Idaho Case Commentaries

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,...

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...