court Broadens the Scope of the § 63-602B Property-Tax Exemption Introduction First Presbyterian Church of Boise, Idaho, Inc. (FPC) sought a...

Westman v. ISIF: The “Sole-Cause” Clarification of Idaho Code § 72-332 Liability

Date: Aug 25, 2025

Westman v. Industrial Special Indemnity Fund: The Supreme Court of Idaho Clarifies the “Sole-Cause” Exception to Fund Liability under Idaho Code § 72-332 Introduction In Westman v. Industrial Special...

State v. Frias: Clarifying Proximate Causation and the “Criminal-Negligence” Threshold under Idaho Code § 18-7004

Date: Aug 25, 2025

State v. Frias: Clarifying Proximate Causation and the “Criminal-Negligence” Threshold under Idaho Code § 18-7004 Introduction In State v. Frias, Docket No. 50950-2023 (Idaho Aug. 20, 2025), the...

DeKlotz v. NS Support, LLC – Medical Liens Under I.C. § 45-704B Are “Extraordinary Collection Actions” Requiring Full Compliance with the Idaho Patient Act

Date: Aug 25, 2025

Medical Liens Under I.C. § 45-704B Are “Extraordinary Collection Actions”: Commentary on DeKlotz v. NS Support, LLC, 174 Idaho ___ (2025) 1. Introduction In DeKlotz v. NS Support, LLC the Idaho...

Idaho Supreme Court Abandons Statute-of-Limitations Bar for Easements by Necessity and Expands Discretion to Revisit “Law-of-the-Case”: Easterling v. Clark (“Easterling II”)

Date: Aug 25, 2025

Idaho Supreme Court Abandons Statute-of-Limitations Bar for Easements by Necessity and Expands Discretion to Revisit “Law-of-the-Case” Doctrine: Detailed Commentary on Easterling v. Clark (2025) 1....

“No Shortcuts to Summary Judgment” – Rupp v. City of Pocatello and the Idaho Supreme Court’s Dual Message on Discovery Diligence and Rule 56 Analysis

Date: Aug 25, 2025

“No Shortcuts to Summary Judgment” – Rupp v. City of Pocatello and the Idaho Supreme Court’s Dual Message on Discovery Diligence and Rule 56 Analysis Introduction Rupp v. City of Pocatello, 174 Idaho...

Smith v. State: Defining the Limits of “Counsel Abandonment” and Pro-Se Filings in Idaho Post-Conviction Practice

Date: Aug 25, 2025

Smith v. State: Defining the Limits of “Counsel Abandonment” and Pro-Se Filings in Idaho Post-Conviction Practice 1. Introduction The Idaho Supreme Court’s 2025 decision in Smith v. State, Docket No....

Hansen v. Boise School District #1: Personal Property Injury as a Prerequisite to Takings Standing

Date: Aug 19, 2025

Hansen v. Boise School District #1 (Idaho 2025): Personal Property Injury as a Prerequisite to Takings Standing 1. Introduction In Hansen v. Boise School District #1, the Supreme Court of Idaho...

No Stand-Alone “Community Caretaking” Exception: State v. Adams and the Constitutional Limits on Searching Civilly-Committed Patients

Date: Aug 13, 2025

No Stand-Alone “Community Caretaking” Exception: State v. Adams and the Constitutional Limits on Searching Civilly-Committed Patients Introduction State v. Adams, 50841 (Idaho Aug. 11 2025), squarely...

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