disclosure requirement in Idaho

2017Our decision in State v. Olsen, 103 Idaho 278 , 647 P.2d 734 (1982), appears to be the seminal case involving the disclosure of rebuttal witnesses.

2017Olsen, 103 Idaho at 283 , 647 P.2d at 739 .

2017When the State called the booking deputy and investigating officer to testify in rebuttal, Montgomery objected based on a footnote in State v. Wilson, 158 Idaho 585 , 589 n.2, 349 P.3d 439 , 443 n.2 (Ct. App. 2015), which pointed out that Idaho Criminal Rule 16(b)(6) contained no language excepting rebuttal witnesses from the disclosure requirement and questioned the precedential value of our case law which did not address the language of the rule.

2017When the State called the booking deputy and investigating officer to testify in rebuttal, Montgomery objected based on a footnote in State v. Wilson, 158 Idaho 585 , 589 n.2, 349 P.3d 439 , 443 n.2 (Ct. App. 2015), which pointed out that Idaho Criminal Rule 16(b)(6) contained no language excepting rebuttal witnesses from the disclosure requirement and questioned the precedential value of our case law which did not address the language of the rule.

2025Under that standard, there must be “a substantial relation between the disclosure requirement and a sufficiently important governmental interest.” Id. (quoting Doe v. Reed, 561 U.S. 186 , 196 (2010)).

2025Id.

2025Under that standard, there must be “a substantial relation between the disclosure requirement and a sufficiently important governmental interest.” Id. (quoting Doe v. Reed, 561 U.S. 186 , 196 (2010)).

2024The district court in Lepper did not issue a subsequent order modifying the discovery deadlines in its scheduling order. 11 Instead, the district court in Lepper sanctioned a party for violating a disclosure requirement that “they had no prior notice of.” Id.

2023See Brady v. Maryland, 373 U.S. 83 (1963); Napue v. Illinois, 360 U.S. 264 (1959).

2017The district court did exactly what it was required to do—it applied our existing case law, stating: The prior precedent established by previous rulings of the Supreme Court and continuing beyond the amendment to Idaho Code Section 19-1302 stands for the proposition that rebuttal witnesses do not have to be disclosed, and those cases have not been overruled, which includes State versus Jones, 125 Idaho 477 [ 873 P.2d 122 (1994)], and State versus Lopez, 107 Idaho 726 [ 692 P.2d 370 (1984)].

2017The district court did exactly what it was required to do—it applied our existing case law, stating: The prior precedent established by previous rulings of the Supreme Court and continuing beyond the amendment to Idaho Code Section 19-1302 stands for the proposition that rebuttal witnesses do not have to be disclosed, and those cases have not been overruled, which includes State versus Jones, 125 Idaho 477 [ 873 P.2d 122 (1994)], and State versus Lopez, 107 Idaho 726 [ 692 P.2d 370 (1984)].

2017The district court did exactly what it was required to do—it applied our existing case law, stating: The prior precedent established by previous rulings of the Supreme Court and continuing beyond the amendment to Idaho Code Section 19-1302 stands for the proposition that rebuttal witnesses do not have to be disclosed, and those cases have not been overruled, which includes State versus Jones, 125 Idaho 477 [ 873 P.2d 122 (1994)], and State versus Lopez, 107 Idaho 726 [ 692 P.2d 370 (1984)].

2017The district court did exactly what it was required to do—it applied our existing case law, stating: The prior precedent established by previous rulings of the Supreme Court and continuing beyond the amendment to Idaho Code Section 19-1302 stands for the proposition that rebuttal witnesses do not have to be disclosed, and those cases have not been overruled, which includes State versus Jones, 125 Idaho 477 [ 873 P.2d 122 (1994)], and State versus Lopez, 107 Idaho 726 [ 692 P.2d 370 (1984)].

2006B.Scope of the Industrial Commission’s Review of Attorney Fees The Industrial Commission is empowered by statute to issue rules and regulations necessary to accomplish the purpose of the Worker’s Compensation Act, I.C. § 72-508; Rhodes, 125 Idaho at 141 , 868 P.2d at 469 , which is to provide “sure and certain relief for injured workmen and their families and dependents ...” I.C. § 72-201.

2006B.Scope of the Industrial Commission’s Review of Attorney Fees The Industrial Commission is empowered by statute to issue rules and regulations necessary to accomplish the purpose of the Worker’s Compensation Act, I.C. § 72-508; Rhodes, 125 Idaho at 141 , 868 P.2d at 469 , which is to provide “sure and certain relief for injured workmen and their families and dependents ...” I.C. § 72-201.