Idaho Code

Idaho Code § 20-209H (2026)

duty to establish inmate accounts — payment of restitution.

✓ current as of May 2026

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duty to establish inmate accounts — payment of restitution.

The state board of correction shall establish an account in the name of each inmate confined in a correctional facility. All moneys in the inmate’s possession upon admission, all moneys earned from institutional employment and all moneys received by the inmate from any other source, other than money that is contraband, shall be deposited in the inmate’s account. If the court ordered an inmate to make restitution under section 19-5304, Idaho Code, and the restitution is still owing, then twenty percent (20%) of each deposit in the inmate’s account shall be paid to the state board of correction who shall, within five (5) days after the end of the month, pay such moneys to the clerk of the court in which the restitution order was entered for payment to the victim. The provisions of this section shall apply to any inmate confined in a correctional facility on or after the effective date of this section.

Notes of Decisions

Cited in 4 cases (2 in the last 5 years), 2017–2024 · leading case: Kenneth M. Workman v. Christopher Rich, 403 P.3d 1200 (Idaho Ct. App. 2017).

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Kenneth M. Workman v. Christopher Rich, 403 P.3d 1200 (Idaho Ct. App. 2017). · cites it 2× “§§ 10-1110 and 10-1111 are applicable because garnishments from inmate accounts made under I.C. § 20-209H can only be made for restitution that “is still owing.”

Ayarzagoitia v. Christensen (D. Idaho 2020). · cites it 4× “Section 20-209H requires the Idaho Board of Correction to set up accounts for all prisoners held in state facilities.”

State v. Fisher (Idaho Ct. App. 2024). · cites it 4× “He contends that the requirement essentially places a burden on those who may wish to support an inmate to pay for the inmate’s restitution obligation.”

State v. Sanchez (Idaho Ct. App. 2021). · cites it 3× “§ 19-5305(2)” and the Department was “clearly acting within its statutory authority” to garnish Sanchez’s inmate account.”

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