Idaho Code
Idaho Code

Idaho Code § 19-4206 (2026)

Prisoners required to exhaust administrative remedies in conditions of confinement cases. 

✓ current as of May 2026
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Prisoners required to exhaust administrative remedies in conditions of confinement cases. 

(1) Unless a petitioner who is a prisoner establishes to the satisfaction of the court that he is in imminent danger of serious physical injury, no petition for writ of habeas corpus or any other civil action shall be brought by any person confined in a state or county institution, or in a state, local or private correctional facility, with respect to conditions of confinement until all available administrative remedies have been exhausted. If the institution, or state, local or private correctional facility does not have a system for administrative remedy, this requirement shall be waived.

(2)  At the time of filing, the petitioner shall submit, together with the petition for writ of habeas corpus a true, correct and complete copy of any documentation which demonstrates that he has exhausted administrative remedies described in subsection (1) of this section.
(3)  If at the time of filing the petition for writ of habeas corpus the petitioner fails to comply with this section, the court shall dismiss the petition with or without prejudice.
Notes of Decisions
Cited in 14 cases (1 in the last 5 years), 1983–2021 · leading case: Drennon v. Idaho State Corr. Inst., 181 P.3d 524 (Idaho Ct. App. 2007).
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Drennon v. Idaho State Corr. Inst., 181 P.3d 524 (Idaho Ct. App. 2007). · cites it 21× “1 This Court has held that I.C. § 19-4206 requires an inmate filing a petition for a writ of habeas corpus to submit, as part of the petition, any documentation in his or her possession or within his or her reach, showing participation in the applicable grievance process.”
Marks v. Vehlow, 671 P.2d 473 (Idaho 1983). · cites it 4× “I.C. § 19-4206 provides: "If the writ is directed to the sheriff or other ministerial officer of the court, out of which it issues, it must be delivered by the clerk to such officer without delay, as other writs are delivered for service.”
Drennon v. Fisher, 120 P.3d 1146 (Idaho Ct. App. 2005). · cites it 6× “” Here, the district court’s order granting the respondent’s motion to dismiss stated: The Respondent has directed the Court’s attention to Idaho Code § 19-4206 which requires that a petitioner, who is a prisoner, must submit documentation with the petition demonstrating that he…”
Butters v. Valdez, 241 P.3d 7 (Idaho Ct. App. 2010). · cites it 12× “ction of the court that he is in imminent danger of serious physical injury, no petition for writ of habeas corpus or any other civil action shall be brought by any person confined in a state or county institution, or in a state, local or private correctional facility, with…”
Burghart v. Carlin, 264 P.3d 71 (Idaho Ct. App. 2011). · cites it 4× “I.C. § 19-4206; Dremion v. Idaho State Corr.”
State v. Strange, 214 P.3d 672 (Idaho Ct. App. 2009). · cites it 4× “The district court denied Strange’s motion for new trial, and sentenced him to a unified term of five years, with one and one-half years determinate on the possession charge. This appeal followed.”
Williams v. Hollinshead (Idaho 2020). · cites it 14× “The district court granted summary judgment, holding that the Petitioners had failed to exhaust their administrative remedies as required by Idaho Code section 19-4206, and that they did not qualify for an exception.”
Williams v. Hollinshead (Idaho 2020). · cites it 14× “The district court granted summary judgment, holding that the Petitioners had failed to exhaust their administrative remedies as required by Idaho Code section 19-4206, and that they did not qualify for an exception.”
Rogstad v. Overguard (D. Idaho 2019). · cites it 4× “§ 1997e(a) and Idaho Code § 19-4206 (1).” Def.’s MSJ 1 (Dkt.”
Meadows v. Atencio (D. Idaho 2021). · cites it 4× “” Idaho Code § 19-4206 (1); see also Drennon v.”
William Gray v. Kristi Lynch (Idaho Ct. App. 2012). · cites it 2× “Idaho Code § 19-4206 requires habeas corpus petitioners to exhaust administrative remedies in order to avoid dismissal.”
William Lightner v. M. Tidwell (Idaho Ct. App. 2010). · cites it 2× “Valdez, Docket No. 36856 (Ct. App. Sept. 30, 2010). The affidavits and submitted exhibits establish that the IDOC follows a three-step process for inmates to seek a remedy within the prison system.”
Show all 14 citing cases →
— Idaho Code § 19-4206(1) — 6 cases
Drennon v. Idaho State Corr. Inst., 181 P.3d 524 (Idaho Ct. App. 2007). “1 This Court has held that I.C. § 19-4206 requires an inmate filing a petition for a writ of habeas corpus to submit, as part of the petition, any documentation in his or her possession or within his or her reach, showing participation in the applicable grievance process.”
Butters v. Valdez, 241 P.3d 7 (Idaho Ct. App. 2010). “ction of the court that he is in imminent danger of serious physical injury, no petition for writ of habeas corpus or any other civil action shall be brought by any person confined in a state or county institution, or in a state, local or private correctional facility, with…”
Williams v. Hollinshead (Idaho 2020). “The district court granted summary judgment, holding that the Petitioners had failed to exhaust their administrative remedies as required by Idaho Code section 19-4206, and that they did not qualify for an exception.”
Williams v. Hollinshead (Idaho 2020). “The district court granted summary judgment, holding that the Petitioners had failed to exhaust their administrative remedies as required by Idaho Code section 19-4206, and that they did not qualify for an exception.”
Meadows v. Atencio (D. Idaho 2021). “” Idaho Code § 19-4206 (1); see also Drennon v.”
— Idaho Code § 19-4206(2) — 4 cases
Burghart v. Carlin, 264 P.3d 71 (Idaho Ct. App. 2011). “I.C. § 19-4206; Dremion v. Idaho State Corr.”
Drennon v. Idaho State Corr. Inst., 181 P.3d 524 (Idaho Ct. App. 2007). “1 This Court has held that I.C. § 19-4206 requires an inmate filing a petition for a writ of habeas corpus to submit, as part of the petition, any documentation in his or her possession or within his or her reach, showing participation in the applicable grievance process.”
Williams v. Hollinshead (Idaho 2020). “The district court granted summary judgment, holding that the Petitioners had failed to exhaust their administrative remedies as required by Idaho Code section 19-4206, and that they did not qualify for an exception.”
Williams v. Hollinshead (Idaho 2020). “The district court granted summary judgment, holding that the Petitioners had failed to exhaust their administrative remedies as required by Idaho Code section 19-4206, and that they did not qualify for an exception.”
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