Debra Peterson v. Dept of H&W, 320 P.3d 1244

1985 divorce decree required child support; custody amended in 1998 shifting support obligations; last child emancipated April 2002.
Prior to 2011, Idaho law (1995 amendment) barred renewal of child-support judgments; statutes limited collection actions to five years after emancipation.
In 2011 the legislature amended I.C. §§ 10-1110 and 10-1111 to allow renewal of child-support judgments and extended lien/enforcement periods; Senate Bill No. 1103 included a section 5 declaring retroactivity to July 1, 1995 and permitting renewal of judgments that "would otherwise have expired" to be renewed by Dec. 30, 2011.
The Department of Health & Welfare moved in Aug. 2011 to renew Ms. Peterson’s child-support judgment for $7,125.01 under the 2011 law; Ms. Peterson moved to dismiss/for summary judgment arguing the motion was time-barred and that revival would impair vested rights.
The magistrate granted renewal; the district court reversed, treating section 5 as nonbinding legislative history because it was compiled as an Idaho Code annotation; the Department appealed to the Idaho Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §5 of SB1103 (retroactive/renewal effective date) is legally operative despite being compiled as an Idaho Code annotation	Peterson: §5 is merely legislative history/annotation and not law; cannot be used to revive expired claims	DHW: §5 is part of the enacted bill and is legally effective despite placement as an annotation in the Code	Reversed district court: §5 is part of the enacted statute and operative; Code compilation placement does not nullify enacted law
Whether the child-support judgment could be renewed despite prior limitations/vested-rights arguments	Peterson: statute of limitations/lien expiration (five years after emancipation) ran in April 2007; vested-rights doctrine prevents retroactive revival	DHW: §5 independently authorizes renewal of judgments currently enforced by DHW and revives those that would have expired; no vested right in statute-of-limitations shelter	Court: renewal valid under §5; statutes of limitation are remedial and may be extended/relieved by legislation—no vested right impaired

State Dep’t of Health & Welfare v. Slane, 155 Idaho 274 (discussing standard of review for district court acting in appellate capacity)
Verska v. Saint Alphonsus Reg’l Med. Ctr., 151 Idaho 889 (statutory interpretation principle: give effect to all words)
Hecla Min. Co. v. Idaho State Tax Comm’n, 108 Idaho 147 (statute of limitations is remedial; lapse does not create vested immunity from suit)
Golconda Lead Mines v. Neill, 82 Idaho 96 (Idaho Code is a compilation/evidence of law, not itself the law)
Roark v. Crabtree, 893 P.2d 1058 (Utah case cited by Peterson for vested-rights view; cited and distinguished by Idaho Supreme Court)