Idaho Code
Idaho Code

Idaho Code § 19-2020 (2026)

Grounds of challenge for implied bias. 

✓ current as of May 2026
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Grounds of challenge for implied bias. 

A challenge for implied bias may be taken for all or any of the following causes and for no other:

1.  Consanguinity or affinity within the fourth degree to the person alleged to be injured by the offense charged, or on whose complaint the prosecution was instituted, or to the defendant.
2.  Standing in the relation of guardian and ward, attorney and client, master and servant, or landlord and tenant, or being a member of the family or boarder or lodger of the defendant, or of the person alleged to be injured by the offense charged or on whose complaint the prosecution was instituted, or in his employment on wages.
3.  Being a party adverse to the defendant in a civil action or having complained against or been accused by him in a criminal prosecution.
4.  Having served on the grand jury which found the indictment, or on a coroner’s jury which inquired into the death of a person whose death is the subject of the indictment.
5.  Having served on a trial jury which has tried another person for the offense charged in the indictment.
6.  Having been one of a jury formerly sworn to try the same charge, and whose verdict was set aside or which was discharged without a verdict after the case was submitted to it, or being a witness for the prosecution, or subpoenaed as such.
7.  Having served as a juror in a civil action brought against the defendant for the act charged as an offense.
8.  Having formed or expressed an unqualified opinion or belief that the prisoner is guilty or not guilty of the offense charged.
9.  If the offense charged be punishable with death, the entertaining of such conscientious opinions as would preclude his finding the defendant guilty; in which case he must neither be permitted nor compelled to serve as a juror.
Notes of Decisions
Cited in 28 cases (5 in the last 5 years), 1953–2026 · leading case: State v. Enno, 807 P.2d 610 (Idaho 1991).
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State v. Enno, 807 P.2d 610 (Idaho 1991). · cites it 24× “2d 1327 (1987), this Court upheld the constitutionality of I.C. § 19-2020 and the procedure of "death qualifying" a jury in a capital case even though the jury does not participate in the sentencing process.”
State v. Mark Lankford, 399 P.3d 804 (Idaho 2017). · cites it 12× “” I.C. § 19-2020 (“Grounds of challenge for implied bias.”
State v. David Leon Johnson, 414 P.3d 234 (Idaho 2018). · cites it 8× “Idaho Code section 19-2020 provides a criminal defendant can strike a juror for implied bias on any one of nine enumerated grounds and “for no other.”
State v. Luke, 1 P.3d 795 (Idaho 2000). · cites it 16× “The District Court Did Not Deny Luke A Fair Trial By Allowing Juror Number Twelve To Remain On The Jury. Luke argues that the district court erred when it allowed one of the jurors, Mr.”
State v. Johns, 736 P.2d 1327 (Idaho 1987). · cites it 8× “III Johns challenges the wisdom of the legislature in adopting I.C. § 19-2020(9), which authorizes "death-qualifying" of juries in Idaho.”
Smith v. Phillips, 455 U.S. 209 (1982). · cites it 2× “1981); Idaho Code § 19-2020 (1979); Minn. Rule Crim.”
State v. Owen, 253 P.2d 203 (Idaho 1953). · cites it 8× “Among the grounds of challenge for implied bias provided by § 19-2020 I.C. is the following: "If the offense charged be punishable with death, the entertaining of such conscientious opinions as would preclude his finding the defendant guilty; in which case he must neither be…”
State v. Bowman, 866 P.2d 193 (Idaho Ct. App. 1993). · cites it 3× “Bowman recognizes that the relationship complained of in this case, that of church leader/ehurch member, is not specifically covered by I.C. § 19-2020(2). She argues, however, that this situation is unique because it is highly unusual for a minister or other member of the clergy…”
State v. Ish, 551 P.3d 746 (Idaho 2024). · cites it 8× “Ish has not demonstrated or otherwise argued that any of the legislatively designated relationships constituting grounds for implied bias in Idaho Code section 19-2020 are applicable to this case, nor can we find that the relationship at issue here is sufficiently analogous to…”
State v. Hauser, 150 P.3d 296 (Idaho Ct. App. 2006). · cites it 4× “Here, we only address whether Juror 31 had actual bias since the facts do not fit within any of the exclusive categories of implied bias enumerated in I.C. § 19-2020. Actual bias is defined as "the existence of a state of mind on the part of the juror in reference to the case,…”
State v. Major, 665 P.2d 703 (Idaho 1983). · cites it 4× “In that case, in looking at I.C. § 19-2020, [1] which allows for challenges for implied bias, we ruled that the "proscribed relationship [here attorney/client *707 relationship] between a prospective juror and an attorney in the case is not a ground for challenge for implied…”
State v. Santana, 14 P.3d 378 (Idaho Ct. App. 2000). · cites it 4× “” Idaho Code § 19-2020 provides the legal grounds for finding implied bias, none of which encompass the instant situation.”
Show all 28 citing cases →
— Idaho Code § 19-2020(1) — 2 cases
State v. Frandsen (Idaho 2025).
State v. Frandsen (Idaho 2026).
— Idaho Code § 19-2020(2) — 3 cases
State v. Luke, 1 P.3d 795 (Idaho 2000). “The District Court Did Not Deny Luke A Fair Trial By Allowing Juror Number Twelve To Remain On The Jury. Luke argues that the district court erred when it allowed one of the jurors, Mr.”
State v. Bowman, 866 P.2d 193 (Idaho Ct. App. 1993). “Bowman recognizes that the relationship complained of in this case, that of church leader/ehurch member, is not specifically covered by I.C. § 19-2020(2). She argues, however, that this situation is unique because it is highly unusual for a minister or other member of the clergy…”
State v. Cypher, 438 P.2d 904 (Idaho 1968).
— Idaho Code § 19-2020(8) — 1 case
State v. Enno, 807 P.2d 610 (Idaho 1991). “2d 1327 (1987), this Court upheld the constitutionality of I.C. § 19-2020 and the procedure of "death qualifying" a jury in a capital case even though the jury does not participate in the sentencing process.”
— Idaho Code § 19-2020(9) — 3 cases
State v. Enno, 807 P.2d 610 (Idaho 1991). “2d 1327 (1987), this Court upheld the constitutionality of I.C. § 19-2020 and the procedure of "death qualifying" a jury in a capital case even though the jury does not participate in the sentencing process.”
State v. Johns, 736 P.2d 1327 (Idaho 1987). “III Johns challenges the wisdom of the legislature in adopting I.C. § 19-2020(9), which authorizes "death-qualifying" of juries in Idaho.”
Larsen v. May, 468 P.2d 866 (Idaho 1970).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.