Idaho Code
Idaho Code § 61-625 (2026)
Orders not subject to collateral attack.
✓ current as of May 2026
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Orders not subject to collateral attack.
All orders and decisions of the commission which have become final and conclusive shall not be attacked collaterally.
Notes of Decisions
Cited in 6
cases, 1976–2020 · leading case: Idaho Power Co. v. Idaho Pub. Utils. Comm'n, 639 P.2d 442 (Idaho 1981).
Idaho Power Co. v. Idaho Pub. Utils. Comm'n, 639 P.2d 442 (Idaho 1981). “15121 adopting the Intervenor Funding Rules was a final and conclusive order under I.C. § 61-625 and thus binding upon those utilities receiving notice and failing to appeal or file for rehearing; (2) whether Congress had the power under the Commerce and Supremacy Clauses to…”
Empire Lumber Co. v. Washington Water Power Co., 755 P.2d 1229 (Idaho 1988). “To unilaterally change rates that are charged for sales or rates that are paid for purchases is to wage a collateral attack on final Commission Orders in the manner prohibited by Idaho Code § 61-625 . ... . For Water Power to continue to assert or infer that it is not bound to…”
Utah-Idaho Sugar Co. v. Intermountain Gas Co., 597 P.2d 1058 (Idaho 1979). “§ 61-307 was an impermissible collateral attack on a Commission order barred by I.C. § 61-625; 5 that Intermountain properly interpreted the provisions of Schedule LV-1 to bar U & I credit for the monthly demand charge component of Schedule LV-1 toward actual gas used; that the…”
Rosebud Enter., Inc. v. Idaho Pub. Utils. Comm'n, 951 P.2d 521 (Idaho 1997). “Rosebud asserts that IPUC’s refusal to require Idaho Power to purchase power from the qualified facility at the 1994 rates constitutes a collateral attack on the validity of the IPUC orders approving the 1994 rates in violation of section 61-625 of the Idaho Code. We disagree.”
Associated Pac. Movers, Housemovers, Inc. v. Rowley, 551 P.2d 618 (Idaho 1976). “On appeal, the appellants challenge the award of the housemoving permit on the ground that Rowley’s second application and the hearing thereon amounted to a collateral attack on the first order of denial and thereby violated I.C. § 61-625, which provides: “All orders and…”
Franklin Energy Storage One, LLC v. Kjellander (D. Idaho 2020). “Idaho Power relies upon Idaho Code § 61-625 , which states that “[a]ll orders and decisions of the commission which have become final and conclusive shall not be attacked collaterally,” and on case law identifying a public policy interest in finality.”
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