Idaho Code

Idaho Code § 55-918 (2026)

Extinguishment of a cause of action.

✓ current as of May 2026

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Extinguishment of a cause of action.

A cause of action with respect to a transfer or obligation under this act is extinguished unless action is brought:

(1) Under section 55-913(1)(a), Idaho Code, not later than four (4) years after the transfer was made or the obligation was incurred or, if later, not later than one (1) year after the transfer or obligation was or could reasonably have been discovered by the claimant;

(2) Under section 55-913(1)(b) or 55-914(1), Idaho Code, not later than four (4) years after the transfer was made or the obligation was incurred; or

(3) Under section 55-914(2), Idaho Code, not later than one (1) year after the transfer was made or the obligation was incurred.

Notes of Decisions

Cited in 9 cases (2 in the last 5 years), 1996–2024 · leading case: Hillen v. City of Many Trees (In re CVAH, Inc.), 570 B.R. 816 (Bankr. D. Idaho 2017).

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Hillen v. City of Many Trees (In re CVAH, Inc.), 570 B.R. 816 (Bankr. D. Idaho 2017). · cites it 7× “Compare Idaho Code § 55-918 with § 548(a)(1). Here, in something of a new foray, Trustee seeks to enlarge the available look-back period for avoidable transfers to six, and even ten years, by utilizing the provisions of the FDCPA and the IRC, respectively.”

Zazzali Ex Rel. DBSI, Inc. v. Mott (In Re DBSI, Inc.), 445 B.R. 344 (Bankr. D. Del. 2011). · cites it 2× “Idaho Code § 55-918 ; see In re Hodge, 220 B.”

Zazzali v. Mott (In Re DBSI, Inc.), 447 B.R. 243 (Bankr. D. Del. 2011). · cites it 2× “Idaho Code § 55-918 ; see In re Hodge, 220 B.”

Fitzgerald v. Magic Valley Evangelical Free Church, Inc. (In Re Hodge), 200 B.R. 884 (Bankr. D. Idaho 1996). · cites it 2× “See Idaho Code § 55-918 (2). Specifically, Plaintiff seeks to apply Idaho Code §§ 55-913 , 55-914, the state law analog of Section 548(a)(2).”

Zazzali v. United States (In Re DBSI, Inc.), 869 F.3d 1004 (9th Cir. 2017). “Idaho Code Ann. § 55-918 . Accordingly, pursuant to Section 548, Zazzali sought to recover transfers in the amount of approximately $56,000 that were made in the two years prior to the bankruptcy petition date.”

Finn v. All. Bank, 838 N.W.2d 585 (Minn. Ct. App. 2013). “§ 651C-9 (1993); Idaho Code Ann. § 55-918 (2007); 740 Ill.”

Zazzali v. Goldsmith (In re DBSI Inc.), 593 B.R. 795 (Bankr. D. Idaho 2018). · cites it 2× “See Idaho Code § 55-918 (1) (providing that causes of action under Idaho Code § 55-913 (1)(a) are extinguished unless action is brought within 4 years); see generally *818 Decker v.”

Geile v. Wickersham (Bankr. D. Idaho 2023). · cites it 2× “I.C. § 55-918. A prerequisite to both I.C.”

Mitchell v. Kruckenberg (Bankr. D. Or. 2024). “49 Idaho Code § 55-918 (a) (2023); Or. Rev. Stat.”

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