Idaho Code
Idaho Code § 5-224 (2026)
Actions for other relief.
✓ current as of May 2026
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Actions for other relief.
An action for relief not hereinbefore provided for must be commenced within four (4) years after the cause of action shall have accrued.
Notes of Decisions
Cited in 91
cases (23 in the last 5 years), 1933–2025 · leading case: Guzman v. Piercy / Canyon Cnty. / Sutton, 318 P.3d 918 (Idaho 2014).
Guzman v. Piercy / Canyon Cnty. / Sutton, 318 P.3d 918 (Idaho 2014). “Guzman’s and Sutton’s answers included a statutes of limitations defense based on I.C. § 5-224, and Guzman again raised the doctrine of equitable estoppel and doctrine of estoppel by laches as affirmative defenses.”
C & G, Inc. v. Canyon High. Dist. No. 4, 75 P.3d 194 (Idaho 2003). “On September 24, 1998, the Highway District filed a motion for summary judgment on the ground the applicable four-year statute of limitations, Idaho Code § 5-224 (2002), ran before C & G filed its complaint.”
Sommer v. Misty Valley, LLC, 511 P.3d 833 (Idaho 2021). “The district court held that the Sommers’ declaratory judgment action was not time-barred by the four-year “catch-all” statute of limitations set forth in Idaho Code section 5-224 which states: 6 ACTIONS FOR OTHER RELIEF.”
Brown v. Greenheart, 335 P.3d 1 (Idaho 2014). “” I.C. § 5-224. The district court correctly held that the Browns’ quiet title action was not barred by the four-year statute of limitations provided by Idaho Code section 5-224.”
Hibbler v. Fisher, 712 P.2d 708 (Idaho Ct. App. 1985). “§ 5-218(4), or alternatively in I.C. § 5-224. Only I.C. § 5-224 remains in issue since § 5-218(4) deals with the fraud claim which was disposed of by an unappealed directed verdict.”
Harris v. State Ex Rel. Kempthorne, 210 P.3d 86 (Idaho 2009). “Idaho Code § 5-224 precludes the Harrises from recovering.”
McCuskey v. Canyon Cnty. Commissioners, 912 P.2d 100 (Idaho 1996). “The County contends that MeCuskey and Bell’s action is time barred by I.C. § 5-224. We agree and affirm the district court’s order granting summary judgment in favor of Canyon County.”
Wadsworth v. Dep't of Transp., 915 P.2d 1 (Idaho 1996). “The district court granted summary judgment to the Department, finding that there was no genuine issue of material fact and that the Department was entitled to judgment as a matter of law.”
DOE(s) v. Boy Scouts of Am., 356 P.3d 1049 (Idaho 2015). “The District Court identified three potential candidates: Idaho Code section 5-218(4), which governs fraud claims; Idaho Code section 5-219(4), which governs personal injury claims; and Idaho Code section 5-224, which is a catch-all statute of limitations.”
Myers v. City of Pocatello, 559 P.2d 1136 (Idaho 1977). “Considering the foregoing elements of malicious prosecution, it is clear that this complaint does not fully set them forth. The complaint fails to allege that the defendant(s) acted with malice, which appellants contend can be inferred from the language of the complaint.”
Graham Cnty. Soil & Water Conservation Dist. v. United States Ex Rel. Wilson, 545 U.S. 409 (2005). “2004) (retaliation action for whistle-blowers); Idaho Code §§ 5-224 , 6-2105(2) (Lexis 1998) (catchall; retaliation action for whistle-blowers); Ill.”
Taylor v. AIA Servs. Corp., 261 P.3d 829 (Idaho 2011). “Idaho Code § 5-237 requires "actions against directors or stockholders of a corporation to recover a penalty or forfeiture, or to enforce a liability by law" to be brought within three years "after the discovery by the aggrieved party of the facts upon which the penalty or…”
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