Idaho Code
Idaho Code

Idaho Code § 5-214A (2026)

Action to foreclose mortgage on real property. 

✓ current as of May 2026
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Action to foreclose mortgage on real property. 

An action for the foreclosure of a mortgage on real property must be commenced within five (5) years from the maturity date of the obligation or indebtedness secured by such mortgage. If the obligation or indebtedness secured by such mortgage does not state a maturity date, then the date of the accrual of the cause of action giving rise to the right to foreclose shall be deemed the date of maturity of such obligation or indebtedness.

Notes of Decisions
Cited in 9 cases, 1984–2019 · leading case: Nathon A. Baughman v. Wells Fargo Bank, 395 P.3d 393 (Idaho 2017).
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Nathon A. Baughman v. Wells Fargo Bank, 395 P.3d 393 (Idaho 2017). · cites it 18× “This is an appeal out of Kootenai County from a judgment dismissing the Plaintiffs’ claims, including that the statute of limitations under Idaho Code section 5-214A barred any foreclosure proceedings by the Defendants, and granting a counterclaim for judicial foreclosure of a…”
Elliott v. Darwin Neibaur Farms, 69 P.3d 1035 (Idaho 2003). · cites it 12× “Statute of Limitation The Neibaurs contend that the action filed by the Elliotts was not filed within the applicable statute of limitation prescribed by I.C. § 5-214A. While the promissory notes recited that final payment of the principal balance would be due on November 15,…”
CMJ Props., LLC v. JP Morgan Chase Bank, N.A., 406 P.3d 873 (Idaho 2017). · cites it 10× “The district court did not err in interpreting the statute of limitations set forth in Idaho Code section 5-214A, CMJ argues alternatively that if the maturity date of the credit line is a question of law, the district court erred in interpreting the statute of limitations set…”
Monitor Fin., L.C. v. Wildlife Ridge Estates, LLC, 433 P.3d 183 (Idaho 2019). · cites it 2× “Idaho Code section 5-214A provides a five-year statute of limitations for the commencement of an action for the foreclosure of a mortgage.”
Karterman v. Rosenkrance, 901 P.2d 491 (Idaho 1995). · cites it 14× “This is a mortgage foreclosure case in which the United States challenges the trial court’s application of Idaho’s statute of limitation in mortgage foreclosure actions, I.C. § 5-214A. We conclude that I.C. § 5-214A cannot be applied against the United States due to federal…”
McCray v. Twitchell, 735 P.2d 1098 (Idaho Ct. App. 1987). · cites it 8× “The trial court indicated it was sympathetic to the sellers’ interpretation of I.C. § 5-214A, but concluded that our Supreme Court’s decision in Gebrueder Heideman, K.”
Gebrueder Heidemann, K.G. v. A.M.R. Corp., 688 P.2d 1180 (Idaho 1984). · cites it 2× “Ill Respondent has cross appealed, claiming that plaintiff’s suit is barred by I.C. § 5-214A, which states: “5-214A. Action to foreclose mortgage on real property.”
Isaak v. Idaho First Nat'l Bank, 811 P.2d 832 (Idaho 1991). · cites it 2× “when evidence had been received of the value of the farm could the trial court have determined whether the Isaaks would have been entitled to a deficiency judgment against Haney. Although there was a delay of more than a year after the default by Haney on the November 1, 1984…”
Monitor Fin. v. Wildlife Ridge Estates (Idaho 2019). · cites it 2× “Idaho Code section 5-214A provides a five-year statute of limitations for the commencement of an action for the foreclosure of a mortgage.”
— Idaho Code § 5-214A(l) — 1 case
McCray v. Twitchell, 735 P.2d 1098 (Idaho Ct. App. 1987). “The trial court indicated it was sympathetic to the sellers’ interpretation of I.C. § 5-214A, but concluded that our Supreme Court’s decision in Gebrueder Heideman, K.”
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