causation instruction (Idaho) · Go Syfert
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causation instruction in Idaho

12 Idaho opinions name it 2 courts 2005–2026 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.

Followed or applied (6)

CaseFollowedCited
Coombs v. Curnowgreen
idaho · 2009 · cited in 1 Idaho opinions naming this issue, 2025–2025
2 sentences

2025NCMC relies on Clark v. Klein, 137 Idaho 154, 159 , 45 P.3d 810, 815 (2002) and Coombs v. Curnow, 148 Idaho 129, 140 , 219 P.3d 453, 464 (2009).

2025NCMC relies on Clark v. Klein, 137 Idaho 154, 159 , 45 P.3d 810, 815 (2002) and Coombs v. Curnow, 148 Idaho 129, 140 , 219 P.3d 453, 464 (2009).

11
Clark v. Kleingreen
idaho · 2002 · cited in 1 Idaho opinions naming this issue, 2025–2025
2 sentences

2025NCMC relies on Clark v. Klein, 137 Idaho 154, 159 , 45 P.3d 810, 815 (2002) and Coombs v. Curnow, 148 Idaho 129, 140 , 219 P.3d 453, 464 (2009).

2025NCMC relies on Clark v. Klein, 137 Idaho 154, 159 , 45 P.3d 810, 815 (2002) and Coombs v. Curnow, 148 Idaho 129, 140 , 219 P.3d 453, 464 (2009).

11
State v. Montroygreen
idaho · 1923 · cited in 1 Idaho opinions naming this issue, 2017–2017
2 sentences

2017The right to counsel is “made obligatory upon the States by the Fourteenth Amendment,” Gideon, 372 U.S. at 342, 83 S.Ct. at 795 , 9 L.Ed.2d at 803-04 (emphasis added); see also Montroy, 37 Idaho at 690 , 217 P. at 614 .

2017The right to counsel is “made obligatory upon the States by the Fourteenth Amendment,” Gideon, 372 U.S. at 342, 83 S.Ct. at 795 , 9 L.Ed.2d at 803-04 (emphasis added); see also Montroy, 37 Idaho at 690 , 217 P. at 614 .

11
Gideon v. Wainwrightgreen
scotus · 1963 · cited in 1 Idaho opinions naming this issue, 2017–2017
2 sentences

2017The right to counsel is “made obligatory upon the States by the Fourteenth Amendment,” Gideon, 372 U.S. at 342, 83 S.Ct. at 795 , 9 L.Ed.2d at 803-04 (emphasis added); see also Montroy, 37 Idaho at 690 , 217 P. at 614 .

2017The right to counsel is “made obligatory upon the States by the Fourteenth Amendment,” Gideon, 372 U.S. at 342, 83 S.Ct. at 795 , 9 L.Ed.2d at 803-04 (emphasis added); see also Montroy, 37 Idaho at 690 , 217 P. at 614 .

11
State v. Perrygreen
idaho · 2010 · cited in 1 Idaho opinions naming this issue, 2015–2015
2 sentences

2015See State v. Perry, 150 Idaho 209, 221, 226-227 , 245 P.3d 961, 973, 978-79 (2010).

2015See State v. Perry, 150 Idaho 209, 221, 226-227 , 245 P.3d 961, 973, 978-79 (2010).

11
State v. Zichkogreen
idaho · 1996 · cited in 1 Idaho opinions naming this issue, 2015–2015
2 sentences

2015See State v. Zichko, 129 Idaho 259, 263 , 923 P.2d 966, 970 (1996). 19 In summary, this Court recognizes that proximate cause could serve to limit criminal liability for arson in some cases.

2015See State v. Zichko, 129 Idaho 259, 263 , 923 P.2d 966, 970 (1996). 19 In summary, this Court recognizes that proximate cause could serve to limit criminal liability for arson in some cases.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway.

Also cited on this issue (11)

CaseCitedYears
Sharp v. Thomas Bros Plumbing green
idaho · 2022
2 sentences

2026We conclude that the Commission applied an incorrect legal standard because the Commission’s analysis is inconsistent with the compensable consequences doctrine, discussed in Sharp v. Thomas Brothers Plumbing, 170 Idaho 343 , 510 P.3d 1136 (2022).

2026We conclude that the Commission applied an incorrect legal standard because the Commission’s analysis is inconsistent with the compensable consequences doctrine, discussed in Sharp v. Thomas Brothers Plumbing, 170 Idaho 343 , 510 P.3d 1136 (2022).

22026–2026
State v. Azad Haji Abdullah green
idaho · 2015
2 sentences

2019Id.

2019Id.

22018–2019
Jerome Thriftway Drug, Inc. v. Winslow green
idaho · 1986
2 sentences

2025In Clark, the Supreme Court found no error in the district court’s instruction on standard of care, stating: In the present case, Appellants objected to Instruction No. 18 because it states that “[t]he mere fact that an undesirable or unfortunate result occurs following medical care rendered by the Defendant does not, of itself, establish a breach of the standard of care.” Although in Jerome Thriftway Drug, Inc. v. Winslow, 110 Idaho 615 , 717 P.2d 1033 (1986), we found the trial court did not abuse its discretion in giving a jury instruction that provided “the mere occurrence of a fire does n

2025In Clark, the Supreme Court found no error in the district court’s instruction on standard of care, stating: In the present case, Appellants objected to Instruction No. 18 because it states that “[t]he mere fact that an undesirable or unfortunate result occurs following medical care rendered by the Defendant does not, of itself, establish a breach of the standard of care.” Although in Jerome Thriftway Drug, Inc. v. Winslow, 110 Idaho 615 , 717 P.2d 1033 (1986), we found the trial court did not abuse its discretion in giving a jury instruction that provided “the mere occurrence of a fire does n

12025–2025
Newberry v. Martens green
idaho · 2005
2 sentences

2025Citing Newberry v. Martens, 142 Idaho 284 , 127 P.3d 187 (2005), Mann asserts that the “unfortunate result” language is inappropriate in reference to causation in a medical malpractice case.

2025Citing Newberry v. Martens, 142 Idaho 284 , 127 P.3d 187 (2005), Mann asserts that the “unfortunate result” language is inappropriate in reference to causation in a medical malpractice case.

12025–2025
State v. Corbus green
idaho · 2011
1 sentence

2019The argument is also contrary to the causation analysis applied in Cottrell and articulated by the Idaho Supreme Court in Corbus, 150 Idaho 599 , 240 P.3d 398 .

12019–2019
State v. Cottrell green
idahoctapp · 2012
2 sentences

2019Cottrell, 152 Idaho at 393 , 271 P.3d at 1249 .

2019Cottrell, 152 Idaho at 393 , 271 P.3d at 1249 .

12019–2019
Aberdeen Investors, Inc. v. Adams County Board of County Commissioners green
coloctapp · 2009
1 sentence

2019The argument is also contrary to the causation analysis applied in Cottrell and articulated by the Idaho Supreme Court in Corbus, 150 Idaho 599 , 240 P.3d 398 .

12019–2019
State v. Lloyd Hardin McNeil green
idahoctapp · 2014
1 sentence

2017Wisdom cites us to State v. McNeil, 168 Idaho 280 , 346 P.3d 297 (Ct. App. 2014), but McNeil does not change our analysis.

12017–2017
Hatley v. Lewiston Grain Growers, Inc. green
idaho · 1976
2 sentences

2014Because the claimant in Hatley died, the Court applied a presumption in Idaho Code section 72-228 that where “the injury arose in the course of employment, it shall be presumed, in the absence of substantial evidence to the contrary, ... that the injury or death was not occasioned by the employee’s intoxication.” Id. at 722 , 552 P.2d at 485 .

2014Because the claimant in Hatley died, the Court applied a presumption in Idaho Code section 72-228 that where “the injury arose in the course of employment, it shall be presumed, in the absence of substantial evidence to the contrary, ... that the injury or death was not occasioned by the employee’s intoxication.” Id. at 722 , 552 P.2d at 485 .

12014–2014
State v. Vasquez green
idahoctapp · 2005
2 sentences

2013A defendant does not meet this causation test if the defendant “was already serving time in one county . . . when he was served with an arrest warrant from another county . . . on unrelated charges.” Vasquez, 142 Idaho at 68 , 122 P.3d at 1168 .

2013A defendant does not meet this causation test if the defendant “was already serving time in one county . . . when he was served with an arrest warrant from another county . . . on unrelated charges.” Vasquez, 142 Idaho at 68 , 122 P.3d at 1168 .

12013–2013
State v. Horn green
idahoctapp · 1993
2 sentences

2005Although Vasquez argues that this Court should use a causation test to determine whether he is entitled to prejudgment credit for time served in the Payette County jail, he fails to cite in his opening brief State v. Horn, 124 Idaho 849 , 865 P.2d 176 , a case directly on point, for application of this test. 1 In Horn the defendant, like Vasquez, was being confined in a county jail for one charge when he was served with an arrest warrant from a different county for an unrelated charge.

2005Although Vasquez argues that this Court should use a causation test to determine whether he is entitled to prejudgment credit for time served in the Payette County jail, he fails to cite in his opening brief State v. Horn, 124 Idaho 849 , 865 P.2d 176 , a case directly on point, for application of this test. 1 In Horn the defendant, like Vasquez, was being confined in a county jail for one charge when he was served with an arrest warrant from a different county for an unrelated charge.

12005–2005

Statutes the citing opinions construe

ID § Idaho Code § 18-802 (3) ID § Idaho Code § 19-4906 (3) ID § Idaho Code § 72-102 (3) ID § Idaho Code § 72-201 (3) ID § Idaho Code § 72-804 (3)

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.

Where else courts name it

TX 252 (1978–2026) CA 161 (1978–2026) PA 61 (1952–2026) IL 49 (1980–2025) IA 48 (1982–2023) MI 47 (1988–2026) MO 40 (1989–2024) OH 33 (1991–2023) UT 30 (1986–2026) MA 28 (1980–2025) OR 28 (1990–2024) NY 27 (1933–2024) MD 26 (1977–2022) AL 26 (1981–2025) MN 25 (1987–2026) LA 24 (1984–2019) NM 23 (1938–2024) CT 22 (1991–2025) WA 22 (1983–2023) FL 21 (1984–2025) NJ 19 (1990–2026) WI 19 (1995–2024) GA 18 (1902–2025) SD 16 (1992–2020) VA 13 (1988–2024) CO 13 (1984–2020) AZ 13 (1997–2024) AK 12 (1988–2022) DC 12 (1990–2024) ID 12 (2005–2026) MT 11 (1990–2022) IN 11 (1986–2026) TN 11 (1997–2019) VT 10 (1991–2024) NC 10 (1988–2020) HI 9 (1995–2018) KS 9 (1991–2025) ME 8 (1982–2021) WY 8 (1982–2013) NE 8 (1996–2026) RI 7 (1993–2008) NH 7 (1986–2021) MS 7 (1992–2011) AR 6 (1999–2025) DE 4 (2014–2024) KY 3 (2006–2026) WV 2 (1997–2001) NV 2 (2012–2026) OK 2 (1981–2016) ND 2 (1994–2010)

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.

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