Idaho Code

Idaho Code § 18-114 (2026)

Union of act and intent. 

✓ current as of May 2026
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Union of act and intent. 

In every crime or public offense there must exist a union, or joint operation, of act and intent, or criminal negligence.

Notes of Decisions
Cited in 74 cases (6 in the last 5 years), 1951–2025 · leading case: State v. Stiffler, 763 P.2d 308 (Idaho Ct. App. 1988).
State v. Stiffler, 763 P.2d 308 (Idaho Ct. App. 1988). · cites it 62× “Idaho Code § 18-114 provides that "[i]n every crime or public offense there must exist a union, or joint operation, of act and intent, or criminal negligence.”
State v. Card, 825 P.2d 1081 (Idaho 1991). · cites it 16× “[3] In addition, those individuals who are incapable of forming the necessary intent needed for the crime are protected by the mens rea requirements of I.C. §§ 18-114, [4] 18-115 [5] and 18-207.”
State v. Stiffler, 788 P.2d 220 (Idaho 1990). · cites it 16× “" I.C. § 18-114 (1987). A person is not capable of committing a crime, if the person who committed the act that is charged did so "under an ignorance or mistake of fact which disproves any criminal intent.”
State v. Beam, 710 P.2d 526 (Idaho 1985). · cites it 10× “" Beam does not specify any instance in which evidence relating to his mental condition was offered and excluded by the trial court.”
State v. Fox, 866 P.2d 181 (Idaho 1993). · cites it 12× “Fox therefore turns to I.C. § 18-114, which provides that "[i]n every crime or public offense there must exist a union, or joint operation, of act and intent, or criminal negligence.”
State v. Charlynda Goggin, 333 P.3d 112 (Idaho 2014). · cites it 10× “§ 37-2732(a) — does not expressly require a mental element, Idaho Code section 18-114 provides that “[i]n every crime or public offense there must exist a union, or joint operation, of act and intent, or criminal negligence.”
State v. Searcy, 798 P.2d 914 (Idaho 1990). · cites it 8× “The statutes in these three states, however, expressly permit evidence of mental illness or disability to be presented at trial, not in support of an independent insanity defense, but rather in order to permit the accused to rebut the state's evidence offered to prove that the…”
State v. Carsner, 894 P.2d 144 (Idaho Ct. App. 1995). · cites it 16× “While the preferred practice would be to not give any such instruction, [1] we cannot say that it amounted to error in this case.”
Stuart v. State, 801 P.2d 1216 (Idaho 1990). · cites it 4× “" Second, as was already highlighted: [T]he legislative abolition of intent in its alternative definition of murder by torture is clearly in conflict with the first definition, that which was properly adopted from the California Supreme Court, and also in headlong conflict with…”
State v. Curtis, 680 P.2d 1383 (Idaho Ct. App. 1984). · cites it 8× “Idaho Code § 18-114 , like § 18-4006, is of ancient vintage.”
State v. Draper, 261 P.3d 853 (Idaho 2011). · cites it 4× “" I.C. § 18-114. He argues that a reasonable jury could have found that Draper's intent to kill, as included in the definition of premeditation, [1] was not present when he stabbed Stoddart as, he argues, he only stabbed her after Adamcik stabbed her and he did so only at…”
State v. Enno, 807 P.2d 610 (Idaho 1991). · cites it 4× “13 [12] requires the jury to find the joint union of act and intent consistent with I.C. § 18-114 and also contains language from I.”
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