Idaho Code
Idaho Code

Idaho Code § 18-2401 (2026)

Consolidation of theft offenses. 

✓ current as of May 2026
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Consolidation of theft offenses. 

(1) Conduct denominated theft in this chapter constitutes a single offense superceding the separate offenses previously known as embezzlement, extortion, false pretenses, cheats, misrepresentations, larceny and receiving stolen goods.

(2)  An accusation of theft may be supported by evidence that it was committed in any manner that would be theft under this chapter, notwithstanding the specification of a different manner in the indictment, information or complaint, subject only to the power of the court to ensure fair trial by granting a continuance or other appropriate relief where the conduct of the defense would be prejudiced by lack of fair notice or by surprise.
Notes of Decisions
Cited in 19 cases, 1967–2020 · leading case: State v. Major, 725 P.2d 115 (Idaho 1986).
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State v. Major, 725 P.2d 115 (Idaho 1986). · cites it 28× “" The legislature then, in subparagraph (2) of I.C. § 18-2401, stated that an accusation of theft under the new consolidated chapter could be supported by evidence of any of the other types of property crimes prior to the consolidation.”
State v. Darbin, 708 P.2d 921 (Idaho Ct. App. 1985). · cites it 4× “" Idaho Code § 18-2401 consolidated the various species of theft into a single statutory offense.”
State v. Manzanares, 272 P.3d 382 (Idaho 2012). · cites it 2× “manufacturing of a substance prohibited therein; (f) Any unlawful use of a weapon that is a felony pursuant to chapter 33, title 18, Idaho Code; (g) Assault and battery, as provided in chapter 9, title 18, Idaho Code; (h) Criminal solicitation, as provided in section 18-2001,…”
State of Iowa v. Betty Ann Nall, 894 N.W.2d 514 (Iowa 2017). “); Idaho Code Ann. § 18-2401 (West, Westlaw current through ch.”
State v. Seiber, 791 P.2d 18 (Idaho Ct. App. 1990). · cites it 4× “Furthermore, Idaho Code § 18-2401 (2) states "[a]n accusation of theft may be supported by evidence that it was committed in any manner that would be theft under this chapter, notwithstanding the specification of a different manner in the indictment, information or complaint.”
Jones v. State, 493 A.2d 1062 (Md. 1985). · cites it 2× “§§ 708-830 and 708-835 (1976); Idaho Code § 18-2401 (Supp. 1984); Ill. Ann.”
State v. Olin, 725 P.2d 801 (Idaho Ct. App. 1986). · cites it 4× “"Deprive" was given a special definition as withholding property "permanently or for so extended a period or under such circumstances that the major portion of its economic value or benefit is lost.”
State v. Jesser, 501 P.2d 727 (Idaho 1972). · cites it 2× “I.C. § 18-2401 provides: “Embezzlement is the fraudulent appropriation of property by a person to whom it has been intrusted.”
Cardiel, 25 I. & N. Dec. 12 (BIA 2009). “, Idaho Code § 18-2401 (1994) (“Conduct denominated theft in this chapter constitutes a single offense superceding [sic] the separate offenses previously known as embezzlement, extortion, false pretenses, cheats, misrepresentations, larceny and receiving stolen goods.”
State v. Compton, 450 P.2d 79 (Idaho 1969). · cites it 4× “" I.C. § 18-2401. The state apparently, though not specifically, elected to charge defendant under the particular statute, I.”
Perry v. Farm Bureau Mut. Ins. Co. of Idaho, 936 P.2d 1342 (Idaho Ct. App. 1997). · cites it 2× “The district court determined that there were no disputed issues of fact and that the conduct of Smith in this case would constitute embezzlement as it was defined in former I.”
State v. Carpenter, 435 P.2d 789 (Idaho 1967). · cites it 2× “” This definition is based on the provisions of I.C. § 18-2401, and § 18-2402, defining embezzlement and embezzlement by a public officer.”
Show all 19 citing cases →
— Idaho Code § 18-2401(1) — 3 cases
State v. Major, 725 P.2d 115 (Idaho 1986). “" The legislature then, in subparagraph (2) of I.C. § 18-2401, stated that an accusation of theft under the new consolidated chapter could be supported by evidence of any of the other types of property crimes prior to the consolidation.”
State v. Gums, 894 P.2d 163 (Idaho Ct. App. 1995).
State v. Margaret Fallon Arronte (Idaho Ct. App. 2010).
— Idaho Code § 18-2401(2) — 1 case
State v. Major, 725 P.2d 115 (Idaho 1986). “" The legislature then, in subparagraph (2) of I.C. § 18-2401, stated that an accusation of theft under the new consolidated chapter could be supported by evidence of any of the other types of property crimes prior to the consolidation.”
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