This state requires employees to report injuries to their employers within 60 days to qualify for workers’ compensation benefits. Did this employee fulfill the law’s reporting requirement?
Scott Chadwick filed a complaint with the Idaho Industrial Commission seeking workers’ comp benefits from his employer, Multi-State Electric LLC. Chadwick claims he suffered back injuries at work on May 29, 2012 and July 26, 2012.
He visited various medical providers until he finally had an MRI on Oct. 8, 2012, which showed he had osteoarthritic changes in his lumbar spine and a disc protrusion.
The Commission found Chadwick didn’t provide timely notice to Multi-State of both claimed injuries, therefore he was denied workers’ comp benefits. Chadwick appealed, and the Idaho Supreme Court recently heard his case.
Idaho law says an employee has to notify his employer of a workplace injury “not later than 60 days after,” to qualify for comp. The court found there was no evidence that Chadwick gave written notice within the required time period.
Chadwick argued he’d given the required notice because, within 60 days, Multi-State knew he had sought medical care for his back pain. The Commission ruled Multi-State’s “knowledge that Claimant’s back hurt or that he received treatment for back pain is insufficient to meet the notice requirement.” The Idaho Supreme Court agreed:
“Knowledge of the injury requires notice that the physical condition was caused by an accident arising out of and in the course of the claimant’s employment. Thus, a claimant who complained of pain was not entitled to benefits where there was no evidence that the employer had actual knowledge of a work-related injury within the statutory time for giving notice.”
Chadwick argued Multi-State should have investigated to find out if his back pain was from work. No dice, said the court. Idaho law doesn’t require that.
So the court upheld the Commission’s denial of benefits to Chadwick.
There are all sorts of good reasons for employees to report workplace injuries to you as soon as they realize they’ve suffered one: make sure someone else doesn’t suffer a similar injury, ensure the employee’s initial injury doesn’t get worse, etc.
Idaho isn’t the only state that requires employees to give sufficient notice to their employers to be eligible to collect workers’ comp benefits. That’s just one more reason for workers to report their injuries sooner rather than later.
(Scott M. Chadwick v. Multi-State Electric LLC, Supreme Court of the State of Idaho, No. 42473-2014, 11/25/15)