Idaho Code
Idaho Code

Idaho Code § 5-222 (2026)

Actions on open accounts — Accrual of cause. 

✓ current as of May 2026
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Actions on open accounts — Accrual of cause. 

In an action brought to recover a balance due upon a mutual, open and current account, where there have been reciprocal demands between the parties, the cause of action is deemed to have accrued from the time of the last item proved in the account on either side.

Notes of Decisions
Cited in 5 cases, 1964–2016 · leading case: Unifund CCR, LLC v. Lorene K. Lowe, 367 P.3d 145 (Idaho 2016).
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Unifund CCR, LLC v. Lorene K. Lowe, 367 P.3d 145 (Idaho 2016). · cites it 12× “Did the District Court Err in Holding that the Cardholder Agreements Were Contracts in Writing? “An action upon any contract, obligation or liability founded upon an instrument in writing” must be brought within five years of when the cause of action accrued. I.C. § 5-216.”
Billings v. Sisters of Mercy of Idaho, 389 P.2d 224 (Idaho 1964). · cites it 4× “I.C. § 5-222 - "an action brought to recover a balance due upon a mutual, open and current account, * * * the cause of action is deemed to have accrued from the time of the last item proved in the account on either side.”
City of Grangeville v. Haskin, 777 P.2d 1208 (Idaho 1989). · cites it 4× “" I.C. § 5-222. *1213 Judge Reinhardt correctly stated the issue presented, whether or not the City of Grangeville could impose personal liability on Haskin for delinquent water, sewer, and garbage bills accumulated by his tenants when they opened up the accounts individually…”
Eagle Water Co., Inc. v. Roundy Pole Fence Co., Inc., 7 P.3d 1103 (Idaho 2000). · cites it 2× “I.C. § 5-222 provides: Actions on open accounts — Accrual of cause.”
Eagle Water Co., Inc. v. Roundy Pole Fence Co., Inc., 7 P.3d 1110 (Idaho Ct. App. 1999). · cites it 8× “§ 5-222, an action on a mutual, open and current account accrues at “the time of the last item proved in the account on either side.”
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