Idaho Code

Idaho Code § 72-425 (2026)

Permanent disability evaluation. 

✓ text as last checked Oct. 2026 (this copy records no edition or section history)
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Permanent disability evaluation. 

"Evaluation (rating) of permanent disability" is an appraisal of the injured employee’s present and probable future ability to engage in gainful activity as it is affected by the medical factor of permanent impairment and by pertinent nonmedical factors as provided in section 72-430, Idaho Code.

Notes of Decisions
Cited in 86 cases (4 in the last 5 years), 1975–2026 · leading case: Horton v. Garrett Freightlines, Inc., 772 P.2d 119 (Idaho 1989).
Horton v. Garrett Freightlines, Inc., 772 P.2d 119 (Idaho 1989). · cites it 58× “Idaho Code § 72-425 amalgamated with § 72-430: Permanent disability evaluation.”
Baldner v. Bennett's, Inc., 649 P.2d 1214 (Idaho 1982). · cites it 36× “§ 72-425 requires the Commission to consider other factors such as claimant's age, sex, education, training, usable skills, together with the economic and social environment to determine the extent of a claimant's permanent disability, and that the Commission's failure to…”
Graybill v. Swift & Co., 766 P.2d 763 (Idaho 1988). · cites it 32× “" After considering claimant's age, education, work experience and the other non-medical factors provided for in I.C. § 72-425, the commission made its finding of fact that claimant's "impairment of 6 1/2% of the whole man, which is based primarily upon claimant's pain…”
Bennett v. Clark Hereford Ranch, 680 P.2d 539 (Idaho 1984). · cites it 28× “I.C. § 72-425, at the time relevant to this proceeding, [5] provided that the evaluation of permanent disability is "an appraisal of the injured employee's present and probable future ability to engage in gainful activity as it is affected by the medical factor of permanent…”
Gordon v. West, 645 P.2d 334 (Idaho 1982). · cites it 18× “I.C. § 72-425... . [T]he effect of successive injuries may be greater than the sum of the impairments resulting from each.”
Houser v. S. Idaho Pipe & Steel, Inc., 649 P.2d 1197 (Idaho 1982). · cites it 18× “" See I.C. § 72-425. Consistent with I.C. §§ 72-422 and 72-425, claimant also directs the court's attention to the statement in Lyons v.”
Davaz v. Priest River Glass Co., 870 P.2d 1292 (Idaho 1994). · cites it 16× “Idaho Code § 72-425 defines permanent disability as a function of the claimant's ability to engage in gainful activity as affected by physical impairment in conjunction with nonmedical factors.”
Marquez v. Pierce Painting, Inc., 423 P.3d 1011 (Idaho 2018). · cites it 25× “” In so ruling, the Commission determined that “the most appropriate way to measure permanent disability based on a loss of earning capacity per Idaho Code §72-425 and Idaho Code §72-430 is to evaluate disability without reference to such injured worker’s immigration status.”
Lyons v. Indus. Special Indem. Fund, 565 P.2d 1360 (Idaho 1977). · cites it 10× “Idaho Code § 72-425 requires that the Commission consider the economic and social environment in which the claimant lives.”
Paulson v. Idaho Forest Indus., Inc., 591 P.2d 143 (Idaho 1979). · cites it 12× “Generally, a permanent disability rating "is an appraisal of the injured employee's present and probable future ability to engage in gainful activity as it is affected by the medical factor of permanent impairment and by nonmedical factors, such as age, sex, education, economic…”
Sharp v. Thomas Bros Plumbing, 510 P.3d 1136 (Idaho 2022). · cites it 16× “The term ”permanent impairment” is defined as “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.”
Reynolds v. Browning Ferris Indus., 751 P.2d 113 (Idaho 1988). · cites it 14× “The authority for this alternative approach is found in I.C. § 72-425: Permanent disability evaluation.”
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