In Chavez v. Stokes, 2015 Opinion No. 64 (July 7, 2015), the Idaho Supreme Court overturned prior precedent holding that the reasonableness of medical treatment in workers’ compensation cases is a question of law subject to free review. According to the Court, the Idaho Industrial Commission’s determination of reasonableness should be reviewed as a finding of fact under the substantial and competent evidence standard.

Chavez concerns an injured worker who was transported to a hospital by Life Flight. After the worker received a bill for the cost, he filed a complaint for workers’ compensation with the Commission. The employer disputed whether the Life Flight transport was reasonable under Idaho Code § 72-432(1) and whether he was responsible for the cost.

The leading case addressing those issues is Sprague v. Caldwell Transportation, Inc., 116 Idaho 720, 779 P.2d 395 (1989). In Sprague, the Court identified three factors to determine the reasonableness of the claimant’s treatment. The Court also held that the Commission’s determination of reasonableness was a legal conclusion subject to de novo review. Since Sprague, the Court has used the three factors as the exclusive method to determine reasonableness.

Chavez overturns Sprague in two fundamental ways. First, the Court clarified that the three factors examined in Sprague do not establish the only means to determine the reasonableness of medical treatment under Section 72-432(1). Second, the Court held that the Commission’s determination of reasonableness should be reviewed as a finding of fact under the substantial and competent evidence standard, not as a question of law subject to free review.