Idaho Case Commentaries

Clarification of “Unprovoked Physical Aggression” Exception to Idaho’s Workers’ Compensation Exclusive Remedy Rule

Date: May 20, 2025

Clarification of “Unprovoked Physical Aggression” Exception to Idaho’s Workers’ Compensation Exclusive Remedy Rule Introduction Arellano v. Sunrise Homes, Inc. (Idaho Supreme Court, May 19, 2025)...

Clarifying Willfulness in Unemployment Benefits Fraud under Idaho Code §72-1366(12)

Date: May 14, 2025

Clarifying Willfulness in Unemployment Benefits Fraud under Idaho Code §72-1366(12) Introduction The Supreme Court of Idaho’s decision in Flynn v. Sun Valley Brewing Company, 50921 (May 13, 2025),...

Requirement of Non-Mailing Assurances for Public Records Lists Under Idaho Law: Sentry Dynamics, Inc. v. Ada County

Date: May 3, 2025

Requirement of Non-Mailing Assurances for Public Records Lists Under Idaho Law: Sentry Dynamics, Inc. v. Ada County Introduction The Idaho Supreme Court decision in Sentry Dynamics, Inc. v. Ada...

Parental Dishonesty and Court-Order Noncompliance as Material Change in Custody Modifications: Stephens v. Buell

Date: May 1, 2025

Parental Dishonesty and Court-Order Noncompliance as Material Change in Custody Modifications: Stephens v. Buell Introduction Stephens v. Buell, decided April 30, 2025 by the Idaho Supreme Court,...

Idaho Precedent on Utility Authority to Replace Meters under Tariff Provisions

Date: Apr 25, 2025

Idaho Precedent on Utility Authority to Replace Meters under Tariff Provisions Introduction In Edwards v. Idaho Public Utilities Commission, 2025-ID-SC-51238, the Idaho Supreme Court addressed...

Mandatory Articulation of Rationale in Relinquishment of Jurisdiction Orders

Date: Apr 18, 2025

Mandatory Articulation of Rationale in Relinquishment of Jurisdiction Orders Introduction In State v. Ruiz, the Idaho Supreme Court considered whether a district court must provide articulated...

Sanctions for Scheduling-Order Violations: Discretionary Attorney Fees under I.R.C.P. 16(e) and Idaho Code § 12-121

Date: Apr 16, 2025

Sanctions for Scheduling-Order Violations: Discretionary Attorney Fees under I.R.C.P. 16(e) and Idaho Code § 12-121 Introduction This commentary examines the Supreme Court of Idaho’s decision in...

Subject-Matter Jurisdiction Fixed at Filing and Express Fee-Shifting Required: Commentary on Sunnyside Park Utilities, Inc. v. Sorrells (Idaho 2025)

Date: Apr 5, 2025

Subject-Matter Jurisdiction Fixed at Filing and Express Fee-Shifting Required: Sunnyside Park Utilities, Inc. v. Sorrells (Idaho 2025) Introduction In Sunnyside Park Utilities, Inc. v. Sorrells, the...

Misrepresentation by Omission Needs No Reliance; Client Directives and Confidentiality Do Not Excuse Disobeying Court Orders — Idaho Supreme Court Disbars Attorney in ISB v. Oleson (2025)

Date: Apr 3, 2025

Misrepresentation by Omission Needs No Reliance; Client Directives and Confidentiality Do Not Excuse Disobeying Court Orders — Idaho Supreme Court Disbars Attorney in ISB v. Oleson (2025)...

Criminal Trespass on Public Property and Limits of Discretion in State v. Bundy

Date: Apr 2, 2025

Criminal Trespass on Public Property and Limits of Discretion in State v. Bundy Introduction State v. Bundy (Idaho Supreme Court, April 1, 2025) clarified the reach of Idaho’s misdemeanor criminal...

Limary v. McLean: Objections to Judicial Questioning in Family Bench Trials May Be Raised on Appeal, and Overreaching Requires Vacatur and Reassignment

Date: Mar 29, 2025

Limary v. McLean: Objections to Judicial Questioning in Family Bench Trials May Be Raised on Appeal, and Overreaching Requires Vacatur and Reassignment Introduction This commentary analyzes the Idaho...

Hill v. Emergency Medicine of Idaho: Idaho rejects children’s loss-of-parental-consortium (nonfatal injury) and deems generic “hindsight bias” expert testimony irrelevant and prejudicial

Date: Mar 28, 2025

Hill v. Emergency Medicine of Idaho: Idaho rejects children’s loss-of-parental-consortium (nonfatal injury) and deems generic “hindsight bias” expert testimony irrelevant and prejudicial Court: Idaho...

Fundamental Error Overrides Preclusion in Idaho Termination/Adoption Cases; Rule 60(b)(4) Must Be Brought Within a “Reasonable Time”; Six‑Month Adoption Repose Unconstitutional as Applied Where an Unwed “Biology‑Plus” Father Received No Notice

Date: Mar 28, 2025

Fundamental Error Overrides Preclusion in Idaho Termination/Adoption Cases; Rule 60(b)(4) Must Be Brought Within a “Reasonable Time”; Six‑Month Adoption Repose Unconstitutional as Applied Where an...

Cole v. IPUC: Constitutional and Other Appellate Claims Are Waived in IPUC Appeals Absent Cogent Authority; Commission May Appear as Respondent Under I.C. § 61-630

Date: Mar 15, 2025

Cole v. IPUC: Constitutional and Other Appellate Claims Are Waived in IPUC Appeals Absent Cogent Authority; Commission May Appear as Respondent Under I.C. § 61-630 1. Introduction In Cole v. Idaho...

Reassessing Custody Schedules and Relocation: Establishing the Paramountcy of Child’s Best Interests

Date: Mar 13, 2025

Reassessing Custody Schedules and Relocation: Establishing the Paramountcy of Child’s Best Interests Introduction The case of Elizabeth Corey Raber versus Michael Robert Raber presented before the...

Raber v. Raber: Courts Must Make an Affirmative Best-Interests Finding Before Ordering Long-Distance Rotating Custody

Date: Mar 13, 2025

Raber v. Raber: Courts Must Make an Affirmative Best-Interests Finding Before Ordering Long-Distance Rotating Custody 1. Introduction In Raber v. Raber (Idaho Supreme Court, March 12, 2025), the...

Refining the Definition of Willfulness in Aggravated Battery Against a Minor: The Idaho Supreme Court’s Decision in State v. Radue

Date: Mar 9, 2025

Refining the Definition of Willfulness in Aggravated Battery Against a Minor: The Idaho Supreme Court’s Decision in State v. Radue Introduction In this landmark decision, the Supreme Court of Idaho...

Establishing the Foundation: New Standards on Expert Testimony and Timely Disclosure in Legal Malpractice Cases

Date: Mar 6, 2025

Establishing the Foundation: New Standards on Expert Testimony and Timely Disclosure in Legal Malpractice Cases Introduction In a significant development from the Supreme Court of Idaho dated March...

Retention of Identification as a Seizure: Imposing the Reasonable Suspicion Requirement Under the Fourth Amendment

Date: Mar 5, 2025

Retention of Identification as a Seizure: Imposing the Reasonable Suspicion Requirement Under the Fourth Amendment Introduction This commentary examines the Supreme Court of Idaho’s decision in STATE...

Ensuring Accuracy in Presentence Investigations: The Redline Correction Mandate in State v. Alvarez

Date: Mar 2, 2025

Ensuring Accuracy in Presentence Investigations: The Redline Correction Mandate in State v. Alvarez Introduction The case of State of Idaho v. Juan C. Alvarez presents a critical examination of the...