Idaho Code

Idaho Code § 72-451 (2026)

Psychological accidents and injuries.

✓ current as of May 2026

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Psychological accidents and injuries.

(1) Psychological injuries, disorders or conditions shall not be compensated under this title, unless the following conditions are met:

(a) Such injuries of any kind or nature emanating from the workplace shall be compensated only if caused by accident and physical injury as defined in section 72-102(17)(a) through (c), Idaho Code, or only if accompanying an occupational disease with resultant physical injury, except that a psychological mishap or event may constitute an accident where:

(i) It results in resultant physical injury as long as the psychological mishap or event meets the other criteria of this section;

(ii) It is readily recognized and identifiable as having occurred in the workplace; and

(iii) It must be the product of a sudden and extraordinary event;

(b) No compensation shall be paid for such injuries arising from conditions generally inherent in every working situation or from a personnel-related action including, but not limited to, disciplinary action, changes in duty, job evaluation or employment termination;

(c) Such accident and injury must be the predominant cause as compared to all other causes combined of any consequence for which benefits are claimed under this section;

(d) Where psychological causes or injuries are recognized by this section, such causes or injuries must exist in a real and objective sense;

(e) Any permanent impairment or permanent disability for psychological injury recognizable under the Idaho worker’s compensation law must be based on a condition sufficient to constitute a diagnosis using the terminology and criteria of the American psychiatric association’s diagnostic and statistical manual of mental disorders, third edition revised, or any successor manual promulgated by the American psychiatric association, and must be made by a psychologist or psychiatrist duly licensed to practice in the jurisdiction in which treatment is rendered; and

(f) Clear and convincing evidence that the psychological injuries arose out of and in the course of the employment from an accident or occupational disease as contemplated in this section is required.

(2) Nothing in subsection (1) of this section shall be construed as allowing compensation for psychological injuries from psychological causes without accompanying physical injury.

(3) The provisions of subsection (1) of this section shall apply to accidents and injuries occurring on or after July 1, 1994, and to causes of action for benefits accruing on or after July 1, 1994, notwithstanding that the original worker’s compensation claim may have occurred prior to July 1, 1994.

(4) Notwithstanding subsection (1) of this section, post-traumatic stress injury suffered by a first responder is a compensable injury or occupational disease when the following conditions are met:

(a) The first responder is examined and subsequently diagnosed with post-traumatic stress injury by a psychologist, a psychiatrist duly licensed to practice in the jurisdiction where treatment is rendered, or a counselor trained in post-traumatic stress injury; and

(b) Clear and convincing evidence indicates that the post-traumatic stress injury was caused by an event or events arising out of and in the course of the first responder’s employment.

(5) No compensation shall be paid for such injuries described in subsection (4) of this section arising from a personnel-related action including, but not limited to, disciplinary action, changes in duty, job evaluation, or employment termination.

(6) As used in subsection (4) of this section:

(a) "Post-traumatic stress injury" means a disorder that meets the diagnostic criteria for post-traumatic stress disorder or post-traumatic stress injury specified by the American psychiatric association’s diagnostic and statistical manual of mental disorders, fifth edition revised, or any successor manual promulgated by the American psychiatric association.

(b) "First responder" means:

(i) A peace officer as defined in section 19-5101(d), Idaho Code, when employed by a city, county, or the Idaho state police;

(ii) A firefighter as defined in section 59-1302(16), Idaho Code;

(iii) A volunteer emergency responder as defined in section 72-102, Idaho Code;

(iv) An emergency medical services provider and an ambulance-based clinician certified pursuant to chapter 9, title 46, Idaho Code; and

(v) An emergency communications officer as defined in section 19-5101(f), Idaho Code.

(7) Subsections (4) through (6) of this section are effective for first responders with dates of injury or manifestations of occupational disease on or after July 1, 2019.

Notes of Decisions

Cited in 12 cases, 1995–2019 · leading case: Mazzone v. Texas Roadhouse, Inc., 302 P.3d 718 (Idaho 2013).

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Mazzone v. Texas Roadhouse, Inc., 302 P.3d 718 (Idaho 2013). · cites it 26× “Idaho Code § 72-451 bars mental-mental claims.”

Luttrell v. Clearwater Cnty. Sheriff's Off., 97 P.3d 448 (Idaho 2004). · cites it 26× “A hearing was held before an Industrial Commission referee who then issued Findings of Fact, Conclusions of Law and Recommendation, concluding that Luttrell’s case was a “classic mental-mental case” without any physical injuries and that compensation for such a claim was barred…”

Joseph Gerdon v. Con Paulos, Inc., 372 P.3d 390 (Idaho 2016). · cites it 22× “At issue in this case was the statutory requirement that “[s]uch accident and injury must be the predominant cause as compared to all other causes combined of any consequence for which benefits are claimed under this section.” I.C. § 72-451(3).”

Gibson v. Ada Cnty. Sheriff's Off., 211 P.3d 100 (Idaho 2009). · cites it 10× “Heyrend’s November 17, 2005 post-hearing deposition should not have been excluded; (3) that she suffered a compensable psychological injury pursuant to I.C. § 72-451; (4) that the Commission violated her rights under the Due Process Clause and the Equal Protection Clause of the…”

Warren v. Williams & Parsons PC CPAS, 337 P.3d 1257 (Idaho 2014). · cites it 20× “[Warren] has not demonstrated that the underlying psychological condition to be addressed in the chronic pain management program is causally related to the subject accident under the standard set by Idaho Code § 72-451 . Absent proof of a causal connection between [Warren]’s…”

Dunlavey v. Econ. Fire & Cas. Co., 526 N.W.2d 845 (Iowa 1995). “1994); Idaho Code § 72-451 (1994); Ky.Rev. Stat.”

Mulder v. Liberty Nw. Ins., 14 P.3d 372 (Idaho 2000). · cites it 2× “An “occupational disease” as defined by the worker’s compensation law is: [A] disease due to the nature of an employment in which the hazards of such disease actually exist, are characteristic of, and peculiar to the trade, occupation, process, or employment, but shall not…”

Zach v. Nebraska State Patrol, 727 N.W.2d 206 (Neb. 2007). “See, Idaho Code Ann. § 72-451 (2006); La. Rev.”

Mazzone v. Texas Roadhouse (Idaho 2013). · cites it 26× “Idaho Code § 72-451 bars mental-mental claims.”

Su Warren v. Williams & Parsons (Idaho 2014). · cites it 16× “[Warren] has not demonstrated that the underlying psychological condition to be addressed in the chronic pain management program is causally related to the subject accident under the standard set by Idaho Code § 72-451 . Absent proof of a causal connection between [Warren]’s…”

Smith v. Indus. Special Indem. Fund, 443 P.3d 178 (Idaho 2019). · cites it 4× “On October 27, 2008, a hearing was held before Referee Alan Taylor with the Industrial Commission of the State of Idaho to determine whether Smith was entitled to benefits for psychological injuries from his wrist accident pursuant to Idaho Code section 72-451. Kevin Smith…”

Smith v. State of Idaho, Indus. Special Indem. Fund (Idaho 2019). · cites it 4× “3 On October 27, 2008, a hearing was held before Referee Alan Taylor with the Industrial Commission of the State of Idaho to determine whether Smith was entitled to benefits for psychological injuries from his wrist accident pursuant to Idaho Code section 72-451. Kevin Smith…”

— Idaho Code § 72-451(3) — 7 cases

Joseph Gerdon v. Con Paulos, Inc., 372 P.3d 390 (Idaho 2016). “At issue in this case was the statutory requirement that “[s]uch accident and injury must be the predominant cause as compared to all other causes combined of any consequence for which benefits are claimed under this section.” I.C. § 72-451(3).”

Mazzone v. Texas Roadhouse, Inc., 302 P.3d 718 (Idaho 2013). “Idaho Code § 72-451 bars mental-mental claims.”

Warren v. Williams & Parsons PC CPAS, 337 P.3d 1257 (Idaho 2014). “[Warren] has not demonstrated that the underlying psychological condition to be addressed in the chronic pain management program is causally related to the subject accident under the standard set by Idaho Code § 72-451 . Absent proof of a causal connection between [Warren]’s…”

Smith v. Indus. Special Indem. Fund, 443 P.3d 178 (Idaho 2019). “On October 27, 2008, a hearing was held before Referee Alan Taylor with the Industrial Commission of the State of Idaho to determine whether Smith was entitled to benefits for psychological injuries from his wrist accident pursuant to Idaho Code section 72-451. Kevin Smith…”

Smith v. State of Idaho, Indus. Special Indem. Fund (Idaho 2019). “3 On October 27, 2008, a hearing was held before Referee Alan Taylor with the Industrial Commission of the State of Idaho to determine whether Smith was entitled to benefits for psychological injuries from his wrist accident pursuant to Idaho Code section 72-451. Kevin Smith…”

— Idaho Code § 72-451(5) — 2 cases

Mazzone v. Texas Roadhouse, Inc., 302 P.3d 718 (Idaho 2013). “Idaho Code § 72-451 bars mental-mental claims.”

Mazzone v. Texas Roadhouse (Idaho 2013). “Idaho Code § 72-451 bars mental-mental claims.”

— Idaho Code § 72-451(6) — 3 cases

Luttrell v. Clearwater Cnty. Sheriff's Off., 97 P.3d 448 (Idaho 2004). “A hearing was held before an Industrial Commission referee who then issued Findings of Fact, Conclusions of Law and Recommendation, concluding that Luttrell’s case was a “classic mental-mental case” without any physical injuries and that compensation for such a claim was barred…”

Su Warren v. Williams & Parsons (Idaho 2014). “[Warren] has not demonstrated that the underlying psychological condition to be addressed in the chronic pain management program is causally related to the subject accident under the standard set by Idaho Code § 72-451 . Absent proof of a causal connection between [Warren]’s…”

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