Idaho Code

Idaho Code § 72-430 (2026)

Permanent disability — Determination of — Percentages — Schedule.

✓ current as of May 2026

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Permanent disability — Determination of — Percentages — Schedule.

(1) Matters to be considered. In determining percentages of permanent disabilities, account shall be taken of the nature of the physical disablement, the disfigurement if of a kind likely to limit the employee in procuring or holding employment, the cumulative effect of multiple injuries, the occupation of the employee, and his age at the time of accident causing the injury, or manifestation of the occupational disease, consideration being given to the diminished ability of the afflicted employee to compete in an open labor market within a reasonable geographical area considering all the personal and economic circumstances of the employee, and other factors as the commission may deem relevant, provided that when a scheduled or unscheduled income benefit is paid or payable for the permanent partial or total loss or loss of use of a member or organ of the body no additional benefit shall be payable for disfigurement.

(2) Preparation of schedules — Availability for inspection — Prima facie evidence. The commission may prepare, adopt and from time to time amend a schedule for the determination of the percentages of unscheduled permanent injuries less than total, including, but not limited to, a schedule for partial loss of binaural hearing and for loss of teeth, and methods for determination thereof. Such schedule shall be available for public inspection, and without formal introduction in evidence shall be prima facie evidence of the percentages of permanent disabilities to be attributed to the injuries or diseases covered by such schedule.

Notes of Decisions

Cited in 68 cases (2 in the last 5 years), 1984–2024 · leading case: Davaz v. Priest River Glass Co., Inc., 870 P.2d 1292 (Idaho 1994).

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Davaz v. Priest River Glass Co., Inc., 870 P.2d 1292 (Idaho 1994). · cites it 64× “C. § 72-430(1). The confusion in this case results from the failure of the statutes to specify the hub from which the spokes of a "reasonable geographic area" radiate, whether it be from the place the injury occurred, the place the claimant resided at the time the injury…”

Horton v. Garrett Freightlines, Inc., 772 P.2d 119 (Idaho 1989). · cites it 67× “Horton's argument breaks down at the point where he concludes that if the Commission had determined that he were totally and permanently disabled as a result of all the physical impairments existing at the time of the evaluation, together with the nonmedical factors contained in…”

Combs v. Kelly Logging, 769 P.2d 572 (Idaho 1989). · cites it 32× “NOTES [1] Idaho Code § 72-430 provides in part: 72-430.”

McCabe v. Jo-Ann Stores, Inc., 175 P.3d 780 (Idaho 2007). · cites it 12× “Idaho Code § 72-430 (1) identifies the essential nonmedieal factors: the nature of the physical disablement; the cumulative effect of multiple injuries; the occupation of the employee; the employee’s age at the time of accident; all personal and economic circumstances of the…”

Brown v. Home Depot, 272 P.3d 577 (Idaho 2012). · cites it 10× “Therefore, we hold that the relevant labor market for evaluating the non-medical factors under I.C. § 72-430 and in determining a claimant’s odd-lot worker status is the labor market at the time of the hearing.”

Sharp v. Thomas Bros Plumbing, 510 P.3d 1136 (Idaho 2022). · cites it 9× “Sharp argues that the Commission erred by disregarding Brown and section 72-425 and by refusing to consider his obesity as a non-medical factor under section 72-430. While we conclude that Sharp’s argument under section 72-430 is unavailing, we agree that the Commission erred by…”

Texas Workers' Comp. Comm'n v. Garcia, 893 S.W.2d 504 (Tex. 1995). · cites it 2× “§ 34-9-1(5); Idaho Code § 72-430 (2); Kan.Stat.Ann. § 44-510d(a)(23); Ky.”

Page v. McCain Foods, Inc., 179 P.3d 265 (Idaho 2008). · cites it 7× “A permanent disability rating is the appraisal of the claimant’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 [I.”

Marquez v. Pierce Painting, Inc., 423 P.3d 1011 (Idaho 2018). · cites it 30× “” 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.”

Corgatelli v. Steel West, Inc., 335 P.3d 1150 (Idaho 2014). · cites it 6× “It provides: “ ‘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]…”

Ball v. Daw Forest Prods. Co., 30 P.3d 933 (Idaho 2001). · cites it 6× “Ball argues that the Commission failed to articulate how his alcoholism was related to the injury; however, alcoholism is a wow-medical factor — non-medical factors are not part of the physical impairment but are other factors that the Commission is required to consider in…”

Rivas v. K.C. Logging, 7 P.3d 212 (Idaho 2000). · cites it 6× “I.C. § 72-430. Whether an individual is disabled is determined by whether the individual has suffered a decrease in wage-earning capacity.”

Show all 68 citing cases →

— Idaho Code § 72-430(1) — 14 cases

Davaz v. Priest River Glass Co., Inc., 870 P.2d 1292 (Idaho 1994). “C. § 72-430(1). The confusion in this case results from the failure of the statutes to specify the hub from which the spokes of a "reasonable geographic area" radiate, whether it be from the place the injury occurred, the place the claimant resided at the time the injury…”

Brown v. Home Depot, 272 P.3d 577 (Idaho 2012). “Therefore, we hold that the relevant labor market for evaluating the non-medical factors under I.C. § 72-430 and in determining a claimant’s odd-lot worker status is the labor market at the time of the hearing.”

Horton v. Garrett Freightlines, Inc., 772 P.2d 119 (Idaho 1989). “Horton's argument breaks down at the point where he concludes that if the Commission had determined that he were totally and permanently disabled as a result of all the physical impairments existing at the time of the evaluation, together with the nonmedical factors contained in…”

Page v. McCain Foods, Inc., 179 P.3d 265 (Idaho 2008). “A permanent disability rating is the appraisal of the claimant’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 [I.”

McCabe v. Jo-Ann Stores, Inc., 175 P.3d 780 (Idaho 2007). “Idaho Code § 72-430 (1) identifies the essential nonmedieal factors: the nature of the physical disablement; the cumulative effect of multiple injuries; the occupation of the employee; the employee’s age at the time of accident; all personal and economic circumstances of the…”

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