Idaho Case Commentaries

When a Tax Statute’s Applicability Date Controls Over Its Emergency-Clause Effective Date: Idaho’s Corporate Rate Cut Applies to Any “Taxable Year Commencing on and After January 1, 2001”

Date: Apr 24, 2026

When a Tax Statute’s Applicability Date Controls Over Its Emergency-Clause Effective Date: Idaho’s Corporate Rate Cut Applies to Any “Taxable Year Commencing on and after January 1, 2001” Case: WAFD,...

Juvenile Corrections Act “Accountability” Permits Detention and Other Dispositions Beyond Restitution/Service

Date: Apr 24, 2026

Juvenile Corrections Act “Accountability” Permits Detention and Other Dispositions Beyond Restitution/Service I. Introduction State v. Jane Doe (2024-29) is an Idaho Supreme Court decision affirming...

State v. Perez Garcia: Immigration Status May Be Considered for Probation Only as It Bears on Ability to Comply with Probation’s Law-Abiding Conditions

Date: Apr 17, 2026

Immigration Status and Probation in Idaho: Status Alone Is Not Disqualifying, but May Be Weighed When It Shows Inability to Comply with “Obey All Laws” Conditions Case: State v. Perez Garcia (Idaho...

State v. Lutz: Criminal Defendants May Initiate Nonsummary Contempt Under I.C.R. 42, but Contempt Requires Probable Cause of Conduct Within I.C. § 7-601 (Typically a Violated Court Order)

Date: Apr 8, 2026

State v. Lutz: Criminal Defendants May Initiate Nonsummary Contempt Under I.C.R. 42, but Contempt Requires Probable Cause of Conduct Within I.C. § 7-601 (Typically a Violated Court Order) I....

Uncertain Severance Timing and Inadmissible “Rights-by-Reputation” Proof Bar Summary Judgment for Implied Easements by Prior Use

Date: Apr 4, 2026

Uncertain Severance Timing and Inadmissible “Rights-by-Reputation” Proof Bar Summary Judgment for Implied Easements by Prior Use I. Introduction In Crystal Homestead Estates, LLC v. That Piece of...

State v. Campbell: Idaho Clarifies Inevitable Discovery Does Not Per Se Require a Separate “Parallel” Investigation

Date: Mar 28, 2026

State v. Campbell: Idaho Clarifies Inevitable Discovery Does Not Per Se Require a Separate “Parallel” Investigation Court: Supreme Court of Idaho Date: March 26, 2026 (Substitute Opinion withdrawing...

Best v. State: Mandatory 20-Day Notice for Sua Sponte Post-Conviction Dismissals on Unargued Grounds; Lack-of-Notice Claim Preservable First Time on Appeal

Date: Mar 28, 2026

Best v. State (Idaho 2026): Mandatory 20-Day Notice When a Court Sua Sponte Dismisses Post-Conviction Claims on Unargued Grounds; Lack-of-Notice Challenge May Be Raised First Time on Appeal 1....

Miller v. Miller: Idaho Confirms Divorce Arbitrability Under the UAA Despite “Exclusive Original Jurisdiction”

Date: Mar 27, 2026

Miller v. Miller: Idaho Confirms Divorce Arbitrability Under the UAA Despite “Exclusive Original Jurisdiction” I. Introduction Miller v. Miller (Idaho Sup. Ct. Mar. 24, 2026) squarely addresses...

Monson v. Monson — TEDRA Authorizes Standalone Civil Actions Parallel to Probate and Requires Joinder of Adverse Claimants to Estate-Related Property Interests

Date: Mar 20, 2026

Monson v. Monson — TEDRA Authorizes Standalone Civil Actions Parallel to Probate and Requires Joinder of Adverse Claimants to Estate-Related Property Interests Court: Supreme Court of Idaho Date:...

Abdullah v. State — No “Actual Innocence” Gateway to Idaho Code § 19-2719’s 42-Day Capital Post-Conviction Deadline

Date: Mar 3, 2026

No “Actual Innocence” Gateway to Idaho Code § 19-2719’s 42-Day Capital Post-Conviction Deadline Case: Abdullah v. State (Idaho Supreme Court) Date: March 2, 2026 Posture: Appeal from summary...

Unopposed Summary Judgment Still Requires Rule 56(a) Findings; Rule 11 Sanctions Cannot Rest Solely on Hearsay

Date: Mar 3, 2026

Unopposed Summary Judgment Still Requires Rule 56(a) Findings; Rule 11 Sanctions Cannot Rest Solely on Hearsay Case: Johnson v. SRM-Double L, LLC Court: Supreme Court of Idaho Date: March 2, 2026...

Johnson v. Beadz Brothers Farms: Counsel Declarations Are Insufficient to Admit Business Records on Summary Judgment; Rule 56(d) Requires Specific, Diligent Grounds for Discovery Continuances

Date: Mar 3, 2026

Johnson v. Beadz Brothers Farms: Counsel Declarations Are Insufficient to Admit Business Records on Summary Judgment; Rule 56(d) Requires Specific, Diligent Grounds for Discovery Continuances I....

Idaho Administrative Water Appeals: Jurisdiction Requires a Timely Petition Targeting the Operative (Superseding) Final Order

Date: Mar 3, 2026

Idaho Administrative Water Appeals: Jurisdiction Requires a Timely Petition Targeting the Operative (Superseding) Final Order I. Introduction City of Idaho Falls v. Idaho Department of Water...

Employment Alone Does Not Create a Special-Relationship Duty to Protect; Verbal Mediation Does Not Assume a Duty Against Third-Party Criminal Violence (Spears v. Antelope Mountain Resort, LLC)

Date: Mar 1, 2026

Employment Alone Does Not Create a Special-Relationship Duty to Protect; Verbal Mediation Does Not Assume a Duty Against Third-Party Criminal Violence (Spears v. Antelope Mountain Resort, LLC) Court:...

Jurisdiction Requires Appealing the Operative (Superseding) IDWR Methodology Order Within 28 Days

Date: Feb 27, 2026

Jurisdiction Requires Appealing the Operative (Superseding) IDWR Methodology Order Within 28 Days I. Introduction City of Idaho Falls v. Idaho Department of Water Resources (Idaho Sup. Ct. Feb. 25,...

Hyde v. Oxarango: Standing Limits Limited-Partner Litigation—Particularized Demand Futility and Distinct Injury Required

Date: Feb 22, 2026

Hyde v. Oxarango: Standing Limits Limited-Partner Litigation—Particularized Demand Futility and Distinct Injury Required Introduction Hyde v. Oxarango (Idaho Supreme Court, Feb. 20, 2026) arises from...

Bedell v. Parsons: A Deed Name Creates Only a Rebuttable Presumption—Co-Tenants May Prove 0% Ownership and Intent Disputes Bar Summary Judgment in Partition

Date: Feb 22, 2026

Bedell v. Parsons: A Deed Name Creates Only a Rebuttable Presumption—Co-Tenants May Prove 0% Ownership and Intent Disputes Bar Summary Judgment in Partition I. Introduction Case: Bedell v. Parsons...

On Remand for Resentencing, a New Magistrate Is Not Bound by a Prior Judge’s Off-the-Record Sentencing Assurance Absent an Explicit Remand Directive

Date: Feb 17, 2026

On Remand for Resentencing, a New Magistrate Is Not Bound by a Prior Judge’s Off-the-Record Sentencing Assurance Absent an Explicit Remand Directive I. Introduction State v. Salazar-Cabrera (Idaho...

Exceptional-Circumstances Exception to Issue Preservation in CID Bond Challenges (and Key CID Act Interpretations)

Date: Feb 15, 2026

Exceptional-Circumstances Exception to Issue Preservation in CID Bond Challenges (and Key CID Act Interpretations) Introduction Doyle v. The Harris Ranch Community Infrastructure District No. 1...

Discovery Defiance as Constructive Waiver: Default Sanctions, Record Limits, and Appellate Waiver in Idaho

Date: Feb 13, 2026

Discovery Defiance as Constructive Waiver: Default Sanctions, Record Limits, and Appellate Waiver in Idaho I. Introduction St. Luke's Health System, LTD v. Rodriguez (Idaho Supreme Court, Feb. 10,...