Idaho Code
Idaho Code § 9-402 (2026)
Historical works — Books of science or art — Published maps or charts — Effect as evidence.
✓ current as of May 2026
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Historical works — Books of science or art — Published maps or charts — Effect as evidence.
Historical works, books of science or art, and published maps or charts, when made by persons indifferent between the parties, are prima facie evidence of facts of general notoriety and interest.
Notes of Decisions
Cited in 15
cases, 1954–2016 · leading case: Randy Hoffer v. Scott A. Shappard, D.O., 380 P.3d 681 (Idaho 2016).
Randy Hoffer v. Scott A. Shappard, D.O., 380 P.3d 681 (Idaho 2016). “” I.C. § 9-402. Assuming, without deciding, that the article contained “evidence of facts of general notoriety and interest,” the statute is of no force or effect to the extent that it conflicts with the rule.”
State v. Crabb, 688 P.2d 1203 (Idaho Ct. App. 1984). “This is true also of the graphs developed when the state’s witness ran his tests on the seized substances.”
State v. Alger, 764 P.2d 119 (Idaho Ct. App. 1988). “The Committee observed that the application of Rule 803(18) could be extended to situations in which a learned treatise was sought to be introduced into evidence, but no expert witness was called to testify concerning the same issues discussed in the treatise.”
J.K. Merrill & Son, Inc. v. Carter, 702 P.2d 787 (Idaho 1985). “We are cognizant that there is a split of authority pertaining to the function of the signature requirement under the UCC § 9-402. 5 Courts and commentators have construed the signature requirement for a financing statement as serving dual functions: notice and authentication.”
Tucker v. Union Oil Co. of California, 603 P.2d 156 (Idaho 1979). “A second theory for admissibility was that the article represented authoritative research on ammonia handling safety measures.”
Hite v. Kulhenak Bldg. Contractor, 524 P.2d 531 (Idaho 1974). “The award of the Industrial Commission should be reversed and remanded with directions to enter findings of fact, conclusions of law and an award based on the unrefuted testimony of appellant's expert witness. BAKES, Justice (dissenting): I don't view with as much alarm as…”
McKay Constr. Co. v. Ada Cnty. Bd. of Cnty. Commissioners, 538 P.2d 1185 (Idaho 1975). “We hold those rulings of the trial court to be erroneous. Although the treatises were clearly hearsay, nevertheless they should have been admitted under an exception to the hearsay rule for learned treatises.”
Cayne v. Washington Trust Bank, 125 F. Supp. 3d 1128 (D. Idaho 2015). “Washington Trust also seeks refuge in § 9-402, which provides that the "existence of a security interest, agricultural lien, or authority given to a debtor to dispose of or use collateral, without more, does not subject a secured party to liability in contract or tort for the…”
Sutton Ex Rel. Sutton v. Brown's Tie & Lumber Co., 361 P.2d 793 (Idaho 1961). “See generally, I.C. § 9-402; 6 Wigmore, Evidence (3d ed.”
Tr. Servs. Corp. v. East River Lumber Co. (In Re Hodge Forest Indus., Inc.), 59 B.R. 801 (Bankr. D. Idaho 1986). “Georgia 1985), the court held that [w]here is it [sic] clear that all parties to an agreement intend for the transfer of collateral to be subject to a security interest that security interest remains in effect, and no new financing statement is required pursuant to [UCC §…”
Julien v. Barker, 272 P.2d 718 (Idaho 1954). “It bears the same liability for damages to users of this product that manufacturers generally bear for negligence, in the preparation of a product offered to the public, or in failure to warn against danger involved in the use of the product.”
Simplot v. William C. Owens, Md, Pa, 805 P.2d 477 (Idaho Ct. App. 1990). “§ 9-402 Official Comment 2. We think the purpose was served here.”
— Idaho Code § 9-402(1) — 2 cases
J.K. Merrill & Son, Inc. v. Carter, 702 P.2d 787 (Idaho 1985). “We are cognizant that there is a split of authority pertaining to the function of the signature requirement under the UCC § 9-402. 5 Courts and commentators have construed the signature requirement for a financing statement as serving dual functions: notice and authentication.”
Matter of Keefer, 26 B.R. 597 (Bankr. D. Idaho 1983).
— Idaho Code § 9-402(7) — 2 cases
Tr. Servs. Corp. v. East River Lumber Co. (In Re Hodge Forest Indus., Inc.), 59 B.R. 801 (Bankr. D. Idaho 1986). “Georgia 1985), the court held that [w]here is it [sic] clear that all parties to an agreement intend for the transfer of collateral to be subject to a security interest that security interest remains in effect, and no new financing statement is required pursuant to [UCC §…”
Newgen v. Ok Livestock Exch., 788 P.2d 846 (Idaho Ct. App. 1990).
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