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?