Idaho Code
Idaho Code

Idaho Code § 72-506 (2026)

Acts of commission or reference — Hearing officers. 

✓ current as of May 2026
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Acts of commission or reference — Hearing officers. 

(1) Any investigation, inquiry or hearing which the commission has power to undertake or hold may be undertaken or held by or before any member thereof or any hearing officer, referee or examiner appointed by the commission for that purpose.

(2)  Every finding, order, decision or award made by any member, hearing officer, referee, or examiner pursuant to such investigation, inquiry or hearing, when approved and confirmed by the commission, and ordered filed in its office, shall be deemed to be the finding, order, decision or award of the commission.
Notes of Decisions
Cited in 23 cases, 1984–2019 · leading case: State Ex Rel. Indus. Comm'n v. Quick Transp., Inc., 999 P.2d 895 (Idaho 2000).
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State Ex Rel. Indus. Comm'n v. Quick Transp., Inc., 999 P.2d 895 (Idaho 2000). · cites it 10× “§ 72-319 cannot be read to allow the Commission to file an action in district court without first having heard the matter in its judicial capacity because such an interpretation would create a conflict with I.C. § 72-506. I.C. § 72-506 states: (1) Any investigation, inquiry or…”
Horton v. Garrett Freightlines, Inc., 684 P.2d 297 (Idaho 1984). · cites it 8× “I.C. § 72-506 provides: "72-506. Acts of commission or reference — Hearing officers.”
Zapata v. J.R. Simplot Co., 975 P.2d 1178 (Idaho 1999). · cites it 4× “See I.C. § 72-506 (2). Further, I.C. § 72-717 establishes that the findings of a referee are only recommendations and must be submitted to the Commission for its review and decision.”
Evans v. Hara's, Inc., 849 P.2d 934 (Idaho 1993). · cites it 4× “§ 72-506(2) ("Every finding, order, decision or award made by any member, hearing officer, referee, or examiner pursuant to such investigation, inquiry or hearing, when approved and confirmed by the commission, and ordered filed in its office, shall be deemed to be the finding,…”
Ball v. Daw Forest Prods. Co., 30 P.3d 933 (Idaho 2001). · cites it 4× “See I.C. § 72-506(1). Ball contends that because uncontested testimony at the hearing established that he is employable only if he can drive and because the Commission found his prognosis to be poor, i.”
Van Heukelom v. Pine Crest Psychiatric Ctr., 684 P.2d 300 (Idaho 1984). · cites it 8× “Specifically, I.C. § 72-506 states: "72-506. Acts of commission or reference — Hearing officers.”
Stevens-McAtee v. Potlatch Corp., 179 P.3d 288 (Idaho 2008). · cites it 2× “As permitted by I.C. § 72-506, the Commission adopted the findings of fact, conclusions of law, and recommendation of the Referee as its own.”
Peterson v. Farmore Pump & Irrigation, 812 P.2d 276 (Idaho 1991). · cites it 4× “I.C. § 72-506 provides: (1) Any investigation, inquiry or hearing which the commission has power to undertake or hold may be undertaken or held by or before any member thereof or any hearing officer, referee or examiner appointed by the commission for that purpose.”
McCabe v. Jo-Ann Stores, Inc., 175 P.3d 780 (Idaho 2007). · cites it 2× “As permitted by I.C. § 72-506, the Commission adopted the findings of fact, conclusions of law, and recommendation of the Referee as *99 its own.”
Fonseca v. Corral Agric., Inc., 321 P.3d 692 (Idaho 2014). · cites it 2× “Fonseca made two motions for sanctions regarding Corral’s discovery responses asserting that Corral failed to properly respond to Fonseca’s discovery requests.”
Ayala v. Robert J. Meyers Farms, Inc., 445 P.3d 164 (Idaho 2019). · cites it 6× “I.C. § 72-506(1). JRP Rule 10 also provides that "[h]earings are held by one or more Commissioners or a Referee appointed by the Commission.”
Dehlbom v. State, Indus. Special Indemn. Fund, 930 P.2d 1021 (Idaho 1997). · cites it 2× “The Court first noted that I.C. § 72-506 provides that findings, orders, and decisions made by a referee become final orders and decisions of the Commission when “approved and confirmed” by the Commission.”
Show all 23 citing cases →
— Idaho Code § 72-506(1) — 3 cases
Ball v. Daw Forest Prods. Co., 30 P.3d 933 (Idaho 2001). “See I.C. § 72-506(1). Ball contends that because uncontested testimony at the hearing established that he is employable only if he can drive and because the Commission found his prognosis to be poor, i.”
Ayala v. Robert J. Meyers Farms, Inc., 445 P.3d 164 (Idaho 2019). “I.C. § 72-506(1). JRP Rule 10 also provides that "[h]earings are held by one or more Commissioners or a Referee appointed by the Commission.”
Ayala v. Meyers Farms (Idaho 2019).
— Idaho Code § 72-506(2) — 8 cases
Evans v. Hara's, Inc., 849 P.2d 934 (Idaho 1993). “§ 72-506(2) ("Every finding, order, decision or award made by any member, hearing officer, referee, or examiner pursuant to such investigation, inquiry or hearing, when approved and confirmed by the commission, and ordered filed in its office, shall be deemed to be the finding,…”
Horton v. Garrett Freightlines, Inc., 684 P.2d 297 (Idaho 1984). “I.C. § 72-506 provides: "72-506. Acts of commission or reference — Hearing officers.”
Ball v. Daw Forest Prods. Co., 30 P.3d 933 (Idaho 2001). “See I.C. § 72-506(1). Ball contends that because uncontested testimony at the hearing established that he is employable only if he can drive and because the Commission found his prognosis to be poor, i.”
Cantu v. J.R. Simplot Co., 826 P.2d 1297 (Idaho 1992).
Lorca-Merono v. Yokes Washington Foods, Inc., 50 P.3d 461 (Idaho 2002).
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