Justia Idaho Supreme Court Opinion Summaries

An employee of a drywall supply company suffered a right ankle injury while carrying drywall sheets up a stairway in October 2019. The employer and its workers’ compensation insurer initially accepted the injury as compensable, providing medical care and temporary disability benefits. After an independent medical examination in January 2021 concluded the employee had reached maximum medical improvement, the insurer discontinued benefits. The employee continued to experience pain and pursued additional treatment, including surgery and further imaging, which ultimately revealed a recurrent tendon tear in the same ankle. Delays in authorizing necessary diagnostic procedures led to an 18-month gap before the recurrent tear was properly identified.Following the denial of benefits for additional treatment, the employee filed a workers’ compensation complaint with the Idaho Industrial Commission. The Commission held a bifurcated hearing addressing causation and entitlement to further medical care and temporary disability benefits. The Commission adopted its Referee’s findings, concluding that the employee had not proven by a preponderance of the evidence that the recurrent tendon tear was caused by the original workplace accident. The Commission reasoned that the recurrent tear was a new injury, not an aggravation of the original compensable injury, and denied the claim for continued benefits. The Commission also denied the employee’s motion for reconsideration, rejecting arguments regarding procedural due process and misapplication of the compensable consequences doctrine as explained in Sharp v. Thomas Brothers Plumbing.On appeal, the Supreme Court of the State of Idaho reversed the Commission’s decision. The Court held that the Commission erred by failing to apply the compensable consequences doctrine correctly to determine causation between the initial compensable injury and the subsequent recurrent tendon tear. The Court found that there was a demonstrable causal connection and that the Commission had improperly required the claimant to negate all other possible causes. The case was remanded for further proceedings, and the employee was awarded attorney fees and costs on appeal. View "Miklos v. L&W Supply" on Justia Law

The claimant suffered a workplace injury while lifting a box, resulting in immediate neck and shoulder pain. She promptly sought medical treatment and was diagnosed with a shoulder strain, receiving temporary disability benefits and performing light duty work. Over time, her symptoms persisted and evolved, leading to various medical evaluations, including imaging studies and independent medical exams. Disagreement arose between medical providers regarding the nature and cause of her cervical spine abnormalities, with one provider opining that a herniated disc at C6-7 was caused by the accident and recommending surgery, while others attributed her symptoms to mild degenerative changes not caused by the workplace incident.After exhausting benefits and undergoing surgical procedures outside of the worker’s compensation system, the claimant filed a complaint with the Idaho Industrial Commission seeking additional medical and disability benefits, asserting that her cervical condition was work-related. Following a hearing, the Commission weighed conflicting medical expert testimony and found some inconsistencies and possible exaggeration in the claimant’s symptom reporting. Ultimately, the Commission determined that the claimant had proven a shoulder injury from the accident but failed to establish, to a reasonable degree of medical probability, that her herniated disc or cervical spine condition was caused by the workplace event.The Supreme Court of the State of Idaho reviewed the Commission’s decision. Applying the standard that factual findings by the Commission will not be disturbed unless clearly erroneous, and that legal conclusions are subject to free review, the Court found substantial and competent evidence supporting the Commission’s denial of additional benefits for the cervical spine condition. The Court affirmed the Commission’s decision and held that neither party was entitled to attorney fees on appeal. View "Proulx v. Saveway Market, Inc." on Justia Law

A police officer employed by a city suffered injuries during a traffic stop in May 2019. The city, acting as a self-insured employer through a third-party administrator, initially accepted liability for a right hip injury, providing compensation and full salary. Subsequently, the officer developed left hip symptoms, and medical opinions varied on whether these were related to the workplace accident. The employer questioned the connection, declined to authorize further treatment for the left hip, and requested access to medical records and an independent medical examination (IME). After the officer did not cooperate with these requests, the employer sent a letter stating that compensation benefits would be suspended, although the Idaho Industrial Commission later found that no actual suspension occurred.The officer later filed a petition with the Idaho Industrial Commission seeking a declaratory ruling on whether a recent Idaho Supreme Court decision (Arreola v. Scentsy, Inc.) applied retroactively to her situation, which would have affected the employer’s ability to suspend benefits unilaterally. While this petition was pending, the employer filed a complaint with the Commission to resolve disputes about the officer’s entitlement to benefits and failure to attend IMEs. The officer responded with a second petition, challenging the employer’s ability to file such a complaint. The Commission declined to address the first petition on procedural grounds and denied the second on the merits, concluding that it had jurisdiction to adjudicate an employer’s complaint.On appeal, the Supreme Court of the State of Idaho affirmed the Commission’s denial of the first petition, finding the issue moot because the officer’s benefits had not been suspended and thus there was no live controversy. However, the Court set aside the denial of the second petition, holding that under Idaho’s worker’s compensation law, only employees—not employers—may file a complaint (application for hearing) with the Commission to adjudicate claims regarding unpaid or discontinued compensation or income benefits. View "Coronado v. City of Boise" on Justia Law

After a 22-year-old man was killed in a car accident caused by a drunk driver, his parents, who were no longer together, each filed separate wrongful death lawsuits. The mother and father’s cases were consolidated and settled before trial, but they could not agree on how to divide the settlement proceeds. The law firm holding the funds initiated an interpleader action to have the court determine the appropriate division. The parents had a complicated history, including periods of estrangement, custody disputes, and issues related to drug use and financial support.The District Court of the Fourth Judicial District, Ada County, held an evidentiary hearing and ultimately awarded 75% of the net settlement proceeds to the mother and 25% to the father. The court based its decision on findings that the father had failed to fulfill his parental and legal obligations, including not paying child support, misusing disability payments intended for the child, and engaging in illegal drug use with his son. The court found that the mother had provided more consistent emotional and financial support. The father appealed, arguing that he was entitled to half of the proceeds and that the court erred by considering his past conduct rather than the proper legal standard for wrongful death damages.The Supreme Court of the State of Idaho reviewed the case and held that the district court erred by not applying the correct legal standard. The Supreme Court clarified that wrongful death damages are forward-looking and intended to compensate for the loss of future support, companionship, and other benefits the decedent would have provided. The court found that the district court improperly based its apportionment on the parents’ past conduct rather than their respective losses. The Supreme Court reversed the district court’s decision, vacated the judgment, and remanded the case for further proceedings consistent with its opinion. View "Rossman Law Group, PLLC v. Holcomb and Carraway" on Justia Law

William Weeks was employed as an equipment operator for Oneida County’s Road and Bridge Department in Idaho. In September 2021, during a period of high COVID-19 transmission, Mr. Weeks continued working as required for critical infrastructure employees. He attended daily morning meetings with coworkers in a break room and often visited local stores. After a coworker became ill and missed work, Mr. Weeks developed COVID-19 symptoms, tested positive, and later died from complications. His wife, JaLyn Weeks, filed a worker’s compensation claim, alleging he contracted COVID-19 at work.The employer denied the claim, and Mrs. Weeks brought her case before the Idaho Industrial Commission. At the hearing, both parties presented expert testimony regarding the likely source and timing of Mr. Weeks’ infection. The Commission found the employer’s expert more persuasive, concluding that it was not possible to determine, by a preponderance of the evidence, that Mr. Weeks contracted COVID-19 at work rather than from other possible sources, such as visits to stores or contact with individuals outside of work. The Commission denied the claim for medical and death benefits.On appeal, the Supreme Court of the State of Idaho reviewed whether the Commission applied the correct legal standard and whether its findings were supported by substantial and competent evidence. The Court held that the Commission properly applied the preponderance of the evidence standard and did not err by refusing to resolve doubts in favor of compensability in occupational disease cases. The Court affirmed the Commission’s decision, holding that Mrs. Weeks failed to prove that Mr. Weeks actually incurred COVID-19 from his employment. The Court did not reach the issue of whether COVID-19 is a compensable occupational disease under Idaho law. View "Weeks v. Oneida County" on Justia Law

An employee suffered a severe hand injury, including the amputation of a finger, while operating a table saw without a safety guard at work. After receiving some worker’s compensation benefits, the employee filed a civil tort action against the employer, alleging that the employer’s requirement to use the saw without a guard constituted “willful or unprovoked physical aggression,” which, under Idaho law, would allow a lawsuit outside the worker’s compensation system. The employer did not respond to the lawsuit, and the employee obtained a default judgment for damages.Several months later, the employer moved to set aside the default judgment, arguing that the district court lacked subject matter jurisdiction because the employee’s worker’s compensation claim had been filed first. The District Court of the Fourth Judicial District agreed, stayed enforcement of the default judgment, and directed the parties to seek a determination from the Idaho Industrial Commission on whether the “willful or unprovoked physical aggression” exception applied. The Commission concluded that the exception did not apply, and the district court then set aside the default judgment and dismissed the civil action.On appeal, the Supreme Court of the State of Idaho held that the district court erred by deferring to the Commission on the applicability of the statutory exception and by setting aside the default judgment. The Supreme Court clarified that district courts have concurrent subject matter jurisdiction to determine whether the exception to the exclusive remedy rule applies, even if a worker’s compensation claim was filed first, unless the Commission has already decided the issue. The Supreme Court reversed the district court’s decision, vacated the Commission’s findings, and remanded with instructions to reenter the default judgment in favor of the employee. View "Tyler v. Masterpiece Floors, Inc." on Justia Law

A meat cutter with a long career suffered multiple work-related injuries over the years, including injuries to his back, shoulder, knee, and wrist, but was able to return to full-time, heavy-duty work after each incident. In 2015, he experienced a severe workplace accident in which his dominant right hand was caught in a meat grinder, resulting in the loss of most of his hand and significant impairment. Despite extensive medical treatment, including surgeries and a spinal cord stimulator, he was left with chronic pain and severe functional limitations. He was ultimately found to be totally and permanently disabled and unable to work.After settling with his employer, the claimant sought additional workers’ compensation benefits from the State of Idaho’s Industrial Special Indemnity Fund (ISIF), arguing that his pre-existing impairments, particularly a left wrist injury, combined with the 2015 accident to cause his total disability. The Idaho Industrial Commission held a hearing, considered expert testimony, and found that while the claimant had several pre-existing impairments, only the left wrist injury was a subjective hindrance to employment. However, the Commission concluded that the 2015 meat grinder accident alone rendered him totally and permanently disabled, as his prior injuries had not prevented him from working full-time before that event. The Commission adopted the findings of its appointed Referee and denied ISIF liability.The Supreme Court of the State of Idaho reviewed the case, applying a standard that defers to the Commission’s factual findings if supported by substantial and competent evidence. The Court held that the Commission’s determination was supported by the record, particularly the expert testimony that the 2015 accident, by itself, caused the claimant’s total and permanent disability. The Court affirmed the Commission’s order, holding that ISIF was not liable for any portion of the claimant’s disability. Costs on appeal were awarded to ISIF. View "Westman v. Industrial Special Indemnity Fund" on Justia Law

Elanore Vaughan purchased a ticket and signed an online liability waiver to go tubing at Eagle Island State Park, operated by Gateway Parks, LLC. The next day, Vaughan was injured when her tube went over an embankment and crashed into a flatbed trailer housing snowmaking equipment. Vaughan sued Gateway, alleging negligence and premises liability, claiming Gateway failed to maintain the tubing hill safely and created a hazard by placing the trailer at the end of the tubing run.The District Court of the Fourth Judicial District of Idaho denied Gateway's motion to dismiss Vaughan's complaint. Gateway argued that Vaughan's claims were barred by the liability waiver she signed and the Responsibilities and Liabilities of Skiers and Ski Area Operators Act. The district court found that while the Act applied, there was a genuine issue of material fact regarding the placement of the snowmaking equipment. The court also concluded that the liability waiver did not preclude Vaughan's claims. Gateway then sought and was granted permission to appeal the denial of its motion for summary judgment.The Supreme Court of the State of Idaho reviewed the case and reversed the district court's decision. The court held that the electronic liability waiver Vaughan signed precluded her claims against Gateway. The waiver explicitly acknowledged the risks of tubing, including collisions with manmade obstacles such as snowmaking equipment. The court determined that the waiver's language was broad enough to encompass Vaughan's accident and injuries. Consequently, the court directed the district court to grant summary judgment in favor of Gateway and dismiss Vaughan's complaint. The court also denied Gateway's request for attorney fees on appeal, as the gravamen of Vaughan's lawsuit was a tort, not a commercial transaction. View "Vaughan v. Gateway Park, LLC" on Justia Law

Laura Milus, on behalf of herself and her minor son, D.L.J., filed a wrongful death action against Sun Valley Company after her husband died from colliding with snowmaking equipment while skiing at Sun Valley Ski Resort. Milus claimed that Sun Valley breached its duties under Idaho Code section 6-1103(2) and (6) by not properly marking the equipment and failing to post a notice about snowmaking operations.The District Court of the Fifth Judicial District of Idaho granted summary judgment in favor of Sun Valley, concluding that the company met its duty under section 6-1103(2) by placing yellow padding on the equipment and had no duty under section 6-1103(6) because the equipment was not actively discharging snow. The court did not address Sun Valley's argument that Milus' claims were barred by section 6-1106, which states that skiers assume the risk of injury from plainly visible or marked snowmaking equipment.The Supreme Court of Idaho reviewed the case and held that ski area operators are held to an ordinarily prudent person standard of care when performing duties under the Ski Area Liability Act. The court found that Milus failed to create a genuine issue of material fact regarding whether Sun Valley met this standard with the yellow padding. However, the court also held that there was a genuine issue of material fact about whether Sun Valley posted the required notice under section 6-1103(6).Despite this, the court affirmed the district court's decision, concluding that Milus' claims were barred by section 6-1106 because Mr. Milus assumed the risk of injury from the plainly marked snowmaking equipment. The court denied Sun Valley's request for attorney fees on appeal, as both parties prevailed on some arguments. View "Milus v. Sun Valley Company" on Justia Law

The plaintiffs, Kandi Terry-Smith and Roy A. Smith, Jr., filed a complaint against Mountain View Hospital (MVH) and Idaho Falls Community Hospital (IFCH) alleging medical malpractice after Kandi suffered an injury while a patient at MVH. The complaint was filed on March 11, 2022, and a second, identical complaint was filed on September 8, 2022. The first case was dismissed for inactivity, but the district court granted an extension for service of process. The process server, Tony Mares, filed an affidavit claiming he served MVH, but deficiencies were later found.In the district court, MVH moved to dismiss the second case as time-barred and the first case for insufficient service of process. The district court denied the Smiths' motion to consolidate the cases and dismissed the second case. The district court granted MVH’s motion to dismiss the first case for insufficient service of process, finding that the Smiths failed to properly serve MVH. The Smiths' subsequent motions for reconsideration, to amend the complaint, and for additional extensions were denied. The district court also denied the Smiths' I.R.C.P. 60(b) motion for relief from the order denying reconsideration and judgment.The Idaho Court of Appeals reviewed the case and affirmed the district court’s judgment. The court held that the Smiths failed to show good cause for the failure to timely serve MVH and did not exercise due diligence. The court also found no excusable neglect and determined that the Smiths' attorney's reliance on the process server’s affidavit was unreasonable. The court denied MVH’s request for attorney fees in the district court due to the lack of a cross-appeal but granted attorney fees and costs on appeal, finding the Smiths' appeal frivolous and without foundation. View "Smith v. Mountain View Hospital, LLC" on Justia Law