Idaho Case Commentaries

Post-Judgment Fee Orders: Untimely Reconsideration Does Not Toll the Appeal Deadline, and a Later “Fee Judgment” Is Not a New Final Judgment

Date: Jan 24, 2026

Post-Judgment Fee Orders: Untimely Reconsideration Does Not Toll the Appeal Deadline, and a Later “Fee Judgment” Is Not a New Final Judgment 1. Introduction In Medical Recovery Services, LLC v. Wood...

York v. Kemper Northwest, Inc.: Rule 54 Waiver—A Party Cannot Recover Attorney Fees Under an Uncited Statutory Basis Added Only by a Late Supplemental Memorandum

Date: Jan 24, 2026

York v. Kemper Northwest, Inc.: Rule 54 Waiver—A Party Cannot Recover Attorney Fees Under an Uncited Statutory Basis Added Only by a Late Supplemental Memorandum 1. Introduction In York v. Kemper...

Idaho Reaffirms the Common-Law Ban on Unreasonable Restraints on Alienation and Adopts the Restatement (Third) Utility-vs-Harm Test

Date: Jan 23, 2026

Idaho Reaffirms the Common-Law Ban on Unreasonable Restraints on Alienation and Adopts the Restatement (Third) Utility-vs-Harm Test Case: Smallwood v. Little (Idaho Supreme Court, Jan. 22, 2026) |...

Rule 54 Attorney-Fee Waiver: A Timely Memorandum Must Cite and Analyze the Fee Statute; a Complaint Reference or Later Supplement Cannot Cure

Date: Jan 21, 2026

Rule 54 Attorney-Fee Waiver: A Timely Memorandum Must Cite and Analyze the Fee Statute; a Complaint Reference or Later Supplement Cannot Cure I. Introduction In York v. Kemper Northwest, Inc. (Idaho...

Crookham v. County of Canyon: LLUPA “Affected Person” Standing Displaces Idaho’s Self-Imposed Lujan-Style Standing Test

Date: Jan 17, 2026

Crookham v. County of Canyon: LLUPA “Affected Person” Standing Displaces Idaho’s Self-Imposed Lujan-Style Standing Test 1. Introduction In Crookham v. County of Canyon (Idaho Jan. 16, 2026), the...

Vacatur of Custody Orders Eliminates Any Controlling Custody Schedule; Remand Requires New Temporary Orders and a Complete Best-Interests Analysis (Raber v. Raber)

Date: Jan 16, 2026

Vacatur of Custody Orders Eliminates Any Controlling Custody Schedule; Remand Requires New Temporary Orders and a Complete Best-Interests Analysis Case: Raber v. Raber (Supreme Court of Idaho, Jan....

Adverse Medical-Debt Credit Reporting Is Commercial Speech; Idaho Patient Act Preconditions to “Extraordinary Collection Actions” Survive First and Fourteenth Amendment Facial Challenges

Date: Jan 11, 2026

Adverse Medical-Debt Credit Reporting Is Commercial Speech; Idaho Patient Act Preconditions to “Extraordinary Collection Actions” Survive First and Fourteenth Amendment Facial Challenges Introduction...

State v. Frandsen: Text Exhibits Must Be Redacted for Unnoticed 404(b) “Other Acts” Even When Admitted for a Non-Hearsay Purpose; Prior Acquaintance Alone Does Not Establish Juror Bias

Date: Jan 9, 2026

State v. Frandsen: Text Exhibits Must Be Redacted for Unnoticed 404(b) “Other Acts” Even When Admitted for a Non-Hearsay Purpose; Prior Acquaintance Alone Does Not Establish Juror Bias Court: Supreme...

Idaho Code § 55-3211 Makes HOA Short-Term Rental Bans Property-Based Unless the Affected Owner Expressly Consents in Writing

Date: Jan 8, 2026

Idaho Code § 55-3211 Makes HOA Short-Term Rental Bans Property-Based Unless the Affected Owner Expressly Consents in Writing Introduction North Henry's Lake Homeowners Association, Inc. v. Bryan...

Stasiewicz v. South Henry’s Lake Outlet HOA / Henry’s Lake Village: Limits on Sua Sponte Res Judicata and “Mootness” Dismissals Under I.R.C.P. 12(b)(1)

Date: Jan 8, 2026

New Idaho Rule: Courts May Not Raise Res Judicata Sua Sponte, and Rule 12(b)(1) “Mootness” Dismissals Cannot Decide Intertwined Merits—Especially Where a Restrictive Easement Leaves Effectual Relief...

Compensable Consequences in Idaho: Recurrent Injury Remains Compensable Absent Proof of Rash or Deliberate Disregard

Date: Jan 8, 2026

Compensable Consequences in Idaho: Recurrent Injury Remains Compensable Absent Proof of Rash or Deliberate Disregard Introduction Miklos v. L&W Supply Corporation (Idaho Supreme Court, Jan. 6, 2026)...

TEDRA Grants District Courts Broad Subject-Matter Jurisdiction to Decide Declaratory Rights in Estate Assets Despite Ongoing Probate

Date: Jan 7, 2026

TEDRA Grants District Courts Broad Subject-Matter Jurisdiction to Decide Declaratory Rights in Estate Assets Despite Ongoing Probate Introduction Nelson v. Wylie (Idaho Supreme Court, January 6,...

Jurisdiction Requires a Timely Petition Identifying the Operative Agency Order (Superseding Methodology Orders Must Be Appealed)

Date: Jan 3, 2026

Jurisdiction Requires a Timely Petition Identifying the Operative Agency Order (Superseding Methodology Orders Must Be Appealed) Case: City of Idaho Falls v. IDWR Court: Supreme Court of Idaho Date:...

Stipulations Are Limited: “Independent Contractor” for Wage Claims Does Not Establish ICRA “Contractor” Status or Illegality Without Proof

Date: Jan 2, 2026

Stipulations Are Limited: “Independent Contractor” for Wage Claims Does Not Establish ICRA “Contractor” Status or Illegality Without Proof Case: Ward v. Bishop Construction Court: Supreme Court of...

Proulx v. Saveway Market, Inc. — Contextual Construction of Commission Findings and Deference to Medical-Weighing in Cervical-Spine Causation Claims

Date: Jan 2, 2026

Contextual Construction of Commission Findings and Deference to Medical-Weighing in Cervical-Spine Causation Claims Case: Proulx v. Saveway Market, Inc. Court: Supreme Court of Idaho Date: December...

Monson v. Monson: Independent TEDRA Actions and Party Joinder in Idaho Estate Disputes

Date: Dec 26, 2025

Monson v. Monson: Independent TEDRA Actions and Party Joinder in Idaho Estate Disputes I. Introduction Monson v. Monson, No. 51838-2024 (Idaho Dec. 23, 2025), is a significant Idaho Supreme Court...

Condominium Descriptions and Futile Tender: The Idaho Supreme Court Refines Statute of Frauds and Specific Performance in McLaughlin v. Moore

Date: Dec 24, 2025

Condominium Descriptions and Futile Tender: The Idaho Supreme Court Refines Statute of Frauds and Specific Performance in McLaughlin v. Moore I. Introduction In McLaughlin v. Moore, Docket No....

State v. Frandsen: Idaho Supreme Court Refines Juror Impartiality, Victim Text Evidence, and Forensic Interviewer Testimony

Date: Dec 21, 2025

State v. Frandsen: Idaho Supreme Court Refines Juror Impartiality, Victim Text Evidence, and Forensic Interviewer Testimony I. Introduction In State v. Frandsen, Docket No. 50878 (Idaho Dec. 19,...

Carelon Behavioral Health, Inc. v. State: No Declaratory or Mandamus Work‑Around to the Procurement Act’s Bar on Judicial Review

Date: Dec 19, 2025

Carelon Behavioral Health, Inc. v. State of Idaho: No Declaratory or Mandamus Work‑Around to the Procurement Act’s Bar on Judicial Review I. Introduction In Carelon Behavioral Health, Inc. v. State,...

Probation Waivers vs. Co‑Occupant Objection: State v. Horn and the Limits of Georgia v. Randolph in Idaho

Date: Dec 11, 2025

Probation Waivers vs. Co‑Occupant Objection: State v. Horn and the Limits of Georgia v. Randolph in Idaho I. Introduction In State v. Horn, the Idaho Supreme Court confronted two recurring and...