Idaho Code

Idaho Code § 6-2101 (2026)

Legislative intent. 

✓ current as of May 2026
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Legislative intent. 

The legislature hereby finds, determines and declares that government constitutes a large proportion of the Idaho work force and that it is beneficial to the citizens of this state to protect the integrity of government by providing a legal cause of action for public employees who experience adverse action from their employer as a result of reporting waste and violations of a law, rule or regulation.

Notes of Decisions
Cited in 25 cases (5 in the last 5 years), 2002–2026 · leading case: Berrett v. Clark Cnty. Sch. Dist., 454 P.3d 555 (Idaho 2019).
Berrett v. Clark Cnty. Sch. Dist., 454 P.3d 555 (Idaho 2019). · cites it 8× “] I.C. § 6-2101. She argues that in order to give effect to this intent, there must be a cause of action for the wrongful termination of the spouse of a whistleblower or else employers will be able to indirectly force an employee to forego the protected activity.”
Summers v. City of McCall, 84 F. Supp. 3d 1126 (D. Idaho 2015). · cites it 12× “Wrongful Termination in violation of Idaho Code § 6-2101 re: investigation of the Valley County Sheriff’s Office 2.”
Curlee v. Kootenai Cnty. Fire & Rescue, 224 P.3d 458 (Idaho 2008). · cites it 4× “ANALYSIS Curlee claims that she was discharged in violation of the Idaho Protection of Public Employees Act, I.C. § 6-2101 et seq. (the Act), which is commonly referred to as a “whistleblower act.”
Eller v. Idaho State Police, 443 P.3d 161 (Idaho 2019). · cites it 4× “" I.C. § 6-2101. The time limit for bringing a whistleblower claim is much shorter than provided in the ITCA.”
Mallonee v. State, 84 P.3d 551 (Idaho 2004). · cites it 6× “Idaho Code § 6-2101 et seq. is commonly referred to as the whistle-blower statute, which seeks to “protect the integrity of government by providing a legal cause of action for public employees who experience adverse action from their employer as a result of reporting waste and…”
Richard T. Wright v. Ada Cnty., 376 P.3d 58 (Idaho 2016). · cites it 4× “Idaho’s Whistleblower Act, which was enacted in 1994, seeks to “protect the integrity of government by providing a legal cause of action for - public employees who experience adverse action from their employer as a result of reporting waste and violations of a *496 law, rule or…”
Van v. Portneuf Med. Ctr., 212 P.3d 982 (Idaho 2009). · cites it 2× “I.C. §§ 6-2101 to 2109. In count two Van alleged breach of his employment contract and of the implied covenant of good faith and fair dealing.”
Van v. Portneuf Med. Ctr., Inc., 330 P.3d 1054 (Idaho 2014). · cites it 3× “PMC asserts that its decision to terminate Van was due to his inability to maintain positive interpersonal relations with his colleagues and to foster a positive team environment. In response, Van filed this lawsuit and alleged in count one that he had been wrongfully terminated…”
Patterson v. State, Dep't of Health & Welfare, 256 P.3d 718 (Idaho 2011). · cites it 2× “, and the Idaho Protection of Public Employees Act (IP-PEA), I.C. § 6-2101 et seq. Appellant, Lynette Pattei’son, argues that she was constructively discharged from her position as the Program Supervisor of the Fraud Unit at the Idaho Department of Health and Welfare (IDHW) due…”
Wholey v. Roebuck, 803 A.2d 482 (Md. 2002). “)(whistleblowing by state employees); Idaho Code § 6-2101 (1997)(whistleblowing by public employees protected); Ind.”
Cryer v. Idaho Dep't of Labor, 332 F. Supp. 3d 1260 (D. Idaho 2018). · cites it 3× “Cryer alleges that he was fired in violation of the Idaho Protection of Public Employees Act ("IPPEA"), Idaho Code §§ 6-2101 et seq. The IPPEA "protect[s] the integrity of government by providing a legal cause of action for public employees who experience adverse action from…”
Jeffry Black v. Idaho State Police, 314 P.3d 625 (Idaho 2013). · cites it 2× “” I.C. § 6-2101; Van v. Portneuf Med. Ctr., 147 Idaho 552, 557 , 212 P.”
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