Idaho Case Commentaries

Shelstad v. Pacific Life Insurance Company — Economic Loss Rule Bars Negligence Claims Against Insurers for Third‑Party Investment Losses Absent a Recognized “Special Relationship”; Apparent Authority Cannot Extend Beyond the Principal’s Manifestations and Express Disclaimers

Date: Sep 18, 2026

Economic Loss Rule Bars Negligence Claims Against Insurers for Third‑Party Investment Losses Absent a Recognized “Special Relationship”; Apparent Authority Cannot Extend Beyond the Principal’s...

Post-Conviction Summary Dismissal Reversed: A Petitioner’s Admissible Affidavit Can Create a Material Fact Dispute Over Counsel’s Failure to Convey Plea Acceptance

Date: Sep 16, 2026

Post-Conviction Summary Dismissal Reversed: A Petitioner’s Admissible Affidavit Can Create a Material Fact Dispute Over Counsel’s Failure to Convey Plea Acceptance Case: Ennis Jr. v. State of Idaho...

Amended Judgments Do Not Reset Post‑Judgment Interest: Interest Runs from the Entry Date of the Unreversed Money Award

Date: Sep 12, 2026

Amended Judgments Do Not Reset Post‑Judgment Interest: Interest Runs from the Entry Date of the Unreversed Money Award 1. Introduction In SNAP! MOBILE v. VERTICAL RAISE (Idaho Supreme Court, Sept....

Statutory Extraterritorial Arrest Violations Do Not Trigger Idaho’s Exclusionary Rule Absent a Constitutional Breach (State v. Satterfield)

Date: Sep 12, 2026

Statutory Extraterritorial Arrest Violations Do Not Trigger Idaho’s Exclusionary Rule Absent a Constitutional Breach (State v. Satterfield) 1. Introduction In State v. Satterfield (Idaho Sept. 11,...

Judicially Enforceable “Clear and Concise” Yes/No Effect Statements: Substantial-Compliance Review Under Idaho Code § 34-1810(1)(b)

Date: Sep 8, 2026

Judicially Enforceable “Clear and Concise” Yes/No Effect Statements: Substantial-Compliance Review Under Idaho Code § 34-1810(1)(b) I. Introduction Idahoans United v. McGrane/Labrador [SUBSTITUTE] is...

Byrd v. Coffey: Preponderance Standard Governs Declaratory Judgments Interpreting Ambiguous Deeds Before Applying Quiet-Title Burdens

Date: Sep 5, 2026

Byrd v. Coffey: Preponderance Standard Governs Declaratory Judgments Interpreting Ambiguous Deeds Before Applying Quiet-Title Burdens Supreme Court of Idaho (Sept. 4, 2026) 1. Introduction Byrd v....

Unscheduled Lease-Option Rights Remain Bankruptcy Estate Property, Defeating Debtor Standing in Idaho

Date: Sep 5, 2026

Unscheduled Lease-Option Rights Remain Bankruptcy Estate Property, Defeating Debtor Standing in Idaho Case: Conger v. Clark (Idaho Sup. Ct. Sept. 4, 2026) | Court: Supreme Court of Idaho 1....

Idaho Supreme Court Requires Accurate, Clear, and Concise “Yes/No Effect” Ballot Statements Under I.C. § 34-1810(1)(b) and Confirms Extraordinary-Writ Review

Date: Sep 5, 2026

Idaho Supreme Court Requires Accurate, Clear, and Concise “Yes/No Effect” Ballot Statements Under I.C. § 34-1810(1)(b) and Confirms Extraordinary-Writ Review 1. Introduction Case: Idahoans United v....

Sedillo v. State: Idaho Constitutional Double Jeopardy Applies the Pleading Theory and Requires Merger of Theft into Robbery When the Same Taking Is Charged

Date: Sep 5, 2026

Sedillo v. State: Idaho Constitutional Double Jeopardy Applies the Pleading Theory and Requires Merger of Theft into Robbery When the Same Taking Is Charged I. Introduction In Sedillo v. State (Idaho...

Idaho Code § 7-711(2) Business Damages: “Owned” Means Fee Title Ownership (Beneficial Ownership Insufficient)

Date: Sep 4, 2026

Idaho Code § 7-711(2) Business Damages: “Owned” Means Fee Title Ownership (Beneficial Ownership Insufficient) Case: IDAHO TRANSPORTATION BOARD v. TRIPLE CROWN DEVELOPMENT, LLC (Idaho Supreme Court,...

Rule 35(a) Authorizes Correction of Ambiguous Sentencing Credit, but Any Substantive Clarification Requires Defendant’s Presence Under Rule 43

Date: Sep 4, 2026

Rule 35(a) Authorizes Correction of Ambiguous Sentencing Credit, but Any Substantive Clarification Requires Defendant’s Presence Under Rule 43 I. Introduction In State v. Mooney (Idaho Supreme Court,...

Quasi-Judicial Immunity Is Personal-Only; Rule 32 “Other Copying” Fees Must Conform to I.C. § 74-102(10)

Date: Sep 2, 2026

Quasi-Judicial Immunity Is Personal-Only; Rule 32 “Other Copying” Fees Must Conform to I.C. § 74-102(10) Introduction In BRYAN D. SMITH v. CHRIS POULTER IN HIS CAPACITY AS BONNEVILLE COUNTY CLERK,...

Reinstatement Recommendations Must Contain Actual Findings and Reasoned Analysis Under I.B.C.R. 518(b)(4)(C): In the Matter of Webb

Date: Aug 29, 2026

Reinstatement Recommendations Must Contain Actual Findings and Reasoned Analysis Under I.B.C.R. 518(b)(4)(C): In the Matter of Webb 1. Introduction In In the Matter of Brian L. Webb (Idaho Sup. Ct....

Service of Notice of Appeal Is Nonjurisdictional; Late Expert Declarations Cannot Be Wholly Excluded When Substantially Justified/Harmless and Supporting Properly Disclosed Malpractice Opinions

Date: Jul 31, 2026

Service of Notice of Appeal Is Nonjurisdictional; Late Expert Declarations Cannot Be Wholly Excluded When Substantially Justified/Harmless and Supporting Properly Disclosed Malpractice Opinions...

Statutory “Domestic Violence” (I.C. § 39-6303) Controls Custody Presumptions; Limited, Time-Bound School-Selection Delegation Is Compatible with Joint Legal Custody

Date: Jul 16, 2026

Statutory “Domestic Violence” (I.C. § 39-6303) Controls Custody Presumptions; Limited, Time-Bound School-Selection Delegation Is Compatible with Joint Legal Custody 1. Introduction Devai v. Burk...

Missing “Master Map” Does Not Defeat an Express Utility Easement; Installation Fixes a Floating Easement’s Location, and Easement Metes-and-Bounds Need Not Appear in a Trespass/Nuisance Defense Judgment

Date: Jul 11, 2026

Missing “Master Map” Does Not Defeat an Express Utility Easement; Installation Fixes a Floating Easement’s Location, and Easement Metes-and-Bounds Need Not Appear in a Trespass/Nuisance Defense...

Needham v. Needham: Divorce Courts Cannot Compel Corporate-Fiduciary Acts; Post-Dissolution Community Assets Must Be Valued at Dissolution

Date: Jul 9, 2026

Needham v. Needham: Divorce Courts Cannot Compel Corporate-Fiduciary Acts; Post-Dissolution Community Assets Must Be Valued at Dissolution I. Introduction Case: Needham v. Needham (Idaho Supreme...

Minor Land Divisions Are LLUPA-Reviewable “Other Similar Applications” When Used as a De Facto Subdivision

Date: Jul 9, 2026

Minor Land Divisions Are LLUPA-Reviewable “Other Similar Applications” When Used as a De Facto Subdivision Case: Budig v. Bonner County (Idaho Supreme Court, July 8, 2026) | Core Holding: Two...

Guardianship “Backdating” Does Not Control Idaho Quiet Title: Situs-State Jurisdiction Prevails Over Later Foreign Incapacity Findings

Date: Jul 9, 2026

Guardianship “Backdating” Does Not Control Idaho Quiet Title: Situs-State Jurisdiction Prevails Over Later Foreign Incapacity Findings I. Introduction Shaw v. Shaw (Idaho Supreme Court, July 8, 2026)...

Trust Beneficiaries Lack Standing to Partition Undistributed Trust Real Property; No-Contest Clause Enforced Against Objections to Trustee Distribution Absent Probable Cause

Date: Jul 1, 2026

Trust Beneficiaries Lack Standing to Partition Undistributed Trust Real Property; No-Contest Clause Enforced Against Objections to Trustee Distribution Absent Probable Cause I. Introduction In...