Idaho Code

Idaho Code § 72-422 (2026)

Permanent impairment.

✓ current as of May 2026

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Permanent impairment.

"Permanent impairment" is any anatomic or functional abnormality or loss after maximal medical rehabilitation has been achieved and which abnormality or loss, medically, is considered stable or nonprogressive at the time of evaluation. Permanent impairment is a basic consideration in the evaluation of permanent disability, and is a contributing factor to, but not necessarily an indication of, the entire extent of permanent disability.

Notes of Decisions

Cited in 56 cases (2 in the last 5 years), 1975–2025 · leading case: Hartley v. Miller-Stephan, 692 P.2d 332 (Idaho 1984).

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Hartley v. Miller-Stephan, 692 P.2d 332 (Idaho 1984). · cites it 43× “) I.C. § 72-422 defines permanent impairment as follows: "72-422.”

Horton v. Garrett Freightlines, Inc., 772 P.2d 119 (Idaho 1989). · cites it 38× “Horton returned to his work with Garrett Freightlines without ever knowing of his potential entitlement to some compensation for "permanent impairment" suffered in the accident, I.C. § 72-422, and for resultant "permanent disability," I.”

Mapusaga v. Red Lion Riverside Inn, 748 P.2d 1372 (Idaho 1987). · cites it 16× “I remain amazed that three of my esteemed colleagues were persuaded to Justice Shepard's view that the brain was not part of the anatomy of a human being, and that its functional loss or abnormality was not within the purview of the plain language of I.C. § 72-422 which defined…”

Houser v. S. Idaho Pipe & Steel, Inc., 649 P.2d 1197 (Idaho 1982). · cites it 12× “As to this assertion, claimant directs the court's attention to I.C. § 72-422, which states in part, "[p]ermanent impairment is a basic consideration in the evaluation of permanent disability, and is a contributing factor to, but not necessarily an indication of, the entire…”

Reynolds v. Browning Ferris Indus., 751 P.2d 113 (Idaho 1988). · cites it 16× “And since permanent impairment is a "basic consideration in the evaluation of permanent disability," I.C. § 72-422, then the Commission erroneously relinquished jurisdiction over the future determination of Reynolds' permanent disability.”

Urry v. Walker & Fox Masonry Contractors, 769 P.2d 1122 (Idaho 1989). · cites it 14× “" I.C. § 72-422. It is a "basic consideration" in determining disability.”

Smith v. J.B. Parson Co., 908 P.2d 1244 (Idaho 1996). · cites it 10× “Since no impairment rating of Smith’s blood condition was made by any of Smith’s physicians, the referee determined that, based on Smith’s testimony and physicians’ reports, Smith’s polycythemia vera was a functional abnormality, which constituted a permanent physical impairment…”

Red Lion Motor Inn-Riverside v. Indus. Sp. Indem. Fund, 835 P.2d 1275 (Idaho 1992). · cites it 32× “§ 72-332, dealing with the payment obligations of the Industrial Special Indemnity Fund, incorporates by reference *1280 I.C. § 72-422, which defines permanent impairment.”

Paulson v. Idaho Forest Indus., Inc., 591 P.2d 143 (Idaho 1979). · cites it 6× “" I.C. § 72-422. [5] Temporary impairment would *151 likewise be a factor but not necessarily the controlling consideration in determining the extent of a person's temporary disability.”

Roy Green v. Indus. Special Indem., 371 P.3d 329 (Idaho 2016). · cites it 6× “” I.C. § 72-422. 4 . At oral argument, Employer/Surety questioned whether this Court should continue the application of the "but for" test because the test deviates from the "combined effects” language in Idaho Code section 72-332(1).”

Graybill v. Swift & Co., 766 P.2d 763 (Idaho 1988). · cites it 8× “) The permanent impairment portion of that analysis, as defined in I.C. § 72-422 "is any anatomic or functional abnormality or loss after maximal medical rehabilitation has been achieved and which abnormality or loss, medically, is considered stable or nonprogressive at the time…”

Brown v. Home Depot, 272 P.3d 577 (Idaho 2012). · cites it 6× “I.C. § 72-422.” Stoddard, 147 Idaho at 192 , 207 P.”

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