Idaho Code
Idaho Code

Idaho Code § 45-513 (2026)

Joinder of actions — Filing fees as costs — Attorney’s fees. 

✓ current as of May 2026
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Joinder of actions — Filing fees as costs — Attorney’s fees. 

Any number of persons claiming liens against the same property may join in the same action, and when separate actions are commenced the court may consolidate them. The court shall also allow as part of the costs the moneys paid for filing and recording the claim, and reasonable attorney’s fees.

Notes of Decisions
Cited in 48 cases (3 in the last 5 years), 1954–2024 · leading case: Regdab, Inc. v. Graybill, 444 P.3d 323 (Idaho 2019).
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Regdab, Inc. v. Graybill, 444 P.3d 323 (Idaho 2019). · cites it 30× “No party filed an answer and the district court granted Regdab's motion for default. Most of the defendants later settled with Regdab.”
Magleby v. Kevin, 296 P.3d 400 (Idaho 2013). · cites it 25× “The Maglebys recovered attorney fees from the Garns under Idaho Code § 45-513 . The Maglebys recovered attorney fees against ITP by default.”
Elec. Wholesale Supply Co. v. Nielson, 41 P.3d 242 (Idaho 2001). · cites it 10× “There is substantial and competent evidence to support the district court’s conclusion. VI. THE DISTRICT COURT DID NOT ABUSE ITS DISCRETION BY AWARDING EWSC A DISPROPORTIONATE AMOUNT OF ATTORNEY FEES COMPARED TO THE AMOUNT OF THE AWARD.”
L & W SUPPLY CORP. v. Chartrand Fam. Trust, 40 P.3d 96 (Idaho 2002). · cites it 10× “Chartrand requested attorney fees pursuant to I.C. § 45-513. The district judge held that, although Chartrand was the prevailing party, it was not entitled to an award of attorney fees under that section.”
Credit Suisse AG v. Teufel Nursery, Inc., 321 P.3d 739 (Idaho 2014). · cites it 10× “In its Order Re: Attorney Fees, the district court ultimately awarded Teufel attorney fees under Idaho Code § 45-513 in the amount of $162,775.”
Oldcastle Precast, Inc. v. Parktowne Constr., Inc., 128 P.3d 913 (Idaho 2005). · cites it 24× “Section 2 of the enactment provided that subcontractors, laborers, and other persons could lien the public works of any county, city, town or school district.”
Minich v. Gem State Developers, Inc., 591 P.2d 1078 (Idaho 1979). · cites it 4× “§ 44-513 (now I.C. § 45-513), which read: "The court shall also allow as part of the costs .”
Olsen v. Frank, 873 P.2d 1340 (Idaho Ct. App. 1994). · cites it 29× “) Idaho Code § 45-513 , on the other hand, states, “The court shall also allow as part of the costs the moneys paid for filing and recording the claim [of lien], and reasonable attorney’s fees.”
Fairfax v. Ramirez, 982 P.2d 375 (Idaho Ct. App. 1999). · cites it 20× “Finally, the court awarded Fairfax attorney fees pursuant to I.C. §§ 45-513 and 12-120(3). The Ramirezes filed pro se a notice of appeal from the memorandum decision on the bench trial.”
Acoustic Specialties, Inc. v. Wright, 651 P.2d 529 (Idaho 1982). · cites it 16× “The next issue presented on appeal is whether the district court erred in holding that the respondents were entitled to a reasonable attorney fee pursuant to I.C. § 45-513. The district court determined a reasonable attorney fee award to Acoustic Specialties was $10,000.”
Intermountain Real Props., LLC v. Draw, LLC, 311 P.3d 734 (Idaho 2013). · cites it 6× “The first issue is Intermountain’s lien foreclosure appeal.”
Parkwest Homes v. Julie G. Barnson, 302 P.3d 18 (Idaho 2013). · cites it 6× “However, Idaho Code section 45-513 provides for the award of reasonable attorney fees in an action to foreclose a mechanic’s lien.”
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