Idaho Top Court Rules that Employers Can’t Initiate Workers’ Comp Claims

Case File

According to the Idaho Supreme Court, the state's Workers' Compensation Law did not authorize an employer to file a complaint for compensation or income benefits with the commission. Simply Research subscribers have access to the full text of the decision.

Case

Coronado v. City of Boise, No. 51722 (Idaho 11/14/25)

What Happened?

A police officer for an Idaho city suffered an industrial accident on the job. The city accepted the officer's claim for a right hip injury and initiated voluntary compensation. However, one year later, the city declined to authorize compensation for medical treatment of the officer's left hip, and the officer refused the city's requests for access to her medical records and to schedule an independent medical examination.

The city, acting through its third-party administrator, sent the officer a letter stating that it was temporarily suspending the officer's compensation payments.

After the letter was sent, the Idaho Supreme Court held in Arreola v. Scentsy, Inc., 531 P.3d 1148 (Idaho 2023), that only the commission had the authority to: 1) resolve IME disputes; and 2) order the suspension of a claimant's compensation benefits. The officer filed a petition for a declaratory ruling to determine whether Arreola applied retroactively.

With the officer's petition pending, the city filed a complaint against her, requesting the commission to adjudicate various issues concerning the officer's entitlement to benefits and her failure to submit to IMEs.

The officer filed a second petition, asking the commission to determine whether the city could file an application requestion a hearing to litigate a worker's right to compensation.

The commission found the first petition procedurally improper and denied the second petition on the merits.

The officer appealed to Idaho's Supreme Court, arguing that the Workers' Compensation Law did not permit an employer to file a complaint to litigate a worker's right to compensation.

Rule of Law

A commission's order or award can be set aside if the commission acts without jurisdiction or in excess of its power. Per Fuentes v. Cavco Indus. Inc., 511 P.3d 852 (Idaho 2022), the commission exceeds its powers if it misapplies its judicial rules.

What the Idaho Supreme Court Said

The Idaho Supreme Court agreed with the officer that the WCL did not allow an employer to make and file with the commission an application requesting a hearing. In the court's view, the commission exceeded its powers by authorizing the city to file a complaint against an injured worker.

The court acknowledged that the commission was empowered to determine all questions arising under the WCL and that it possessed exclusive jurisdiction to determine all actions that involved issues relating to a worker's injury.

However, these provisions did "not confer on an employer an unfettered right to move for a hearing" because:

(1) The legislature enacted the WCL to provide "sure and certain relief for injured" workers, and consistent with that purpose, the WCL created certain core remedies for employees alone. "This means the workers' compensation claim belongs to the employee," the court wrote.

(2) If employers could unilaterally initiate an employee's claim by filing a complaint, they would usurp control over employees' compensatory rights under the WCL. "In a world of employer-initiated complaints, relief under the WCL would be neither sure nor certain for the very people it was designed to serve," the court wrote.

(3) The WCL defined both compensation and income benefits as remedies exclusively available to employees.

Workers' Comp 101: In Idaho, "compensation" includes "any or all of the income benefits and the medical and related benefits and medical services." "Income benefits" are "payments provided for or made ... to the injured employee disabled by an injury or occupational disease."

The Idaho Supreme Court held that the commission was not authorized to entertain an employer's making or filing of an application for a hearing to adjudicate an employee's claims to unpaid or discontinued compensation benefits or discontinued income benefits as only employees are allowed to so move.

Verdict: The Idaho Supreme Court set aside the commission's order denying the officer's second petition because the commission acted in excess of its power.

Takeaway

In Idaho, when the subject matter of a hearing concerns compensatory rights, only an employee may file a complaint to request a hearing before the commission.

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