STATE COURT COMPLAINT TEMPLATE – BREACH OF CONTRACT

Idaho District Court
[// GUIDANCE: This template is drafted for use in any Idaho state district court. Confirm county-specific local rules before filing.]

TABLE OF CONTENTS

1. Caption
2. Preliminary Statement
3. Parties
4. Jurisdiction and Venue
5. General Allegations (Factual Background)
6. First Cause of Action – Breach of Contract
7. Damages
8. Conditions Precedent
9. Demand for Jury Trial (Optional)
10. Prayer for Relief
11. Reservation of Rights
12. Verification
13. Certificate of Service

1. CAPTION

IN THE DISTRICT COURT OF THE [___] JUDICIAL DISTRICT
OF THE STATE OF IDAHO, IN AND FOR THE COUNTY OF [COUNTY]

[PLAINTIFF LEGAL NAME],
a [State] [entity type/individual],
Plaintiff,

v.

[DEFENDANT LEGAL NAME],
a [State] [entity type/individual],
Defendant.

Case No. ______

COMPLAINT FOR BREACH OF CONTRACT

(DEMAND FOR JURY TRIAL) [// GUIDANCE: Delete if no jury demand.]

2. PRELIMINARY STATEMENT

1. Plaintiff brings this civil action for breach of contract arising out of Defendant’s failure to perform under that certain [title of agreement] dated [Contract Date] (the “Agreement”).
2. Plaintiff seeks monetary damages, prejudgment interest, costs, attorney fees pursuant to Idaho Code § 12-120(3), and such other relief as the Court deems just and proper.
   [// GUIDANCE: Idaho Code § 12-120(3) authorizes attorney fees in commercial contract actions where the amount pleaded exceeds $35,000.]

3. PARTIES

3.1 Plaintiff. [PLAINTIFF LEGAL NAME] (“Plaintiff”) is a [corporation/LLC/individual] organized and existing under the laws of [State] with its principal place of business at [Address].

3.2 Defendant. [DEFENDANT LEGAL NAME] (“Defendant”) is a [corporation/LLC/individual] organized and existing under the laws of [State] with its principal place of business at [Address].
[// GUIDANCE: If asserting diversity for any reason, include citizenship allegations. For Idaho entities, allege principal place of business and state of organization.]

4. JURISDICTION AND VENUE

4.1 Subject-Matter Jurisdiction. This Court has subject-matter jurisdiction under Idaho Const. art. V, § 20 and Idaho Code § 1-705 because the amount in controversy exceeds $10,000 and this is an action at law.

4.2 Personal Jurisdiction. Defendant is subject to personal jurisdiction in Idaho because it [is domiciled in Idaho / transacts business in Idaho / entered into and breached the Agreement in Idaho / agreed in the Agreement to Idaho jurisdiction].

4.3 Venue. Venue is proper in this County under Idaho Code § 5-404 because [cause of action arose here / Defendant resides here / contract was to be performed here].

4.4 Service of Process. Plaintiff will effect service pursuant to Idaho R. Civ. P. 4(d).
[// GUIDANCE: Insert chosen service method—personal, certified mail, publication, etc.—and attach Process Server’s Affidavit after service.]

5. GENERAL ALLEGATIONS (FACTUAL BACKGROUND)

5.1 On or about [Contract Date], Plaintiff and Defendant entered into the Agreement, a true and correct copy of which is attached as Exhibit A.

5.2 Under the Agreement, Defendant was obligated to [describe performance obligations: e.g., “deliver 5,000 units of Product within 30 days”].

5.3 Plaintiff fully performed its contractual obligations, including but not limited to [describe Plaintiff’s performance].

5.4 Beginning on or about [Date], Defendant failed to [describe breach—e.g., “make the required payments”].

5.5 Plaintiff provided Defendant with written notice of default on [Date] in accordance with Section [__] of the Agreement and Idaho R. Civ. P. 8(a)(2).

5.6 Despite demand, Defendant has not cured its breach and remains in default.

6. FIRST CAUSE OF ACTION – BREACH OF CONTRACT

6.1 Plaintiff realleges and incorporates by reference ¶¶ 1 – 5.6.

6.2 Existence of Contract. A valid and enforceable contract exists between Plaintiff and Defendant (Ex. A).

6.3 Breach. Defendant materially breached the Agreement by [specific acts/omissions].

6.4 Damages. As a direct and proximate result of Defendant’s breach, Plaintiff has suffered damages in an amount to be proven at trial but not less than $[___], plus prejudgment interest under Idaho Code § 28-22-104.

6.5 Attorney Fees. Pursuant to Idaho Code § 12-120(3) and Section [__] of the Agreement, Plaintiff is entitled to recover reasonable attorney fees and costs incurred herein.

7. DAMAGES

Plaintiff seeks:
a. Compensatory damages of $[___];
b. Pre- and post-judgment interest at the statutory rate;
c. Attorney fees and costs per statute and contract;
d. Any other relief the Court deems just and equitable.
[// GUIDANCE: Insert any claim for consequential, expectancy, or liquidated damages if authorized by contract.]

8. CONDITIONS PRECEDENT

All conditions precedent to Defendant’s performance have occurred, been performed, or have been waived.

9. DEMAND FOR JURY TRIAL (OPTIONAL)

Plaintiff demands a trial by jury on all issues so triable pursuant to Idaho R. Civ. P. 38(b).
[// GUIDANCE: If contract contains an enforceable jury waiver, delete this section and add “Plaintiff acknowledges the contractual jury waiver contained in Section [__] of the Agreement.”]

10. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that judgment be entered in its favor and against Defendant as follows:

1. Compensatory damages in an amount to be determined at trial, but not less than $[___];
2. Pre- and post-judgment interest under Idaho Code § 28-22-104;
3. Reasonable attorney fees and costs pursuant to Idaho Code § 12-120(3) and the Agreement;
4. Such other and further relief as the Court deems just and proper.

11. RESERVATION OF RIGHTS

Plaintiff reserves the right to amend this Complaint pursuant to Idaho R. Civ. P. 15(a) as justice may require and to seek all additional relief supported by the evidence.

12. VERIFICATION

I, [Name of Authorized Representative or Individual Plaintiff], declare under penalty of perjury pursuant to Idaho Code § 9-1406 that I am the [title] of Plaintiff, that I have read the foregoing Complaint, and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.

Date: _ ____
[Name], [Title]

[// GUIDANCE: Idaho permits unsworn verification under § 9-1406. If notarization is preferred, replace with jurat.]

13. CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the ___ day of [Month], 20__, I served a true and correct copy of the foregoing Complaint on the following by:
☐ U.S. Mail ☐ Certified Mail ☐ Overnight Delivery ☐ Email ☐ iCourt E-File & Serve

• [Defense Counsel Name], Esq.
[Law Firm]
[Address]
[Email]

[Attorney Name], Attorney for Plaintiff
Bar No. [_]
[Law Firm]
[Address]
Telephone: [--]
Email: [_]

[// GUIDANCE: Idaho Rule of Civil Procedure 5(b) governs service of pleadings after the original complaint. Confirm method consistency with local electronic filing rules.]

DISCOVERY LIMITS NOTE

[// GUIDANCE: Under Idaho R. Civ. P. 26(b), the presumptive limits (absent stipulation or court order) include 30 interrogatories per party, 10 depositions per side, and the 7-hour rule per deposition. Adjust your discovery strategy accordingly and consider requesting modifications early via stipulation or motion.]

FINAL DRAFTING CHECKLIST

[// GUIDANCE: Remove this section before filing.]
☐ All placeholders completed
☐ Exhibits labeled and attached (e.g., Contract = Ex. A)
☐ Jurisdictional allegations double-checked
☐ Prayer totals verified
☐ Service method selected and compliant with Rule 4
☐ Attorney signature block conforms to Idaho R. Civ. P. 11(a)

End of Template