In Chavez v. Stokes, 2015 Opinion No. 64 (July 7, 2015), the Idaho Supreme Court overturned prior precedent holding that the reasonableness of medical treatment in workers’ compensation cases is a question of law subject to free review. According to the Court, the Idaho Industrial Commission’s determination of reasonableness should be reviewed as a finding of fact under the substantial and competent evidence standard.

Chavez concerns an injured worker who was transported to a hospital by Life Flight. After the worker received a bill for the cost, he filed a complaint for workers’ compensation with the Commission. The employer disputed whether the Life Flight transport was reasonable under Idaho Code § 72-432(1) and whether he was responsible for the cost.
Continue Reading Is the Reasonableness of Medical Treatment in Workers’ Compensation Cases a Question of Law or a Question of Fact for the Purposes of Appellate Review?

In State v. Andre Luis Franklin, five State Supreme Court justices reversed a defendant’s convictions after concluding the trial court erred in excluding evidence to further the defendant’s “other suspect” defense.  The defendant, Franklin, was in pseudo-relationships with two different women, Hibbler and Fuerte, and the women had a history of jealousy with one another.  Soon after Franklin loaned some money to Fuerte, Fuerte began receiving emails from an unknown email address threatening to post compromising pictures of her online.  These emails were purportedly from Franklin.
Continue Reading State v. Franklin – State Supreme Court Divided Over Discretion