Idaho Code
Idaho Code

Idaho Code § 19-2019 (2026)

Particular causes of challenge. 

✓ current as of May 2026
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Particular causes of challenge. 

Particular causes of challenge are of two kinds:

1.  For such a bias as, when the existence of the fact is ascertained, in judgment of law disqualifies the juror, and which is known in this code as implied bias.
2.  For the existence of a state of mind on the part of the juror in reference to the case, or to either of the parties, which, in the exercise of a sound discretion on the part of the trier, leads to the inference that he will not act with entire impartiality, and which is known in this code as actual bias.
Notes of Decisions
Cited in 25 cases (7 in the last 5 years), 1991–2026 · leading case: State v. Hauser, 150 P.3d 296 (Idaho Ct. App. 2006).
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State v. Hauser, 150 P.3d 296 (Idaho Ct. App. 2006). · cites it 8× “" I.C. § 19-2019(2). But disqualification is not necessarily required by every venire person who, at some point during voir dire, expresses bias toward a party.”
State v. Bowman, 866 P.2d 193 (Idaho Ct. App. 1993). · cites it 5× “I.C. § 19-2019. Bowman notes in her brief that these jurors were not challenged for actual bias under I.”
State v. Ramos, 808 P.2d 1313 (Idaho 1991). · cites it 8× “Idaho Code § 19-2019 (2) provides for the excusing of a juror for cause "[f]or the existence of a state of mind on the part of the juror in reference to the case, or to either of the parties, which, in the sound discretion on the part of the trier, leads to the inference that he…”
State v. Santana, 14 P.3d 378 (Idaho Ct. App. 2000). · cites it 6× “After the parties were allowed to re-question S.O., Judge Gutierrez determined that no actual bias existed and S.”
State v. Tolman, 828 P.2d 1304 (Idaho 1992). · cites it 4× “in reference to the case, or to either of the parties, which, in the exercise of a sound discretion on the part of the trier, leads to the inference that he will not act with entire impartiality, and which is known in this code as actual bias.”
State v. Azad Haji Abdullah, 348 P.3d 1 (Idaho 2015). · cites it 2× “” I.C. § 19-2019(2). Despite a juror’s expression of bias towards a party, “disqualification is not necessarily required.”
State v. Ish, 551 P.3d 746 (Idaho 2024). · cites it 6× “I.C. § 19-2019. Counsel’s questioning of Juror No.”
State v. Fueller, 547 P.3d 1210 (Idaho Ct. App. 2024). · cites it 8× “I.C. § 19-2019(1), (2). Here, because Juror 71’s responses did not fit within any of the enumerated categories of implied bias under I.”
State v. Rhoades, 822 P.2d 960 (Idaho 1991). · cites it 2× “The finding of the court was that Krubsack “had a state of mind and a personal situation which would have prevented his attention from being substantially devoted to this proceeding as contemplated in I.C. § 19-2019.” He was excused. The other, Michael Landry, was excused for…”
State v. Rey Alfredo Ornelas, 330 P.3d 1085 (Idaho Ct. App. 2014). · cites it 4× “I.C. § 19-2019; see also I.C.R. 24(b) (addressing the procedure for voir dire examination and challenging potential jurors for cause).”
Mulford v. Union Pac. R.R., 321 P.3d 684 (Idaho 2014). · cites it 2× “Mulford also asserts that I.C. §§ 19-2019 and 19-2020(1) support his claim of error.”
State v. Cody Sellers, 387 P.3d 137 (Idaho Ct. App. 2016). · cites it 4× “Idaho Code § 19-2019 (2) defines bias as “the existence of a state of mind on the part of the juror in reference to the case, or to either of the parties, which in the exercise of a sound discretion on the part of the trier, leads to the inference that he will not act with…”
Show all 25 citing cases →
— Idaho Code § 19-2019(1) — 5 cases
State v. Bowman, 866 P.2d 193 (Idaho Ct. App. 1993). “I.C. § 19-2019. Bowman notes in her brief that these jurors were not challenged for actual bias under I.”
State v. Fueller, 547 P.3d 1210 (Idaho Ct. App. 2024). “I.C. § 19-2019(1), (2). Here, because Juror 71’s responses did not fit within any of the enumerated categories of implied bias under I.”
State v. Melius (Idaho Ct. App. 2020).
State v. Frandsen (Idaho 2025).
State v. Frandsen (Idaho 2026).
— Idaho Code § 19-2019(2) — 17 cases
State v. Hauser, 150 P.3d 296 (Idaho Ct. App. 2006). “" I.C. § 19-2019(2). But disqualification is not necessarily required by every venire person who, at some point during voir dire, expresses bias toward a party.”
State v. Azad Haji Abdullah, 348 P.3d 1 (Idaho 2015). “” I.C. § 19-2019(2). Despite a juror’s expression of bias towards a party, “disqualification is not necessarily required.”
State v. Santana, 14 P.3d 378 (Idaho Ct. App. 2000). “After the parties were allowed to re-question S.O., Judge Gutierrez determined that no actual bias existed and S.”
State v. Bowman, 866 P.2d 193 (Idaho Ct. App. 1993). “I.C. § 19-2019. Bowman notes in her brief that these jurors were not challenged for actual bias under I.”
State v. Ramos, 808 P.2d 1313 (Idaho 1991). “Idaho Code § 19-2019 (2) provides for the excusing of a juror for cause "[f]or the existence of a state of mind on the part of the juror in reference to the case, or to either of the parties, which, in the sound discretion on the part of the trier, leads to the inference that he…”
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