Idaho Top Court Finds ‘Unknowns’ about COVID Exposure Nix Widow’s Claim

Case File

When a worker contracted and died from COVID, too many questions about where he was exposed to the virus kept his widow from obtaining benefits. Look for Idaho compliance info Simply Research.

Case

Estate of Weeks v. Oneida County, No. 52031 (Idaho 11/14/25)

What Happened?

An equipment operator with an Idaho county's road and bridge department generally began each workday in a five-to-15-minute meeting in the office break room, which was approximately 18 feet by 30 feet and where crew members sat around a table and received their work assignments for the day.

As COVID-19 transmission levels heightened in the county during the pandemic, employees were allowed to use masks but generally chose not to. The morning meetings continued as usual.

One of the operator's coworkers developed COVID symptoms, and although he did not get tested, remained out of work until his symptoms resolved. The day after the coworker returned to work, the operator began experiencing COVID symptoms but continued working for the next two days.

After testing positive for COVID, the worker did not return to work, and later died from COVID complications.

Following the operator's death, his widow filed a workers' compensation claim for medical and death benefits, which the employer denied. The case went to a hearing, with the Workers' Compensation Commission denying the widow's claim. The commission determined that the widow failed to prove by a preponderance of the evidence that the worker had contracted COVID at work.

The commission concluded that, due to many unknowns regarding the operator's whereabouts during the relevant time period, no direct proof established that the operator actually "incurred" COVID-19 from his employment.

The widow appealed to the Idaho Supreme Court.

Rule of Law

Under Idaho law, an occupational disease is one that arises from "the nature of employment" and is characteristic of and peculiar to the trade, occupation, process or employment. However, as explained in Jobe v. Dirne Clinic/Heritage Health, 408 P.3d 63 (Idaho 2017), an employer is not liable for an occupational disease unless the disease is actually incurred in the employer's employment.

What the Idaho Supreme Court Said

The Idaho Supreme Court found that the commission relied on "substantial and competent evidence" to conclude that the widow failed to prove that the operator actually incurred COVID-19 from his employment.

According to the court, the commission's reliance on a medical expert who placed a possible date of COVID transmission to the operator earlier than what the widow's expert contended reflected a finding that the operator had contact with others outside of work from whom he could have contracted the virus.

For example, the operator shopped

"The record reflects that the decedent did sometimes work with his uncle or a neighbor on [a] ranch ... but is silent on whether he did in fact with either of them during the relevant time period," the court wrote. "Thus, the record ... supports the Commission's conclusion regarding this 'unknown.'"

The court further explained that the widow was required to provide medical testimony demonstrating that, even if the operator had contacts with others outside of work, more likely than not he still contracted COVID-19 from work and not those other contacts.

"No such medical testimony was provided here," the court wrote, and so the commission did not err in concluding that the widow failed to prove that the operator incurred COVID-19 in his employment.

Verdict: The Idaho Supreme Court affirmed the commission's decision denying the widow's workers' compensation claim for medical and death benefits pertaining to the operator's COVID-19 illness.

Takeaway

In Idaho, there is no "balance tipping standard" in favor of compensability in occupational disease cases.

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