Idaho Code
Idaho Code § 9-414 (2026)
Business records — When competent evidence.
✓ current as of May 2026
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Business records — When competent evidence.
A record of an act, condition or event, shall, insofar as relevant, be competent evidence if the custodian or other qualified witness testifies to the identity and the mode of its preparation, and if it was made in the regular course of business, at or near the time of the act, condition or event, and if, in the opinion of the court, the sources of information, method and time of preparation were such as to justify its admission.
Notes of Decisions
Cited in 16
cases, 1955–1997 · leading case: Curiel v. Mingo, 597 P.2d 26 (Idaho 1979).
Curiel v. Mingo, 597 P.2d 26 (Idaho 1979). “Appellant argues that Exhibit K did not qualify for admission into evidence under the Business Records as Evidence Act, I.C. § 9-414, and that Exhibit K, a photocopy reproduction of a writing, was not qualified under I.”
State v. McPhie, 662 P.2d 233 (Idaho 1983). “Even accepting the hearsay character of the price tag admitted in evidence, we hold nevertheless that the price tag falls within the business records exception to the hearsay rule as stated in I.C. § 9-414: "A record of an act, condition or event, shall, insofar as relevant, be…”
State v. White, 644 P.2d 318 (Idaho 1982). “The appellant argues that this reconstructed exhibit is hearsay and that the "regularly kept records" exception under I.C. § 9-414 [1] is the only exception that could possibly apply.”
Cheney v. Palos Verdes Inv. Corp., 665 P.2d 661 (Idaho 1983). “I.C. § 9-414 codifies the business record exception to the hearsay rule, stating: "A record of an act, condition or event, shall, insofar as relevant, be competent evidence if the custodian or other qualified witness testifies to the identity and the mode of its preparation, and…”
Herrick v. Leuzinger, 900 P.2d 201 (Idaho Ct. App. 1995). “Prior to adoption of the Idaho Rules of Evidence, admission of business records was governed by I.C. § 9-414, which is similar to I.R.E. 803(6).”
Beco Corp. v. Roberts & Sons Constr. Co., 760 P.2d 1120 (Idaho 1988). “Idaho Rule of Evidence 803(6) is consistent with former I.C. § 9-414 which prior cases had held must be broadly construed.”
Christensen v. Rice, 763 P.2d 302 (Idaho Ct. App. 1988). “The business record exception is in accord with I.C. § 9-414, the Uniform Business Record as Evidence Act, which was in effect prior to adoption of .”
Kelson v. Ahlborn, 393 P.2d 578 (Idaho 1964). “"A record of an act, condition or event, shall, insofar as relevant, be competent evidence if the custodian or other qualified witness testifies to the identity and the mode of its preparation, and if it was made in the regular course of business, at or near the time of the act,…”
Daniel v. Moss, 469 P.2d 50 (Idaho 1970). “I.C. § 9-414, § 2 of The Uniform Business Records as Evidence Act provides: “9-414.”
Galindo v. Hibbard, 678 P.2d 94 (Idaho Ct. App. 1984). “BELL, HANDBOOK OF EVIDENCE FOR THE IDAHO LAWYER 126 (2d ed. 1972).”
John Scowcroft & Sons Co. v. Roselle, 289 P.2d 621 (Idaho 1955). “This evidence was competent and proper under the provisions of Section 9-414,1.C., to lay the foundation for the admission of the records of respondent covering the transactions between Sum-mitt Supply Company and respondent.”
State v. Evans, 932 P.2d 881 (Idaho 1997). “In Cheney this Court applied I.C. § 9-414, which is consistent with I.”
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