Mazzone v. Texas Roadhouse, Inc.
154 Idaho 750
| Idaho | 2013Background
- Mazzone, a Texas Roadhouse employee, suffered a severe right-arm burn in 2005 from a fryer accident.
- Post-accident, he alleges nightmares, anxiety, and PTSD related to the incident.
- Mazzone received burn center treatment and later psychiatric evaluation; he had preexisting psychiatric history.
- Medical opinions were split: some doctors diagnosed PTSD; others found no PTSD or disputed its basis.
- Industrial Commission referee and then the full Commission ruled against compensation for a compensable psychological injury under IC §72-451; rehearing was denied and an appeal followed.
- The Idaho Supreme Court affirmed, holding the Commission’s decision supported by substantial evidence and that the referee erred in certain evidentiary handling, but the error was harmless, and attorney-fee requests were denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Commission's denial of compensation was supported by substantial evidence | Mazzone contends PTSD diagnosis and causation were supported | Respondents argue diagnosis lacked credible basis and predominant-cause standard not met | Yes; substantial evidence supports denial |
| Whether the referee relied on impermissible or unadmitted evidence | Mazzone asserts DSM-IV-TR and prescription history were misused | Respondents say DSM-IV-TR and history are permissible under IC procedures | Yes; referee erred in interpreting DSM-IV-TR and relying on prescription history |
| Whether the improper evidentiary handling affected outcome | Mazone claims reversible error from medical-diagnosis injection by referee | Respondents contend errors were harmless given conflicting expert opinions | Harmless error; record still supports the denial |
| Whether either party is entitled to attorney fees on appeal | Mazzone seeks fees as prevailing party | Respondents oppose fees under Rule 11.2 and §72-804 | Neither party entitled to appellate attorney fees |
Key Cases Cited
- Gibson v. Ada Cnty. Sheriff’s Office, 147 Idaho 491 (2009) (review of evidence and causation in mental-mental claims; standards for weighing evidence)
- Haldiman v. American Fine Foods, 117 Idaho 955 (1990) (liberal construction in worker-friendly statutes; weight of evidence rules)
- Wynn v. J.R. Simplot Co., 105 Idaho 102 (1983) (employer takes employee as found; preexisting conditions not fatal to claim)
- Dean v. Dravo Corp., 97 Idaho 158 (1975) (substantial evidence standard; findings binding if supported)
- Hagler v. Micron Tech., 118 Idaho 596 (1990) (relaxed evidence rules in IC proceedings; discretionary use of evidence)
- Pomerinke v. Excel Trucking Transp., Inc., 124 Idaho 301 (1993) (expert evidence admissibility and foundation; commission's role as finder of fact)
- Lay v. Idaho State Sch. & Colony, 64 Idaho 455 (1943) (duty to fully inquire; examiner’s role in evidence)
- Eacret v. Clearwater Forest Indus., 136 Idaho 733 (2002) (weight and credibility of expert testimony; standard of review)
- Zapata v. J.R. Simplot Co., 132 Idaho 513 (1999) (standard of review for Commission findings; substantial evidence)