Idaho Case Commentaries

County Plat Changes Cannot Strip CC&Rs: Idaho Supreme Court Clarifies Applicability, Road Construction, and Injunction Specificity in Jordan v. Powers

Date: Aug 31, 2025

County Plat Amendments Cannot Remove Land from CC&Rs; Roads Are Not Categorically Barred but Require Design Committee Approval Case: Jordan v. Powers, Supreme Court of Idaho (Aug. 28, 2025)...

Riverside Reaffirmed: Idaho Supreme Court Confirms Bench-Trier May Resolve Conflicting Inferences at Summary Judgment; No “Rent Substitution” Credit for Affiliate-Funded Construction Absent Proof

Date: Aug 31, 2025

Riverside Reaffirmed: Bench-Trier Summary Judgment and the Limits of “Rent Substitution” under a Triple‑Net Lease Introduction In Erie Properties, LLC v. Global Growth Holdings, Inc., the Idaho...

State v. McGuire: Idaho Supreme Court Clarifies Dual “Duty” Standards—Broad for Felony Battery on Officers, Narrow (Lawfulness-Dependent) for Resisting; Burden-Shifting Misconduct Cured by Prompt Judicial Intervention

Date: Aug 31, 2025

State v. McGuire: Idaho Supreme Court Clarifies Dual “Duty” Standards—Broad for Felony Battery on Officers, Narrow (Lawfulness-Dependent) for Resisting; Burden-Shifting Misconduct Cured by Prompt...

“Tax Debt = Debt”: The Idaho Supreme Court Requires Tax-Relief Firms to Obtain Collection-Agency Licences — Comment on Wall & Associates, Inc. v. Idaho Department of Finance (2025)

Date: Aug 25, 2025

“Tax Debt = Debt”: The Idaho Supreme Court Requires Tax-Relief Firms to Obtain Collection-Agency Licences Commentary on Wall & Associates, Inc. v. Idaho Department of Finance, 174 Idaho ___ (2025) 1....

“Mission-Based Use” as a Religious Purpose: Idaho Supreme Court Broadens the Scope of the § 63-602B Property-Tax Exemption

Date: Aug 25, 2025

“Mission-Based Use” as a Religious Purpose: Idaho Supreme Court Broadens the Scope of the § 63-602B Property-Tax Exemption Introduction First Presbyterian Church of Boise, Idaho, Inc. (FPC) sought a...

Westman v. ISIF: The “Sole-Cause” Clarification of Idaho Code § 72-332 Liability

Date: Aug 25, 2025

Westman v. Industrial Special Indemnity Fund: The Supreme Court of Idaho Clarifies the “Sole-Cause” Exception to Fund Liability under Idaho Code § 72-332 Introduction In Westman v. Industrial Special...

State v. Frias: Clarifying Proximate Causation and the “Criminal-Negligence” Threshold under Idaho Code § 18-7004

Date: Aug 25, 2025

State v. Frias: Clarifying Proximate Causation and the “Criminal-Negligence” Threshold under Idaho Code § 18-7004 Introduction In State v. Frias, Docket No. 50950-2023 (Idaho Aug. 20, 2025), the...

DeKlotz v. NS Support, LLC – Medical Liens Under I.C. § 45-704B Are “Extraordinary Collection Actions” Requiring Full Compliance with the Idaho Patient Act

Date: Aug 25, 2025

Medical Liens Under I.C. § 45-704B Are “Extraordinary Collection Actions”: Commentary on DeKlotz v. NS Support, LLC, 174 Idaho ___ (2025) 1. Introduction In DeKlotz v. NS Support, LLC the Idaho...

Idaho Supreme Court Abandons Statute-of-Limitations Bar for Easements by Necessity and Expands Discretion to Revisit “Law-of-the-Case”: Easterling v. Clark (“Easterling II”)

Date: Aug 25, 2025

Idaho Supreme Court Abandons Statute-of-Limitations Bar for Easements by Necessity and Expands Discretion to Revisit “Law-of-the-Case” Doctrine: Detailed Commentary on Easterling v. Clark (2025) 1....

“No Shortcuts to Summary Judgment” – Rupp v. City of Pocatello and the Idaho Supreme Court’s Dual Message on Discovery Diligence and Rule 56 Analysis

Date: Aug 25, 2025

“No Shortcuts to Summary Judgment” – Rupp v. City of Pocatello and the Idaho Supreme Court’s Dual Message on Discovery Diligence and Rule 56 Analysis Introduction Rupp v. City of Pocatello, 174 Idaho...

Smith v. State: Defining the Limits of “Counsel Abandonment” and Pro-Se Filings in Idaho Post-Conviction Practice

Date: Aug 25, 2025

Smith v. State: Defining the Limits of “Counsel Abandonment” and Pro-Se Filings in Idaho Post-Conviction Practice 1. Introduction The Idaho Supreme Court’s 2025 decision in Smith v. State, Docket No....

Hansen v. Boise School District #1: Personal Property Injury as a Prerequisite to Takings Standing

Date: Aug 19, 2025

Hansen v. Boise School District #1 (Idaho 2025): Personal Property Injury as a Prerequisite to Takings Standing 1. Introduction In Hansen v. Boise School District #1, the Supreme Court of Idaho...

No Stand-Alone “Community Caretaking” Exception: State v. Adams and the Constitutional Limits on Searching Civilly-Committed Patients

Date: Aug 13, 2025

No Stand-Alone “Community Caretaking” Exception: State v. Adams and the Constitutional Limits on Searching Civilly-Committed Patients Introduction State v. Adams, 50841 (Idaho Aug. 11 2025), squarely...

Survival of Attorney-Fee Clauses Beyond Deed Merger & Limits on Fee Recovery: A Commentary on McOmber v. Thompson (Idaho 2025)

Date: Jul 23, 2025

Survival of Attorney-Fee Clauses Beyond Deed Merger & Limits on Fee Recovery: A Comprehensive Commentary on McOmber v. Thompson (Idaho 2025) 1. Introduction In McOmber v. Thompson, the Idaho Supreme...

State v. Ewing: Idaho Supreme Court Validates Annotated Compilation Videos as Rule 1006 Summaries and Re-affirms COVID-19 Speedy-Trial Tolling

Date: Jul 23, 2025

State v. Ewing: Idaho Supreme Court Validates Annotated Compilation Videos as Rule 1006 Summaries and Re-affirms COVID-19 Speedy-Trial Tolling Introduction In State v. Ewing, Docket No. 50452 (Idaho...

Ewing Clarifies the Threshold for Franks Hearings and Harmless Crawford Error in Idaho

Date: Jul 23, 2025

Ewing Clarifies the Threshold for Franks Hearings and Harmless Crawford Error in Idaho Introduction State v. Ewing, Supreme Court of Idaho (2025), arose from the felony-murder conviction of...

Bell v. State: Idaho Supreme Court Clarifies Preservation Requirements and Specificity Standards for Incorporating Claims in Amended Post-Conviction Petitions

Date: Jul 15, 2025

Bell v. State: Idaho Supreme Court Clarifies Preservation Requirements and Specificity Standards for Incorporating Claims in Amended Post-Conviction Petitions 1. Introduction Bell v. State, 52104...

“Jurisdiction vs. Remedy”: Idaho Supreme Court Affirms Its Authority to Hear Appeals from Void Intermediate Decisions – Comment on State v. Moore (2025)

Date: Jul 15, 2025

“Jurisdiction vs. Remedy”: Idaho Supreme Court Affirms Its Authority to Hear Appeals from Void Intermediate Decisions – Comment on State v. Moore (2025) Introduction State v. Moore, decided by the...

“Solicitation Requires an Overt Act” – A Comprehensive Commentary on Insure Idaho v. Horn (Idaho 2025)

Date: Jul 13, 2025

“Solicitation Requires an Overt Act” Idaho Supreme Court Clarifies Enforcement of Non-Solicitation Covenants, Preliminary Injunction Standards, and Contempt Procedure (Insure Idaho, LLC v. Horn, 173...

Expanding the Idaho Attorney General’s Investigatory Reach: The “Reason-to-Believe” Standard and Charitable-Asset Oversight after Children’s Home Society v. Labrador (Idaho 2025)

Date: Jul 13, 2025

Expanding the Idaho Attorney General’s Investigatory Reach: The “Reason-to-Believe” Standard and Charitable-Asset Oversight after Children’s Home Society v. Labrador (Idaho 2025) Introduction The...