Idaho Code

Idaho Code § 5-245 (2026)

Actions to collect child support arrearages.

✓ current as of May 2026

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Actions to collect child support arrearages.

An action or proceeding to collect child support arrearages, arising under an Idaho child support order, can be commenced at any time prior to the expiration of the resulting judgment or any renewal thereof. An action or proceeding under this section shall include, but is not limited to, execution on the judgment, order to show cause, garnishment, income withholding, income tax offset or lottery prize offset.

Notes of Decisions

Cited in 9 cases (2 in the last 5 years), 1998–2023 · leading case: Thomas v. Worthington, 979 P.2d 1183 (Idaho 1999).

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Thomas v. Worthington, 979 P.2d 1183 (Idaho 1999). · cites it 46× “On November 14,1997, Robert filed a Motion to Determine Judgment Unenforceable asserting that I.C. § 5-245 barred collection of the judgment because both children had reached the age of twenty-three.”

Stonecipher v. Stonecipher, 963 P.2d 1168 (Idaho 1998). · cites it 32× “On the day of the scheduled hearing, Dwight filed a motion asserting that any arrearages which had accrued more than five years prior to the date of Donna’s motion to show cause were barred by the statutes of limitation found in Idaho Code § 5-245 , 11-101 and 10-1111. Over…”

Debra Peterson v. Dept of H&W, 320 P.3d 1244 (Idaho 2014). · cites it 7× “I.C. §§ 5-245, 10-1110, 10-1111 (Supp.2013).”

Chandler's-Boise LLC v. Idaho State Tax Comm'n, 398 P.3d 180 (Idaho 2017). · cites it 12× “” I.C. § 5-245 (1988). A 1995 amendment to the statute added the following sentence: “An action or proceeding under this section shall include, but is not limited to, execution on the judgment, order to show cause, garnishment, income withholding, income tax offset or lottery…”

State, Dept. of Health & Welfare v. Housel, 90 P.3d 321 (Idaho 2004). · cites it 2× “I.C. § 5-245 (“Actions to collect child arrearages”); I.”

Collection Bureau, Inc. v. Dorsey, 249 P.3d 1150 (Idaho 2011). · cites it 4× “Idaho Code § 11-101 provides: Except as provided in section 5-245, Idaho Code, for execution on judgments for support of a child, the party in whose favor judgment is given may, at any time within five (5) years after the entry thereof, have a writ of execution issued for its…”

Smith v. Smith, 423 P.3d 998 (Idaho 2018). “However, in 2011, the Idaho Legislature passed Senate Bill 1103 which amended Idaho Code sections 5-245, 10-1110, 10-1111 and allowed, among other things, that child support judgments be renewable.”

Easterling v. Hal Pac. Props., L.P. (Idaho 2021). · cites it 2× “§ 5-219), and actions to recover child support (I.C. § 5-245). Yet, the Chapter does not include a statute of limitations for asserting an easement to real property.”

Easterling v. Hal Pac. Props., L.P. (Idaho 2023). · cites it 2× “§ 5-219), and actions to recover child support (I.C. § 5-245). Yet, the Chapter does not include a statute of limitations for asserting an easement to real property.”

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