The Idaho Supreme Court reversed a workers' compensation decision by the Idaho Industrial Commission, ruling in favor of Christopher Miklos, a drywall delivery employee who sustained a right ankle injury while working for L&W Supply Corporation.
The court issued its opinion on Jan. 6, 2026, in *Miklos v. L&W Supply Corporation*, remanding the case back to the Industrial Commission for further proceedings. Justice Meyer authored the opinion reversing the commission's denial of benefits.
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 to the injured worker.
Miklos contested the discontinuation of benefits, claiming he continued to experience ongoing pain and required additional medical treatment, including surgery. The worker faced significant delays in obtaining proper medical imaging to support his claims.
Subsequent imaging, which was delayed by nearly 18 months due to coverage denials and procedural disputes between the parties, ultimately revealed a recurrent tendon tear in Miklos' ankle. This medical finding became central to the workers' compensation dispute.
Despite the imaging evidence showing the recurrent tendon tear, the Industrial Commission denied Miklos' claim for additional benefits. The commission concluded that Miklos had failed to prove that his recurrent tendon tear was caused by the 2019 industrial accident at L&W Supply Corporation.
The Supreme Court disagreed with the commission's analysis and legal reasoning. In its opinion, the court determined that the Industrial Commission had applied an incorrect legal standard when evaluating Miklos' claim for ongoing workers' compensation benefits.
The case highlights the complex medical and legal issues that can arise in workers' compensation disputes, particularly when there are delays in obtaining diagnostic imaging and questions about the ongoing effects of workplace injuries.
Taylor L. Mossman-Fletcher of Mossman Law Office argued the case for Miklos before the Supreme Court. Nathan T. Gamel of Gamel Law represented L&W Supply Corporation and Indemnity Insurance Company of North America.
The reversal means that Miklos' case will return to the Industrial Commission for reconsideration under the proper legal standard as established by the Supreme Court's ruling. This could potentially result in approval of additional medical treatment and benefits for the injured worker.
The decision underscores the importance of proper legal standards in evaluating workers' compensation claims, particularly in cases involving delayed diagnoses or recurrent injuries that may be related to the original workplace accident.
Workers' compensation cases often involve complex medical evidence and questions about causation between workplace injuries and ongoing medical conditions. The Idaho Supreme Court's reversal suggests that the Industrial Commission must apply appropriate legal standards when weighing such evidence.
The case also illustrates the challenges injured workers may face when seeking ongoing medical treatment for workplace injuries, including disputes over coverage and delays in obtaining necessary diagnostic procedures.
For L&W Supply Corporation and its insurer, the reversal means they may ultimately be responsible for additional medical expenses and benefits related to Miklos' ankle injury, pending the Industrial Commission's reconsideration of the claim.
The Supreme Court's decision to remand rather than rule definitively on the merits indicates that while the commission applied the wrong legal standard, factual questions remain that must be resolved by the Industrial Commission using the correct legal framework.
This case serves as a reminder to employers and insurers about the importance of thoroughly investigating workers' compensation claims and the potential long-term liability that may arise from workplace injuries, even after initial treatment appears complete.
The ruling also emphasizes the critical role that proper medical documentation and timely diagnostic procedures play in workers' compensation disputes, as the delayed imaging in this case ultimately provided key evidence supporting Miklos' claim for ongoing treatment.