odd-lot doctrine (Idaho) · Go Syfert
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odd-lot doctrine in Idaho

17 Idaho opinions name it 1 courts 1988–2024 1 in the last five years

The cases below were cited by Idaho courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
Francis v. Amalgamated Sugar Co.green
idaho · 1977 · cited in 2 Idaho opinions naming this issue, 1988–1989
2 sentences

1989Kindred v. Amalgamated Sugar Co., 114 Idaho 284 , 756 P.2d 401 (1988) (19% impairment increased to 100% disability under odd lot doctrine); Nielson v. Industrial Special Indemnity Fund, 106 Idaho 878 , 684 P.2d 280 (1984) (35% impairment increased to 100% disability under odd lot doctrine); Carey v. Clearwater County Road Dept., 107 Idaho 109 , 686 P.2d 54 (1984) (50% impairment increased to 100% disability under odd lot doctrine); Francis v. Amalgamated Sugar Co., 98 Idaho 407 , 565 P.2d 1364 (1977) (25% disability increased to 100% disability under odd lot doctrine); and Lyons v. Industrial

1989Kindred v. Amalgamated Sugar Co., 114 Idaho 284 , 756 P.2d 401 (1988) (19% impairment increased to 100% disability under odd lot doctrine); Nielson v. Industrial Special Indemnity Fund, 106 Idaho 878 , 684 P.2d 280 (1984) (35% impairment increased to 100% disability under odd lot doctrine); Carey v. Clearwater County Road Dept., 107 Idaho 109 , 686 P.2d 54 (1984) (50% impairment increased to 100% disability under odd lot doctrine); Francis v. Amalgamated Sugar Co., 98 Idaho 407 , 565 P.2d 1364 (1977) (25% disability increased to 100% disability under odd lot doctrine); and Lyons v. Industrial

12
Aguilar v. Stategreen
idaho · 2019 · cited in 1 Idaho opinions naming this issue, 2024–2024
2 sentences

2024“An odd-lot worker is one who, as a result of the injury, is impaired to an extent that his or her ability to perform services is so limited in quality, quantity, or dependability that no reasonable market for his or her services exists.” Aguilar, 164 Idaho at 900 , 436 P.3d at 1249 (citation omitted).

2024“An odd-lot worker is one who, as a result of the injury, is impaired to an extent that his or her ability to perform services is so limited in quality, quantity, or dependability that no reasonable market for his or her services exists.” Aguilar, 164 Idaho at 900 , 436 P.3d at 1249 (citation omitted).

11
Gordon v. Westgreen
idaho · 1982 · cited in 1 Idaho opinions naming this issue, 1996–1996
2 sentences

1996Cf. Gordon v. West, 103 Idaho 100, 104-05 , 645 P.2d 334, 338-39 (1982) (claimant must do more than show he cannot perform his previous type of employment to establish odd-lot status; he must show that there is no suitable occupation available).

1996Cf. Gordon v. West, 103 Idaho 100, 104-05 , 645 P.2d 334, 338-39 (1982) (claimant must do more than show he cannot perform his previous type of employment to establish odd-lot status; he must show that there is no suitable occupation available).

11
Crawford v. Nielsongreen
idaho · 1957 · cited in 1 Idaho opinions naming this issue, 1996–1996
2 sentences

1996See Crawford v. Nielson, 78 Idaho 526 , 307 P.2d 229 (1957) (because odd-lot workers are by definition not absolutely helpless, the mere fact of actual employment is not conclusive as to question of total permanent disability).

1996See Crawford v. Nielson, 78 Idaho 526 , 307 P.2d 229 (1957) (because odd-lot workers are by definition not absolutely helpless, the mere fact of actual employment is not conclusive as to question of total permanent disability).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Idaho. Read the followed side critically anyway.

Also cited on this issue (13)

CaseCitedYears
Lyons v. Industrial Special Indemnity Fund green
idaho · 1977
2 sentences

2017The first step of the odd-lot doctrine consists of & prima facie showing by the claimant that he or she will not be “employed regularly in any well-known branch of the labor market absent a business boom, the sympathy of a particular employer or friends, temporary good luck, or a superhuman effort on [claimant’s] part.” Lyons, 98 Idaho at 406 , 565 P.2d at 1363 .

2017The first step of the odd-lot doctrine consists of & prima facie showing by the claimant that he or she will not be “employed regularly in any well-known branch of the labor market absent a business boom, the sympathy of a particular employer or friends, temporary good luck, or a superhuman effort on [claimant’s] part.” Lyons, 98 Idaho at 406 , 565 P.2d at 1363 .

31989–2017
Carey v. Clearwater County Road Department green
idaho · 1984
2 sentences

1995Dep't, 107 Idaho 109 , 686 P.2d 54 (1984), this Court established a formula for the apportionment of the non-medical portion of liability for an employee’s disability between the I.S.I.F. and the employer/surety where the employee was totally and permanently disabled under the odd-lot doctrine.

1995Dep't, 107 Idaho 109 , 686 P.2d 54 (1984), this Court established a formula for the apportionment of the non-medical portion of liability for an employee’s disability between the I.S.I.F. and the employer/surety where the employee was totally and permanently disabled under the odd-lot doctrine.

31989–2014
Boley v. State, Industrial Special Indemnity Fund green
idaho · 1997
2 sentences

2024“The odd-lot doctrine comes into play when the claimant has proved something less than 100% disability.” Id. (citation omitted).

2001Id.

22001–2024
Stoddard v. Hagadone Corp. green
idaho · 2009
2 sentences

2012Id.

2012Id.

22012–2012
Hegel v. Kuhlman Bros., Inc. green
idaho · 1989
2 sentences

2001Id. at 858 , 771 P.2d at 522 .

2001Id. at 858 , 771 P.2d at 522 .

21997–2001
Huerta v. School Dist. No. 431 green
idaho · 1989
2 sentences

1994No. m, 116 Idaho 43, 48-49 , 773 P.2d' 1130, 1135-36 (1989).

1989Huerta v. School District # 431, 116 Idaho 43 , 773 P.2d 1130 (1989).

21989–1994
Thompson v. MOTEL 6 green
idaho · 2001
2 sentences

2001Thompson v. Motel 6, 135 Idaho 373 , 17 P.3d 874 (2001).

2001Thompson v. Motel 6, 135 Idaho 373 , 17 P.3d 874 (2001).

12001–2001
Hamilton v. Ted Beamis Logging & Construction green
idaho · 1995
2 sentences

1996In that case there was no question that pre-existing conditions did not combine with the subsequent injury since “Hamilton was already totally and permanently disabled [pursuant to the odd-lot doctrine] coming into the second injury.” Id. at 225 , 899 P.2d at 438 .

1996In that case there was no question that pre-existing conditions did not combine with the subsequent injury since “Hamilton was already totally and permanently disabled [pursuant to the odd-lot doctrine] coming into the second injury.” Id. at 225 , 899 P.2d at 438 .

11996–1996
Archer v. Bonners Ferry Datsun green
idaho · 1990
2 sentences

1990We vacate the Commission’s order apportioning fifty percent of the cause of the disability to a preexisting impairment and remand to the Commission for reconsideration under Archer v. Bonners Ferry Datsun, 117 Idaho 166 , 786 P.2d 557 (1990).

1990We vacate the Commission’s order apportioning fifty percent of the cause of the disability to a preexisting impairment and remand to the Commission for reconsideration under Archer v. Bonners Ferry Datsun, 117 Idaho 166 , 786 P.2d 557 (1990).

11990–1990
Kindred v. Amalgamated Sugar Co. green
idaho · 1988
2 sentences

1989Kindred v. Amalgamated Sugar Co., 114 Idaho 284 , 756 P.2d 401 (1988) (19% impairment increased to 100% disability under odd lot doctrine); Nielson v. Industrial Special Indemnity Fund, 106 Idaho 878 , 684 P.2d 280 (1984) (35% impairment increased to 100% disability under odd lot doctrine); Carey v. Clearwater County Road Dept., 107 Idaho 109 , 686 P.2d 54 (1984) (50% impairment increased to 100% disability under odd lot doctrine); Francis v. Amalgamated Sugar Co., 98 Idaho 407 , 565 P.2d 1364 (1977) (25% disability increased to 100% disability under odd lot doctrine); and Lyons v. Industrial

1989Kindred v. Amalgamated Sugar Co., 114 Idaho 284 , 756 P.2d 401 (1988) (19% impairment increased to 100% disability under odd lot doctrine); Nielson v. Industrial Special Indemnity Fund, 106 Idaho 878 , 684 P.2d 280 (1984) (35% impairment increased to 100% disability under odd lot doctrine); Carey v. Clearwater County Road Dept., 107 Idaho 109 , 686 P.2d 54 (1984) (50% impairment increased to 100% disability under odd lot doctrine); Francis v. Amalgamated Sugar Co., 98 Idaho 407 , 565 P.2d 1364 (1977) (25% disability increased to 100% disability under odd lot doctrine); and Lyons v. Industrial

11989–1989
Rost v. J.R. Simplot Co. green
idaho · 1984
2 sentences

1989In Rost v. Simplot, 106 Idaho 444 , 680 P.2d 866 (1984), this Court held that it is the “claimant’s burden to establish a prima facie case that he is a member of the odd-lot category,” and that in order to present a prima facie case of odd-lot total disability, that claimant must prove the unavailability of any suitable work.

1989In Rost v. Simplot, 106 Idaho 444 , 680 P.2d 866 (1984), this Court held that it is the “claimant’s burden to establish a prima facie case that he is a member of the odd-lot category,” and that in order to present a prima facie case of odd-lot total disability, that claimant must prove the unavailability of any suitable work.

11989–1989
Nielson v. State, Indus. Special Indem. Fund green
idaho · 1984
2 sentences

1989Kindred v. Amalgamated Sugar Co., 114 Idaho 284 , 756 P.2d 401 (1988) (19% impairment increased to 100% disability under odd lot doctrine); Nielson v. Industrial Special Indemnity Fund, 106 Idaho 878 , 684 P.2d 280 (1984) (35% impairment increased to 100% disability under odd lot doctrine); Carey v. Clearwater County Road Dept., 107 Idaho 109 , 686 P.2d 54 (1984) (50% impairment increased to 100% disability under odd lot doctrine); Francis v. Amalgamated Sugar Co., 98 Idaho 407 , 565 P.2d 1364 (1977) (25% disability increased to 100% disability under odd lot doctrine); and Lyons v. Industrial

1989Kindred v. Amalgamated Sugar Co., 114 Idaho 284 , 756 P.2d 401 (1988) (19% impairment increased to 100% disability under odd lot doctrine); Nielson v. Industrial Special Indemnity Fund, 106 Idaho 878 , 684 P.2d 280 (1984) (35% impairment increased to 100% disability under odd lot doctrine); Carey v. Clearwater County Road Dept., 107 Idaho 109 , 686 P.2d 54 (1984) (50% impairment increased to 100% disability under odd lot doctrine); Francis v. Amalgamated Sugar Co., 98 Idaho 407 , 565 P.2d 1364 (1977) (25% disability increased to 100% disability under odd lot doctrine); and Lyons v. Industrial

11989–1989
Mapusaga v. Red Lion Riverside Inn green
idaho · 1987
2 sentences

1989Perhaps the most instructive case is Mapusaga v. Red Lion Riverside Inn, 113 Idaho 842 , 748 P.2d 1372 (1987).

1989Perhaps the most instructive case is Mapusaga v. Red Lion Riverside Inn, 113 Idaho 842 , 748 P.2d 1372 (1987).

11989–1989

Statutes the citing opinions construe

ID § Idaho Code § 72-425 (9) ID § Idaho Code § 72-332 (7) ID § Idaho Code § 72-430 (7) ID § Idaho Code § 72-423 (5) ID § Idaho Code § 72-732 (4) ID § Idaho Code § 72-422 (3) ID § Idaho Code § 72-804 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

LA 89 (1972–2009) SD 23 (1988–2024) WY 22 (1983–2023) ID 17 (1988–2024) OR 15 (1972–2016) HI 15 (1982–2024) AR 14 (1985–2006) NJ 11 (1971–2019) IA 10 (1986–2026) WA 9 (1993–2019) UT 9 (1986–2017) NE 8 (1990–2021) WI 7 (2004–2025) NV 3 (1995–2015) AK 2 (1991–2016)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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