Idaho Case Commentaries

Heath v. Olaveson (Idaho 2026) Commentary

Date: Jul 1, 2026

Board Certification Does Not Eliminate Idaho’s Local-Inquiry Foundation: Out-of-Area Experts Must Show a Local Consultant’s Actual Knowledge of the Defined Community Standard (and Those Admissibility...

Bedell v. Parsons: Deed-Listed Cotenant May Have 0% Ownership; Equal-Shares Presumption Cannot Be Resolved by Credibility-Weighing on Summary Judgment

Date: Jul 1, 2026

Bedell v. Parsons: Deed-Listed Cotenant May Have 0% Ownership; Equal-Shares Presumption Cannot Be Resolved by Credibility-Weighing on Summary Judgment Court: Supreme Court of Idaho | Date: June 30,...

Hyde v. Oxarango (Idaho 2026): Strict Standing and Particularized Demand-Futility Pleading for Limited Partnership Derivative Claims, and No Direct-Action Expulsion Without a Distinct Partner Injury

Date: Jun 11, 2026

Hyde v. Oxarango (Idaho 2026): Strict Standing and Particularized Demand-Futility Pleading for Limited Partnership Derivative Claims, and No Direct-Action Expulsion Without a Distinct Partner Injury...

Hartman v. Pocatello Hospital: Mandatory Disclosure of Non‑Testifying Local Standard‑of‑Care Consultants and “General Risk” Foreseeability for Proximate Cause

Date: Jun 2, 2026

Hartman v. Pocatello Hospital: Mandatory Disclosure of Non‑Testifying Local Standard‑of‑Care Consultants and “General Risk” Foreseeability for Proximate Cause 1. Introduction In Hartman v. Pocatello...

State v. Vazquez (Idaho 2026): Subsequent Similar-Act Evidence May Rebut Entrapment Predisposition—No Per Se Temporal Bar

Date: May 30, 2026

State v. Vazquez (Idaho 2026): Subsequent Similar-Act Evidence May Rebut Entrapment Predisposition—No Per Se Temporal Bar I. Introduction Case: State v. Vazquez Court: Supreme Court of Idaho Date:...

Idaho Adopts the “Reasonable Expectations” Test for LLC Member Oppression and Rejects Dissolution on Unpleaded “Illegal Conduct” Grounds

Date: May 28, 2026

Idaho Adopts the “Reasonable Expectations” Test for LLC Member Oppression and Rejects Dissolution on Unpleaded “Illegal Conduct” Grounds Introduction BEARDSLEE v. RATLIFF FAMILY LLC, NO. 1 (Idaho...

Private Termination Due Process: Case-by-Case Appointed Counsel (Including on Appeal) and County-Funded Appellate Records/Transcripts

Date: May 13, 2026

Private Termination Due Process: Case-by-Case Appointed Counsel (Including on Appeal) and County-Funded Appellate Records/Transcripts I. Introduction This consolidated Opinion on Order to Show Cause...

State v. Gutierrez: No Entitlement to Continue Sentencing to Obtain an Unsheduled Psychosexual Evaluation; Fixed Life Sentence Affirmed

Date: May 13, 2026

State v. Gutierrez: No Entitlement to Continue Sentencing to Obtain an Unsheduled Psychosexual Evaluation; Fixed Life Sentence Affirmed Introduction In State v. Gutierrez (Idaho Supreme Court, May...

Bickerstaff v. Bickerstaff: Inferring a Nonmoving Parent’s Relocation and Rejecting “Scoreboard” Best-Interests Analysis in Custody Relocation Orders

Date: May 9, 2026

Bickerstaff v. Bickerstaff: Inferring a Nonmoving Parent’s Relocation and Rejecting “Scoreboard” Best-Interests Analysis in Custody Relocation Orders Introduction In Bickerstaff v. Bickerstaff (Idaho...

Wild Timberland Logging Roads Carry a Presumption of Permissive Use; Episodic Construction Access Does Not Ripen into Prescription Without Notice of Hostility

Date: May 8, 2026

Wild Timberland Logging Roads Carry a Presumption of Permissive Use; Episodic Construction Access Does Not Ripen into Prescription Without Notice of Hostility I. Introduction Spirit Lake Cabins, LLC...

State v. Manuelito: Overdose-Immunity Under I.C. § 37-2739C(2) Requires an Actual Drug-Related Medical Emergency and Need for Medical Assistance (Not a Bystander’s Good-Faith Belief)

Date: May 8, 2026

State v. Manuelito: Overdose-Immunity Under I.C. § 37-2739C(2) Requires an Actual Drug-Related Medical Emergency and Need for Medical Assistance (Not a Bystander’s Good-Faith Belief) Court: Supreme...

Estate of Kalinski v. Murphy Law Office, PLLC: Unjust Enrichment and ICPA Claims Cannot Repackage Legal Malpractice Absent Independent Consumer Deception

Date: May 6, 2026

Estate of Kalinski v. Murphy Law Office, PLLC: Unjust Enrichment and ICPA Claims Cannot Repackage Legal Malpractice Absent Independent Consumer Deception Court: Supreme Court of Idaho Date: May 5,...

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...