The Idaho Supreme Court reversed the Idaho Industrial Commission's decision Monday in a workers' compensation case involving a drywall delivery worker who sustained an ankle injury on the job in 2019.
In *Christopher Miklos v. L&W Supply Corporation* (Idaho 2026), the court ruled in favor of Christopher Miklos, who had been denied benefits after his employer and insurer argued that his recurrent tendon tear was not related to his original workplace injury. The court remanded the case back to the Industrial Commission for further proceedings.
Miklos injured his right ankle on Oct. 28, 2019, while performing his duties as a drywall delivery employee for L&W Supply Corporation. The employer and its insurer, Indemnity Insurance Company of North America, initially accepted the injury as compensable and provided benefits for medical care and temporary disabilities.
The dispute arose following an independent medical examination conducted in January 2021, which concluded that Miklos had reached maximum medical improvement. Based on this assessment, the insurer discontinued benefits. Miklos contested the discontinuation, claiming he continued to experience ongoing pain and required additional medical treatment, including surgery.
A crucial development in the case occurred when subsequent imaging, which was delayed by nearly 18 months due to coverage denials and procedural disputes, revealed a recurrent tendon tear. This finding became central to the legal dispute between Miklos and the defendants.
The Industrial Commission had denied Miklos' claim after concluding that he failed to prove his recurrent tendon tear was caused by the 2019 industrial accident. However, the Idaho Supreme Court found that the Commission applied an incorrect legal standard in reaching its decision.
Justice Meyer authored the opinion for the court, which was filed Jan. 6, 2026, during the November 2024 term. The case was argued by Taylor L. Mossman-Fletcher of Mossman Law Office, LLP in Boise, representing Miklos, while Nathan T. Gamel of Gamel Law, PLLC in Garden City represented L&W Supply Corporation and Indemnity Insurance Company of North America.
The reversal highlights the complex nature of workers' compensation cases, particularly those involving delayed manifestations of workplace injuries. The nearly 18-month delay in obtaining proper imaging studies due to coverage disputes demonstrates the challenges injured workers can face in securing necessary medical care to support their claims.
Workers' compensation law in Idaho, like in other states, requires injured workers to prove that their injuries are work-related and that any ongoing medical treatment is necessary and related to the original workplace incident. The burden of proof can become particularly challenging when there are gaps in medical treatment or when symptoms develop or worsen over time.
The case also illustrates the importance of independent medical examinations in workers' compensation disputes. These examinations, typically conducted by physicians selected by the insurance carrier, often serve as pivotal evidence in determining whether an injured worker has reached maximum medical improvement and whether ongoing benefits should continue.
The court's decision to reverse the Industrial Commission's ruling suggests that the lower tribunal may have applied too stringent a standard in evaluating the connection between Miklos' original injury and his later-discovered tendon tear. By remanding the case, the Supreme Court is directing the Commission to reconsider its analysis under the correct legal framework.
For injured workers in Idaho, this decision may provide encouragement that courts will scrutinize Industrial Commission decisions that deny benefits, particularly when there are questions about the proper legal standards being applied. The case underscores the importance of obtaining comprehensive medical evidence to support workers' compensation claims, even when such evidence may be difficult to obtain due to coverage disputes.
The ruling also highlights the significance of legal representation in workers' compensation cases. Complex medical and legal issues often require skilled advocacy to ensure that injured workers receive the benefits to which they are entitled under state law.
L&W Supply Corporation and its insurer will now face renewed proceedings before the Industrial Commission, where they will need to address the legal standards identified by the Supreme Court. The ultimate outcome of Miklos' claim for ongoing benefits and additional medical treatment will depend on how the Commission applies the correct legal framework on remand.
This case serves as a reminder that workers' compensation law continues to evolve through appellate decisions that clarify the rights and obligations of both injured workers and their employers. The Idaho Supreme Court's reversal ensures that Miklos will have another opportunity to present his case under the proper legal standard before the Industrial Commission.