Idaho Code
Idaho Code § 7-913 (2026)
Modification or correction of award.
✓ current as of May 2026
Find cases:
SyfertCases citing this section
IClegislature.idaho.gov
Justiaon Justia
CornellLII Search
CasesGoogle Scholar
Modification or correction of award.
(a) Upon application made within ninety (90) days after delivery of a copy of the award to the applicant, the court shall modify or correct the award where:
(1) There was an evident miscalculation of figures or an evident mistake in the description of any person, thing or property referred to in the award;
(2) The arbitrators have awarded upon a matter not submitted to them and the award may be corrected without affecting the merits of the decision upon the issues submitted; or
(3) The award is imperfect in a matter of form, not affecting the merits of the controversy.
(b) If the application is granted, the court shall modify and correct the award so as to effect its intent and shall confirm the award as so modified and corrected. Otherwise, the court shall confirm the award as made.
(c) An application to modify or correct an award may be joined in the alternative with an application to vacate the award.
Notes of Decisions
Cited in 17
cases (1 in the last 5 years), 1980–2024 · leading case: Schilling v. Allstate Ins., 980 P.2d 1014 (Idaho 1999).
Schilling v. Allstate Ins., 980 P.2d 1014 (Idaho 1999). “There was no "evident miscalculation of figures" by the arbitrators, no award by the arbitrators "upon a matter not submitted to them," nor was the *1021 award "imperfect in a matter of form," the three grounds specified in Idaho Code § 7-913 that permit a court to modify an…”
Landmark v. Mader Agency, Inc., 878 P.2d 773 (Idaho 1994). “[1] Rather, the district court remanded the award to the arbitrator for modification or correction under I.C. § 7-913. Although I.C. § 7-909 empowers the court to remand an award, that section only allows for modification or correction "upon the grounds stated in paragraphs (1)…”
Cranney v. Mut. of Enumclaw Ins., 175 P.3d 168 (Idaho 2007). “Because Idaho Code § 7-913 (a)(1) does not permit an arbitration award to be modified for a nonmathematical error in awarding prejudgment interest, we affirm the judgment of the district court.”
Barbee v. WMA Sec., Inc., 146 P.3d 657 (Idaho 2006). “§ 7-912 (vacating an award); I.C. § 7-913 (modifying an award). "An arbitrator's rulings on questions of law and fact are binding, even where erroneous, unless one of the enumerated statutory grounds is present.”
Moore v. Omnicare, Inc., 118 P.3d 141 (Idaho 2005). “Further, Moore argues the award should be modified pursuant to Idaho Code § 7-913 to treble the award. Upon application made within 90 days a court shall modify or correct an arbitrator's award where there is an evident miscalculation of figures or a mistake in the description…”
Am. & Foreign Ins. Co. v. Reichert, 94 P.3d 699 (Idaho 2004). “DID THE ARBITRATOR LACK JURISDICTION TO MODIFY OR CORRECT THE FEBRUARY 16, 2001 DECISION AND INTERIM AWARD? American requested the arbitrator to modify or correct the interim award, specifically the prejudgment interest, due to an evident miscalculation of figures, under I.”
Cedillo v. Farmers Ins. Co of Idaho, 345 P.3d 213 (Idaho 2015). ““The evident miscalculation of figures under Idaho Code § 7-913 (a)(l) must be a mathematical error in calculating the amount of an award, not a legal error in the elements or measure of damages when making the award.”
Driver v. SI CORP., 80 P.3d 1024 (Idaho 2003). “Idaho Code section 7-913 is materially the same. The 90-day time limitation under I.”
Loomis, Inc. v. Cudahy, 656 P.2d 1359 (Idaho 1982). “§ 7-912, Vacating an award; I.C. § 7-913, Modification or corrections of award; I.”
Pac. Alaska Seafoods, Inc. v. Vic Hoskins Trucking, Inc., 80 P.3d 1073 (Idaho 2003). “On June 27, 2002, VHT filed an appeal with this Court, claiming the arbitrator 1) exceeded his authority under Idaho Code § 7-912 when he awarded damages to Pacific instead of VHT, and 2) under Idaho Code § 7-913 , miscalculated the damage award to Pacific.”
Deelstra v. Hagler, 188 P.3d 864 (Idaho 2008). “According to Deelstra, the court’s award of attorney fees modified the arbitration award in a manner that is not permissible under I.C. § 7-913. He contends that any such modification was improper because Hagler filed no motion to modify, vacate or correct the award as required…”
State v. Philip Morris, R.J. Reynolds, 354 P.3d 187 (Idaho 2015). “” Under Idaho Code section 7-913, "the court shall modify or correct the award where .”
— Idaho Code § 7-913(1) — 2 cases
Driver v. SI CORP., 80 P.3d 1024 (Idaho 2003). “Idaho Code section 7-913 is materially the same. The 90-day time limitation under I.”
Pac. Alaska Seafoods, Inc. v. Vic Hoskins Trucking, Inc., 80 P.3d 1073 (Idaho 2003). “On June 27, 2002, VHT filed an appeal with this Court, claiming the arbitrator 1) exceeded his authority under Idaho Code § 7-912 when he awarded damages to Pacific instead of VHT, and 2) under Idaho Code § 7-913 , miscalculated the damage award to Pacific.”
— Idaho Code § 7-913(2) — 2 cases
Barbee v. WMA Sec., Inc., 146 P.3d 657 (Idaho 2006). “§ 7-912 (vacating an award); I.C. § 7-913 (modifying an award). "An arbitrator's rulings on questions of law and fact are binding, even where erroneous, unless one of the enumerated statutory grounds is present.”
Schilling v. Allstate Ins., 980 P.2d 1014 (Idaho 1999). “There was no "evident miscalculation of figures" by the arbitrators, no award by the arbitrators "upon a matter not submitted to them," nor was the *1021 award "imperfect in a matter of form," the three grounds specified in Idaho Code § 7-913 that permit a court to modify an…”
— Idaho Code § 7-913(2004) — 1 case
Moore v. Omnicare, Inc., 118 P.3d 141 (Idaho 2005). “Further, Moore argues the award should be modified pursuant to Idaho Code § 7-913 to treble the award. Upon application made within 90 days a court shall modify or correct an arbitrator's award where there is an evident miscalculation of figures or a mistake in the description…”
— Idaho Code § 7-913(3) — 1 case
Schilling v. Allstate Ins., 980 P.2d 1014 (Idaho 1999). “There was no "evident miscalculation of figures" by the arbitrators, no award by the arbitrators "upon a matter not submitted to them," nor was the *1021 award "imperfect in a matter of form," the three grounds specified in Idaho Code § 7-913 that permit a court to modify an…”
— Idaho Code § 7-913(a) — 2 cases
Landmark v. Mader Agency, Inc., 878 P.2d 773 (Idaho 1994). “[1] Rather, the district court remanded the award to the arbitrator for modification or correction under I.C. § 7-913. Although I.C. § 7-909 empowers the court to remand an award, that section only allows for modification or correction "upon the grounds stated in paragraphs (1)…”
Cedillo v. Farmers Ins. Co of Idaho, 345 P.3d 213 (Idaho 2015). ““The evident miscalculation of figures under Idaho Code § 7-913 (a)(l) must be a mathematical error in calculating the amount of an award, not a legal error in the elements or measure of damages when making the award.”
— Idaho Code § 7-913(a)(1) — 4 cases
Schilling v. Allstate Ins., 980 P.2d 1014 (Idaho 1999). “There was no "evident miscalculation of figures" by the arbitrators, no award by the arbitrators "upon a matter not submitted to them," nor was the *1021 award "imperfect in a matter of form," the three grounds specified in Idaho Code § 7-913 that permit a court to modify an…”
Landmark v. Mader Agency, Inc., 878 P.2d 773 (Idaho 1994). “[1] Rather, the district court remanded the award to the arbitrator for modification or correction under I.C. § 7-913. Although I.C. § 7-909 empowers the court to remand an award, that section only allows for modification or correction "upon the grounds stated in paragraphs (1)…”
Cranney v. Mut. of Enumclaw Ins., 175 P.3d 168 (Idaho 2007). “Because Idaho Code § 7-913 (a)(1) does not permit an arbitration award to be modified for a nonmathematical error in awarding prejudgment interest, we affirm the judgment of the district court.”
Am. & Foreign Ins. Co. v. Reichert, 94 P.3d 699 (Idaho 2004). “DID THE ARBITRATOR LACK JURISDICTION TO MODIFY OR CORRECT THE FEBRUARY 16, 2001 DECISION AND INTERIM AWARD? American requested the arbitrator to modify or correct the interim award, specifically the prejudgment interest, due to an evident miscalculation of figures, under I.”
— Idaho Code § 7-913(a)(2) — 2 cases
Norton v. California Ins. Guarantee Ass'n, 155 P.3d 1161 (Idaho 2007).
Perryman Constr. Mgmt. Inc. v. Doeppel Premier Props. Idaho, LLC (Idaho Ct. App. 2024).
— Idaho Code § 7-913(a)(3) — 1 case
Landmark v. Mader Agency, Inc., 878 P.2d 773 (Idaho 1994). “[1] Rather, the district court remanded the award to the arbitrator for modification or correction under I.C. § 7-913. Although I.C. § 7-909 empowers the court to remand an award, that section only allows for modification or correction "upon the grounds stated in paragraphs (1)…”
— Idaho Code § 7-913(a)(i) — 1 case
Cedillo v. Farmers Ins. Co of Idaho, 345 P.3d 213 (Idaho 2015). ““The evident miscalculation of figures under Idaho Code § 7-913 (a)(l) must be a mathematical error in calculating the amount of an award, not a legal error in the elements or measure of damages when making the award.”
— Idaho Code § 7-913(a)(l) — 5 cases
Am. & Foreign Ins. Co. v. Reichert, 94 P.3d 699 (Idaho 2004). “DID THE ARBITRATOR LACK JURISDICTION TO MODIFY OR CORRECT THE FEBRUARY 16, 2001 DECISION AND INTERIM AWARD? American requested the arbitrator to modify or correct the interim award, specifically the prejudgment interest, due to an evident miscalculation of figures, under I.”
Landmark v. Mader Agency, Inc., 878 P.2d 773 (Idaho 1994). “[1] Rather, the district court remanded the award to the arbitrator for modification or correction under I.C. § 7-913. Although I.C. § 7-909 empowers the court to remand an award, that section only allows for modification or correction "upon the grounds stated in paragraphs (1)…”
Cranney v. Mut. of Enumclaw Ins., 175 P.3d 168 (Idaho 2007). “Because Idaho Code § 7-913 (a)(1) does not permit an arbitration award to be modified for a nonmathematical error in awarding prejudgment interest, we affirm the judgment of the district court.”
Schilling v. Allstate Ins., 980 P.2d 1014 (Idaho 1999). “There was no "evident miscalculation of figures" by the arbitrators, no award by the arbitrators "upon a matter not submitted to them," nor was the *1021 award "imperfect in a matter of form," the three grounds specified in Idaho Code § 7-913 that permit a court to modify an…”
Pac. Alaska Seafoods, Inc. v. Vic Hoskins Trucking, Inc., 80 P.3d 1073 (Idaho 2003). “On June 27, 2002, VHT filed an appeal with this Court, claiming the arbitrator 1) exceeded his authority under Idaho Code § 7-912 when he awarded damages to Pacific instead of VHT, and 2) under Idaho Code § 7-913 , miscalculated the damage award to Pacific.”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.