Davis v. Hammack Management, Inc.
161 Idaho 791
| Idaho | 2017Background
- Gary Davis (Claimant) sustained a 2004 workplace injury; after multiple surgeries parties agreed he was totally and permanently disabled as of October 1, 2013 (MMI date).
- Claimant, Employer, Surety, and ISIF executed a Commission‑approved Stipulation providing total & permanent benefits (250 weeks from MMI) but granting Employer a 160‑week/$46,992 credit for previously paid permanent physical impairment (PPI) and related payments.
- After this Court’s decision in Corgatelli (holding no statutory basis for PPI credits), Claimant sought a declaratory ruling that the PPI credit in the Stipulation was void; Employer refused to remove the credit and would cease payments after 90 weeks per the Stipulation.
- Claimant petitioned the Industrial Commission under its Judicial Rules of Practice for a declaratory ruling; the Commission found it had jurisdiction but declined to invalidate the PPI credit; Claimant appealed to the Idaho Supreme Court.
- The Supreme Court (majority) held the Commission had jurisdiction to decide the declaratory petition but concluded the PPI credit and the Commission’s approval of the Stipulation were void because the Commission lacked statutory authority to approve such a credit; court reversed the Commission’s approval and awarded costs to Claimant but denied attorney fees.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Commission jurisdiction to hear declaratory petition | Commission may decide rights under a previously approved stipulation (Williams) | ISIF: Commission lacks enumerated statutory power to entertain such petitions; JRP 15 doesn’t create jurisdiction | Court: Commission had jurisdiction to decide the petition (affirmed) |
| Validity of PPI credit in Commission‑approved Stipulation | PPI credit is void under Corgatelli; Commission lacked authority to approve it | Employer/ISIF: Stipulation was approved and final; Claimant cannot collaterally attack it | Court: PPI credit invalid; Commission’s approval void for exceeding statutory authority (reversed) |
| Whether the approval is subject to collateral attack/finality doctrines | Void orders for lack of statutory authority can be attacked anytime | ISIF: approval became final and cannot be reopened; Claimant should have used post‑award remedies | Court: Where Commission acted beyond statutory power, its order is void and subject to collateral attack (Claimant may proceed) |
| Attorney fees on appeal | Claimant sought fees | Defendants opposed | Court: No attorney fees awarded because matter involved an issue of first impression |
Key Cases Cited
- Corgatelli v. Steel West, Inc., 167 Idaho 287, 336 P.3d 1160 (Idaho 2014) (no statutory basis for employer credit for previously paid PPI)
- Wernecke v. St. Maries Joint Sch. Dist. No. 401, 147 Idaho 277, 207 P.3d 1008 (Idaho 2009) (Commission approval without statutorily required findings can be void / limits on compromising future claims)
- Williams v. Blue Cross of Idaho, 151 Idaho 515, 260 P.3d 1186 (Idaho 2011) (Commission has jurisdiction to decide declaratory petitions clarifying rights under approved settlements)
- Emery v. J.B. Simplot Co., 141 Idaho 407, 111 P.3d 92 (Idaho 2005) (stipulation resolving a specific past claim is not an unlawful waiver of compensation under I.C. § 72‑318(2))
- Vawter v. United Panel Serv., Inc., 155 Idaho 903, 318 P.3d 893 (Idaho 2014) (standard of review for Industrial Commission decisions)