Collection of wages — Limitations.
Any person shall have the right to collect wages, penalties and liquidated damages provided by any law or pursuant to a contract of employment, but any action thereon shall be filed either with the department or commenced in a court of competent jurisdiction within two (2) years after the cause of action accrued, provided, however, that in the event salary or wages have been paid to any employee and such employee claims additional salary, wages, penalties or liquidated damages, because of work done or services performed during his employment for the pay period covered by said payment, any action therefor shall be commenced within twelve (12) months from the accrual of the cause of action. It is further provided that if any such cause of action has accrued prior to the effective date of this act, and is not barred by existing law, action thereon may be commenced within six (6) months from the effective date of this act. In the event an action is not commenced as herein provided, any remedy on the cause of action shall be forever barred.
Notes of Decisions
Manning v. Micron Tech., Inc., 506 P.3d 244 (Idaho 2022).
· cites it 38× “I.C. § 45-614 (2018) (italics added). 2 “A cause of action for the collection of wages accrues when an employee has a right to collect the wages that are allegedly owed to him.”
Paolini v. Albertson's Inc., 149 P.3d 822 (Idaho 2006).
· cites it 4× “It does not require payment of wage components that are not yet due.”
Hutchison v. Anderson, 950 P.2d 1275 (Idaho Ct. App. 1997).
· cites it 6× “We conclude that there was substantial competent evidence to support the district court’s finding that Robert was terminated on December 23, 1991, and that Robert’s May 29, 1992, filing date for this suit was within the six-month statute of limitation prescribed by I.C. §…”
Wood v. Kinetic Sys., Inc., 766 F. Supp. 2d 1080 (D. Idaho 2011).
· cites it 22× “KSI contends that both claims under Idaho state law are barred by the six month statute of limitations contained in Idaho Code § 45-614 . Wood does not dispute the factual contentions KSI makes in support of its statute of limitations argument, contending instead that by failing…”
Callenders, Inc. v. Beckman, 814 P.2d 429 (Idaho Ct. App. 1991).
· cites it 9× “Beckman argues that the trial court erred when it applied I.C. § 45-614 because that section deals with the collection of wages for “servants and laborers,” not with “remuneration” of partners.”
Mercedes E. Turner v. City of Lapwai, 339 P.3d 544 (Idaho 2014).
· cites it 6× “The City also argued that Turner’s claim for unpaid compensation was barred by the six-month statute of limitations in Idaho Code section 45-614, governing actions for unpaid wages.”
Sturm v. CB Transp., Inc., 943 F. Supp. 2d 1102 (D. Idaho 2013).
· cites it 6× “also previously addressed whether Plaintiffs claims were barred under the six month statute of limitations in Idaho Code § 45-614 , but did not decide the issue.”
Shay v. Cesler, 977 P.2d 199 (Idaho 1999).
· cites it 3× “” I.C. § 45-614. This chapter contains two attorney fee provisions.”
Bilow v. Preco, Inc., 966 P.2d 23 (Idaho 1998).
· cites it 2× “§ 45-608 provided: Any person shall have the right to collect salary, wages, overtime compensation, penalties and liquidated damages provided by any law or pursuant to a contract of employment, but any action thereon shall be commenced in a court of competent jurisdiction within…”
Roberts v. Wyman, 23 P.3d 152 (Idaho Ct. App. 2000).
· cites it 4× “This Court held that when an action is brought for wages and treble damages under I.C. §§ 45-614 and 45-617, attorney fees can be granted only pursuant to the attorney fee provisions of the wage claim statutes, and a fee award cannot be based upon I.”
Litster v. Litster Frost (Idaho 2024).
· cites it 28× “It is further provided that if any such cause of action has accrued prior to the effective date of this act, and is not barred by existing law, action thereon may be commenced within six (6) months from the effective date of this act.”
Neff v. Fuji Steak House, Inc. (D. Idaho 2021).
· cites it 2× “Idaho Code § 45-614 (emphasis added). In plain English, this means that if an employee alleges her employer paid some – but not all – amounts owing for any given pay period, then the employee must sue within one year of the date the claim accrues.”
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