Idaho’s Supreme Court ruled that only employees – not employers or insurers – can initiate workers’ compensation benefit disputes before the state commission, clarifying procedural authority.
The dispute began after Sherri Sue Coronado, a Boise police officer, was injured during a traffic stop in 2019. The City of Boise, which self-insures, accepted her claim for a right hip injury and paid both medical expenses and her full salary, as required for peace officers injured on duty. Later, Coronado reported pain in her left hip. Her physician initially stated this new issue was unrelated to the workplace injury, but later revised his opinion, attributing the left hip problem to the original incident.
The City’s claims examiner, citing conflicting medical opinions, declined to authorize compensation for the left hip and requested an independent medical examination (IME). Coronado and her attorney objected to the scheduling and coordination of the IME. After Coronado did not attend the scheduled exam, the claims examiner notified her that her benefits would be suspended under Idaho Code section 72-434, which allows for suspension if an employee unreasonably fails to submit to an IME. However, the Industrial Commission later found that no actual suspension of benefits occurred and Coronado continued to receive her salary.
After a 2023 Idaho Supreme Court decision (Arreola v. Scentsy, Inc.) clarified that only the Commission – not employers – can order suspension of benefits in IME disputes, Coronado filed a petition seeking a declaratory ruling on whether that decision applied retroactively to her situation. While that petition was pending, the City of Boise filed its own complaint with the Commission, seeking a determination on Coronado’s entitlement to benefits and her failure to attend IMEs. Coronado objected, arguing that under Idaho’s Worker’s Compensation Law, only employees – not employers – may file such complaints regarding compensation or income benefits.
The Commission denied Coronado’s petitions, holding that it had jurisdiction to adjudicate an employer’s complaint. Coronado appealed, and the case reached the Idaho Supreme Court.
On November 14, 2025, the Idaho Supreme Court affirmed the Commission’s denial of Coronado’s first petition, finding that the controversy over the alleged suspension of benefits was moot, since Coronado never actually lost her benefits or access to the dispute-resolution process. However, the Court set aside the Commission’s order denying Coronado’s second petition. The justices held that, under Idaho Code section 72-706, only employees may file an application requesting a hearing before the Commission when the claim concerns unpaid or discontinued compensation or income benefits. The Court reasoned that allowing employers to initiate such complaints would undermine the purpose of the Worker’s Compensation Law, which is to provide “sure and certain relief” to injured workers.
The Court’s decision clarifies that while the Commission has broad authority to resolve disputes under the Worker’s Compensation Law, the procedural right to initiate claims for compensation or income benefits belongs exclusively to employees. Employers may not file complaints to adjudicate these specific rights, though they may still participate in other types of proceedings before the Commission as permitted by law.
For insurance professionals and self-insured employers in Idaho, the decision underscores the importance of following the correct procedural channels and reinforces the employee’s primary role in initiating compensation disputes.
