Idaho Code
Idaho Code § 72-425 (2026)
Permanent disability evaluation.
✓ current as of May 2026
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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). “Idaho Code § 72-425 amalgamated with § 72-430: Permanent disability evaluation.”
Baldner v. Bennett's, Inc., 649 P.2d 1214 (Idaho 1982). “§ 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). “" 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). “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). “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). “" 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., Inc., 870 P.2d 1292 (Idaho 1994). “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.”
Lyons v. Indus. Special Indem. Fund, 565 P.2d 1360 (Idaho 1977). “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). “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). “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). “The authority for this alternative approach is found in I.C. § 72-425: Permanent disability evaluation.”
Roberts v. Asgrow Seed Co., 775 P.2d 101 (Idaho 1989). “As to permanent disability, the referee further found claimant's age, limited formal education, limited work experience, physical appearance, and history of excessive alcohol consumption to be pertinent non-medical factors under I.C. §§ 72-425 and 72-430 in arriving at…”
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