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21 Idaho opinions name it 2 courts 1990–2025 3 in the last five years
The cases below were cited by Idaho courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Manning v. Twin Falls Clinic & Hospital, Inc.green2 sentences2005We see then that this Court, when it rejected the lost chance doctrine, did so based on its confidence that the use of the substantial factor test in such circumstances “strikes a fair balance between the claimant and the defense.” Id. 1995In Manning v. Twin Falls Clinic & Hospital, Inc., 122 Idaho 47 , 830 P.2d 1185 (1992), the Supreme Court reiterated that a substantial factor instruction alone was proper in multiple cause cases. | 2 | 4 |
Le'Gall v. Lewis Countygreen2 sentences2023“The but for instruction and the substantial factor instruction are mutually exclusive.” Id. at 187 , 923 P.2d at 432 . 2023“The but for instruction and the substantial factor instruction are mutually exclusive.” Id. at 187 , 923 P.2d at 432 . | 2 | 3 |
Fussell v. St. Clairgreen2 sentences1996Clair, 120 Idaho 591, 595 , 818 P.2d 295, 299 (1991). *187 The trial court should give the substantial factor instruction when more than one cause could have proximately caused the injury. 1996Clair, 120 Idaho 591, 595 , 818 P.2d 295, 299 (1991). *187 The trial court should give the substantial factor instruction when more than one cause could have proximately caused the injury. | 2 | 3 |
Cramer v. Slatergreen2 sentences2014It is well-settled that the “question of proximate cause is one of fact and almost always for the jury.” Cramer v. Slater, 146 Idaho 868, 875 , 204 P.3d 508, 515 (2009). 2014It is well-settled that the “question of proximate cause is one of fact and almost always for the jury.” Cramer v. Slater, 146 Idaho 868, 875 , 204 P.3d 508, 515 (2009). | 2 | 2 |
Ake v. Oklahomagreen2 sentences2015Id. at 72, 74, 86-87 , 105 S.Ct. at 1090-91, 1091-92, 1097-98 , 84 L.Ed.2d at 59, 60-61, 68-69 . 2015Id. at 72, 74, 86-87 , 105 S.Ct. at 1090-91, 1091-92, 1097-98 , 84 L.Ed.2d at 59, 60-61, 68-69 . | 1 | 2 |
Evans v. Teton Countygreen2 sentences2023See Butters, 131 Idaho at 501 , 960 P.2d at 184 (explaining that while location alone cannot confer standing, if the location exposes the plaintiff to a peculiarized harm, that is a factor in the analysis); Evans v. Teton Cnty., 139 Idaho 71, 75 , 73 P.3d 84, 88 (2003) (“this Court will not look to a predetermined distance in deciding whether a property owner has, or does not have, standing”). 2023See Butters, 131 Idaho at 501 , 960 P.2d at 184 (explaining that while location alone cannot confer standing, if the location exposes the plaintiff to a peculiarized harm, that is a factor in the analysis); Evans v. Teton Cnty., 139 Idaho 71, 75 , 73 P.3d 84, 88 (2003) (“this Court will not look to a predetermined distance in deciding whether a property owner has, or does not have, standing”). | 1 | 1 |
Butters v. Hausergreen2 sentences2023See Butters, 131 Idaho at 501 , 960 P.2d at 184 (explaining that while location alone cannot confer standing, if the location exposes the plaintiff to a peculiarized harm, that is a factor in the analysis); Evans v. Teton Cnty., 139 Idaho 71, 75 , 73 P.3d 84, 88 (2003) (“this Court will not look to a predetermined distance in deciding whether a property owner has, or does not have, standing”). 2023See Butters, 131 Idaho at 501 , 960 P.2d at 184 (explaining that while location alone cannot confer standing, if the location exposes the plaintiff to a peculiarized harm, that is a factor in the analysis); Evans v. Teton Cnty., 139 Idaho 71, 75 , 73 P.3d 84, 88 (2003) (“this Court will not look to a predetermined distance in deciding whether a property owner has, or does not have, standing”). | 1 | 1 |
Newberry v. Martensgreen2 sentences2023“This Court has ‘specifically reject[ed]’ the inclusion of the ‘but for’ test where more than one cause could have brought about the injury.” Newberry v. Martens, 142 Idaho 284, 288 , 127 P.3d 187, 191 (2005) (quoting Fussell v. St. 2023This Court affirmed the district court’s decision to give the substantial factor instruction and held the doctor “cannot simultaneously point to a second cause, independent of his negligence, and at the same time maintain that this is a single cause case.” Id. | 1 | 1 |
Easterling v. Kendall, M.D.green2 sentences2020Cf. Easterling, 159 Idaho at 915 , 367 P.3d at 1226 (“Proximate cause in medical malpractice cases involving more than one possible cause of injury will be established if it is shown that the defendant’s conduct was a substantial factor in bringing about the injury suffered by the plaintiff.” ). 8 Redicare responds by arguing that the district court applied a “but for” 1 proximate cause standard to its affirmative defense, while applying the substantial factor standard to the Ackerschotts. 2020Cf. Easterling, 159 Idaho at 915 , 367 P.3d at 1226 (“Proximate cause in medical malpractice cases involving more than one possible cause of injury will be established if it is shown that the defendant’s conduct was a substantial factor in bringing about the injury suffered by the plaintiff.” ). 8 Redicare responds by arguing that the district court applied a “but for” 1 proximate cause standard to its affirmative defense, while applying the substantial factor standard to the Ackerschotts. | 1 | 1 |
State v. Christina Rose Wisdomgreen2 sentences2018State v. Wisdom, 161 Idaho 916, 921 , 393 P.3d 576, 581 (2017). 2018State v. Wisdom, 161 Idaho 916, 921 , 393 P.3d 576, 581 (2017). | 1 | 1 |
Doe v. Sisters of the Holy Crossgreen2 sentences2017Doe v. Sisters of Holy Cross, 126 Idaho 1036, 1040 , 895 P.2d 1229, 1233 (Ct. App. 1995) (citing Manning v. Twin Falls Clinic & Hosp., Inc., 122 Idaho 47, 51 , 830 P.2d 1185, 1189 (1992); Fussell v. St. 2017Doe v. Sisters of Holy Cross, 126 Idaho 1036, 1040 , 895 P.2d 1229, 1233 (Ct. App. 1995) (citing Manning v. Twin Falls Clinic & Hosp., Inc., 122 Idaho 47, 51 , 830 P.2d 1185, 1189 (1992); Fussell v. St. | 1 | 1 |
Hickman v. Fraternal Order of Eagles, Boise 115green2 sentences1995The Court hinted at such, however, in Hickman v. Fraternal Order of Eagles, 114 Idaho 545, 549 , 758 P.2d 704, 708 (1988), and the Court’s decisions have applied the substantial factor analysis only in circumstances where factual cause, not legal cause, was at issue. 1995The Court hinted at such, however, in Hickman v. Fraternal Order of Eagles, 114 Idaho 545, 549 , 758 P.2d 704, 708 (1988), and the Court’s decisions have applied the substantial factor analysis only in circumstances where factual cause, not legal cause, was at issue. | 1 | 1 |
State v. Abbottgreen2 sentences1990The Alaska court in Wilson v. Kotzebue relied on their earlier case of State v. Abbott, 498 P.2d 712 (Alaska 1972), which explained: Normally, in order to satisfy the substantial factor test it must be shown both that the accident would not have happened “but for” the defendant’s negligence and that the negligent act was so important in bringing about the injury that reasonable men would regard it as a cause and attach responsibility to it. 1990The Alaska court in Wilson v. Kotzebue relied on their earlier case of State v. Abbott, 498 P.2d 712 (Alaska 1972), which explained: Normally, in order to satisfy the substantial factor test it must be shown both that the accident would not have happened "but for" the defendant's negligence and that the negligent act was so important in bringing about the injury that reasonable men would regard it as a cause and attach responsibility to it. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Weeks v. Eastern Idaho Health Services
green
2 sentences2014Presumably, the District Court got this from this Court’s decision in Weeks, where the Court stated the following dicta in relation to a differential diagnosis case: 15 As this Court in Weeks, supra, 143 Idaho at 838 , 153 P.3d at 1184 , stated, The Court has not adopted the Daubert standard for admissibility of an expert’s testimony but has used some of Daubert’s standards in assessing whether the basis of an expert’s opinion is scientifically valid. 2014First, Dr. Selznick relied upon facts that other experts rely upon; that is, he reviewed Ms. Nield’s medical records, including her negative test results in August of 2007, and the positive results taken after her admission in November, 2007; he reviewed the 14 In Bloching, this Court disallowed a physician’s testimony that was “possible” and not based upon a “reasonable degree of medical probability.” Id., 129 Idaho at 846 , 934 P.2d at 19 . | 2 | 2014–2014 |
State v. Carlson
green
1 sentence2025Id. | 1 | 2025–2025 |
New York v. Quarles
green
1 sentence2016But “the failure to provide Miranda warnings in and of itself does not render a confession involuntary.” New York v. Quarles, 467 U.S. 649 , 655 n.5 (1984). | 1 | 2016–2016 |
Bloching v. Albertson's, Inc.
green
2 sentences2014First, Dr. Selznick relied upon facts that other experts rely upon; that is, he reviewed Ms. Nield’s medical records, including her negative test results in August of 2007, and the positive results taken after her admission in November, 2007; he reviewed the 14 In Bloching, this Court disallowed a physician’s testimony that was “possible” and not based upon a “reasonable degree of medical probability.” Id., 129 Idaho at 846 , 934 P.2d at 19 . 2014First, Dr. Selznick relied upon facts that other experts rely upon; that is, he reviewed Ms. Nield’s medical records, including her negative test results in August of 2007, and the positive results taken after her admission in November, 2007; he reviewed the 14 In Bloching, this Court disallowed a physician’s testimony that was “possible” and not based upon a “reasonable degree of medical probability.” Id., 129 Idaho at 846 , 934 P.2d at 19 . | 1 | 2014–2014 |
Duarte v. Zachariah
green
2 sentences2009Daniels v. Hadley Mem'l Hosp., 566 F.2d 749 , 760 (D.C.Cir.1977) (finding that a hospital's failure to administer forced oxygen to patient in aniphilactic shock was a substantial factor leading to his death not because it decreased circulation and distribution of sus-phrine injection, but because patient’s lack of respiration lead to cardiac arrest and neurological death); Duarte v. Zachariah, 22 Cal.App.4th 1652 , 28 Cal.Rprt.2d 88, 91 (1994) (holding that injury to bone marrow allegedly caused by an over-prescription of medication is actionable regardless whether plaintiff can show that it c 2009Daniels v. Hadley Mem'l Hosp., 566 F.2d 749 , 760 (D.C.Cir.1977) (finding that a hospital's failure to administer forced oxygen to patient in aniphilactic shock was a substantial factor leading to his death not because it decreased circulation and distribution of sus-phrine injection, but because patient's lack of respiration lead to cardiac arrest and neurological death); Duarte v. Zachariah, 22 Cal.App.4th 1652 , 28 Cal.Rprt.2d 88, 91 (1994) (holding that injury to bone marrow allegedly caused by an over-prescription of medication is actionable regardless whether plaintiff can show that it c | 1 | 2009–2009 |
Daniels v. Hadley Memorial Hospital
green
2 sentences2009Daniels v. Hadley Mem'l Hosp., 566 F.2d 749 , 760 (D.C.Cir.1977) (finding that a hospital's failure to administer forced oxygen to patient in aniphilactic shock was a substantial factor leading to his death not because it decreased circulation and distribution of sus-phrine injection, but because patient’s lack of respiration lead to cardiac arrest and neurological death); Duarte v. Zachariah, 22 Cal.App.4th 1652 , 28 Cal.Rprt.2d 88, 91 (1994) (holding that injury to bone marrow allegedly caused by an over-prescription of medication is actionable regardless whether plaintiff can show that it c 2009Daniels v. Hadley Mem'l Hosp., 566 F.2d 749 , 760 (D.C.Cir.1977) (finding that a hospital's failure to administer forced oxygen to patient in aniphilactic shock was a substantial factor leading to his death not because it decreased circulation and distribution of sus-phrine injection, but because patient's lack of respiration lead to cardiac arrest and neurological death); Duarte v. Zachariah, 22 Cal.App.4th 1652 , 28 Cal.Rprt.2d 88, 91 (1994) (holding that injury to bone marrow allegedly caused by an over-prescription of medication is actionable regardless whether plaintiff can show that it c | 1 | 2009–2009 |
Department of Employment v. Bake Young Realty
green
2 sentences2008Although we have stated that the authority to hire subordinates is an important factor in the analysis of whether a worker is engaged in an independently established trade, occupation, profession, or business, Bake Young Realty, 98 Idaho at 186 , 560 P.2d at 508 , the Commission did not mention this factor in its weighing process. 13. 2008Although we have stated that the authority to hire subordinates is an important factor in the analysis of whether a worker is engaged in an independently established trade, occupation, profession, or business, Bake Young Realty, 98 Idaho at 186 , 560 P.2d at 508 , the Commission did not mention this factor in its weighing process. 13. | 1 | 2008–2008 |
Brown v. Illinois
green
2 sentences2000Brown, 422 U.S. at 605 , 95 S.Ct. at 2262 , 45 L.Ed.2d at 428 . 2000Brown, 422 U.S. at 605 , 95 S.Ct. at 2262 , 45 L.Ed.2d at 428 . | 1 | 2000–2000 |
Fouche v. Chrysler Motors Corp.
green
2 sentences1995See Manning, 122 Idaho 47 , 830 P.2d 1185 ; Fussell, 120 Idaho 591 , 818 P.2d 295 ; Fouche v. Chrysler Motors Corp., 107 Idaho 701 , 692 P.2d 345 (1984). 1995See Manning, 122 Idaho 47 , 830 P.2d 1185 ; Fussell, 120 Idaho 591 , 818 P.2d 295 ; Fouche v. Chrysler Motors Corp., 107 Idaho 701 , 692 P.2d 345 (1984). | 1 | 1995–1995 |
World Wide Lease, Inc. v. Woodworth
green
2 sentences1992Hecla representatives told defendant that they had the authority to agree to the terms of the 1987 agreement because Bunker Hill was in default with Hecla on their underlying agreement on the property- World Wide Lease, Inc. v. Woodworth, 111 Idaho 880 , 728 P.2d 769 (Ct.App.1987), relied upon by the plaintiffs, indicates that condition precedents are not favored by the courts, and that the conduct of the parties may be a factor in the analysis of the existence of the condition precedent. 1992Hecla representatives told defendant that they had the authority to agree to the terms of the 1987 agreement because Bunker Hill was in default with Hecla on their underlying agreement on the property- World Wide Lease, Inc. v. Woodworth, 111 Idaho 880 , 728 P.2d 769 (Ct.App.1987), relied upon by the plaintiffs, indicates that condition precedents are not favored by the courts, and that the conduct of the parties may be a factor in the analysis of the existence of the condition precedent. | 1 | 1992–1992 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.