Idaho Code
Idaho Code § 72-203 (2026)
Employments covered.
✓ current as of May 2026
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Employments covered.
This law shall apply to all public employment and to all private employment including farm labor contracting not expressly exempt by the provisions of section 72-212, Idaho Code.
Notes of Decisions
Cited in 22
cases (2 in the last 5 years), 1953–2023 · leading case: Goodson v. LW Hult Produce Co., 543 P.2d 167 (Idaho 1975).
Goodson v. LW Hult Produce Co., 543 P.2d 167 (Idaho 1975). “" The latter section specifically enunciates an exemption from the Act's coverage for "agricultural pursuits" which include "the raising or harvesting of any agricultural or horticultural commodity * * *.”
Kolar v. Cassia Cnty. Idaho, 127 P.3d 962 (Idaho 2005). “not expressly exempt by the provisions of section 72-212;” sections 72-209 and 72-211 make plainly clear that the exceptions to the exclusivity provisions are quite limited; and neither sections 72-223 nor 72-212 allow for the “professional services” exception Mr.”
Yount v. Boundary Cnty., 796 P.2d 516 (Idaho 1990). “The preceding statute, I.C. § 72-203, declares that workers' compensation law "shall apply to all public employment.”
Adam v. Titan Equip. Supply Corp., 470 P.2d 409 (Idaho 1970). “I.C. § 72-203; Gifford v. Nottingham, supra; Russell v.”
Brown v. Arrington Const. Co., 262 P.2d 789 (Idaho 1953). “That it was the intention of the legislature to make the remedies provided by the act exclusive of all others is further emphasized by § 72-203, I.C., as follows: "The rights and remedies herein granted to an employee on account of a personal injury for which he is entitled to…”
Smith v. Excel Fabrication, LLC, 535 P.3d 1098 (Idaho 2023). “While the Act does not separately define what constitutes a contract for service, it does define private and public employment. Those definitions provide insight into the type of contract required to establish an employer-employee relationship under the Act.”
Provo v. Bunker Hill Co., 393 F. Supp. 778 (D. Idaho 1975). “” (emphasis supplied) Furthermore, it is provided in Idaho Code 72-203: “Right to compensation exclusive.”
Kirk v. United States, 124 F. Supp. 233 (D. Idaho 1954). “Section 72-203, I.C., provides as follows: “The rights and remedies herein granted to an employee on account of a personal injury for which he is entitled to compensation under this act shall exclude all other rights and remedies of such employee, his personal representatives,…”
Daleiden v. Jefferson Cnty. Jt. Sch. Dist. No. 251, 80 P.3d 1067 (Idaho 2003). “§ 72-205(1) and the corresponding requirement that there be a relationship of employment for worker’s compensation coverage, we find that independent contractors are excluded from coverage under this subsection.”
Summers v. W. Idaho Potato Processing Co., 479 P.2d 292 (Idaho 1970). “If she is seeking recovery for emotional trauma manifested by physical injuries, her action is precluded by our statutory Workmen’s Compensation scheme.”
Backsen v. Blauser, 520 P.2d 858 (Idaho 1974). “I.C. § 72-203 provides that the workmen’s compensation laws shall apply to all public employment and all private employment not expressly exempt by I.”
Miller v. FMC Corp., 471 P.2d 550 (Idaho 1970). “The court held,' therefore, that appellant was precluded from bringing a negligence action by the Workmen’s Compensation Statute, I.C. § 72-203, 1 and that he could only look to the Industrial Accident Board for his exclusive remedy.”
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