Morris v. Hap Taylor & Sons, Inc., 301 P.3d 639

Morris suffered a serious head injury working for Hap Taylor & Sons, Inc. on Oct 18, 2006.
He filed a workers’ compensation claim in 2007 seeking medical and disability benefits.
In Jan 2010, the parties executed and the Commission approved a partial lump sum settlement (LSSA) for indemnity only; medical benefits reserved.
Morris later moved to set aside the LSSA, arguing illegality and fraud; the Commission denied the motion in Feb 2012.
Morris appealed to the Idaho Supreme Court, which affirms the Commission’s denial and denies attorney fees on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the LSSA void for failing to show Morris’ current medical and employment status?	Morris contends JR.P. 18(C)(1)(c) requires explicit status.	Liberty argues status was supplied and strict text adherence isn’t required.	LSSA not illegal or void; status information adequately supplied.
Did the Commission err in denying a hearing on Morris’ fraud claim?	Fraud by Morris’ attorney could affect finality and warrant a hearing.	Fraud by attorney is not the basis for reopening; finality rests on fraud by the employer’s surety.	No error; fraud by attorney did not affect finality; no hearing required.
Is Morris entitled to attorney fees on appeal under I.C. § 72-804?	Fees should be awarded due to misrepresentations by Liberty to the Commission.	Respondents had reasonable grounds; no award of fees on appeal.	Not entitled to fees; prevailing party not shown to have acted unreasonably.

Wernecke v. St. Maries School Dist., 147 Idaho 277 (2009) (discusses illegality and setting aside of awards under I.C. § 72-332)
Harmon v. Lute’s Const. Co., Inc., 112 Idaho 291 (1986) (only fraud by employer’s surety may justify setting aside an approved lump sum)
Danti v. Danti, 146 Idaho 929 (2009) (counsel’s negligence generally not ground to set aside a judgment)
Ketchem v. Ketchem, 11 S.E.2d 788 (1940) (Georgia Supreme Court expansion of fraud claim remedies)