Davis v. Hammack Mgmt.

Claimant Gary Davis, employer Hammack Management, Inc., surety the Idaho State Insurance Fund, and the Idaho Industrial Special Indemnity Fund (“ISIF”) entered into a compensation agreement (“Stipulation”). The parties agreed that Claimant became totally and permanently disabled based on the combined effects of preexisting impairments and a workplace injury that occurred in 2004. The Stipulation outlined each party’s financial obligations to Claimant, including a credit to Employer for permanent partial impairment benefits previously paid. The Idaho Industrial Commission (“Commission”) approved the Stipulation. Subsequently, the Idaho Supreme Court issued its decision in “Corgatelli v. Steel West, Inc.,” (335 P.3d 1150 (2014)), prohibiting such a credit. Claimant then sought a declaratory ruling that the credit in the Stipulation was void. The Commission issued an order stating that the Stipulation was binding as written and subsequently denied Claimant’s motion for reconsideration. Claimant appealed. The Supreme Court concluded the credit in the Stipulation was invalid and the Commission’s order approving the Stipulation was void. The Court affirmed the Industrial Commission’s holding that it had subject matter jurisdiction over the Claimant’s petition for declaratory ruling but reversed its order upholding the Stipulation and the credit. View "Davis v. Hammack Mgmt." on Justia Law