Idaho's top court hands HR teams a clear warning on who controls workers' comp hearings
Idaho’s top court ruled only employees – not employers like the City of Boise – can initiate hearings over disputed workers’ comp benefits, reshaping HR practices.
On November 14, 2025, the Idaho Supreme Court issued its decision in a case involving Sherri Sue Coronado, a Boise police officer, and the City of Boise, her self-insured employer. The dispute began after Coronado was injured during a traffic stop in 2019, suffering a right hip injury. The City accepted her claim for that injury and began compensation, but later declined to authorize payment for treatment to her left hip, questioning whether it was related to the original workplace incident.
When Coronado did not respond to requests for medical records or to attend an independent medical examination, the City, through its third-party administrator, sent her a letter stating that her compensation payments would be temporarily suspended. The Idaho Industrial Commission later determined that Coronado’s benefits were not actually suspended.
The legal conflict escalated after the Idaho Supreme Court, in a separate case (Arreola v. Scentsy, Inc.), held that only the Commission – not employers – has the authority to resolve disputes over medical examinations and to order the suspension of compensation payments. Coronado then petitioned the Commission to determine whether this new precedent applied to her situation and whether the employer could file a complaint to litigate her right to compensation.
The Commission denied Coronado’s first petition, finding it was procedurally improper, and denied the second on the merits, holding that it had jurisdiction to adjudicate an employer’s complaint. Coronado appealed, arguing that the workers’ compensation law does not permit employers to file complaints seeking hearings on an employee’s entitlement to compensation.
The Idaho Supreme Court agreed with Coronado. The Court held that, under Idaho Code section 72-706, only employees may file an application requesting a hearing before the Commission when the subject is unpaid or discontinued compensation or income benefits. The Court set aside the Commission’s order that had allowed employer-initiated complaints, clarifying that the right to initiate these proceedings belongs exclusively to employees.
The outcome means that, in Idaho, employers and insurers cannot initiate formal hearings to challenge or resolve disputes over unpaid or discontinued workers’ compensation benefits. The process must be started by the employee. The decision requires HR teams and claims administrators to respect the employee’s procedural rights and adjust their claims management practices accordingly.
The decision is final on the procedural issue; it does not address the underlying facts of Coronado’s injury claim.
This decision clarifies the procedural landscape for workers’ compensation disputes in the state. It underscores the importance of understanding and following statutory procedures when managing workplace injury claims.
