Idaho Code
Idaho Code

Idaho Code § 72-719 (2026)

Modification of awards and agreements — Grounds — Time within which made. 

✓ current as of May 2026
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Modification of awards and agreements — Grounds — Time within which made. 

(1) On application made by a party in interest filed with the commission at any time within five (5) years of the date of the accident causing the injury or date of first manifestation of an occupational disease, on the ground of a change in conditions, the commission may, but not oftener than once in six (6) months, review any order, agreement or award upon any of the following grounds:

(a)  Change in the nature or extent of the employee’s injury or disablement; or
(b)  Fraud.
(2)  The commission on such review may make an award ending, diminishing or increasing the compensation previously agreed upon or awarded, subject to the maximum and minimum provided in this law, and shall make its findings of fact, rulings of law and order or award, file the same in the office of the commission, and immediately send a copy thereof to the parties.
(3)  The commission, on its own motion at any time within five (5) years of the date of the accident causing the injury or date of first manifestation of an occupational disease, may review a case in order to correct a manifest injustice.
(4)  This section shall not apply to a commutation of payments under section 72-404.
Notes of Decisions
Cited in 44 cases, 1975–2019 · leading case: Sines v. Appel, 644 P.2d 331 (Idaho 1982).
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Sines v. Appel, 644 P.2d 331 (Idaho 1982). · cites it 66× “The primary issue presented by appellant is that the Commission erred in refusing to grant a modification of the previous award as sought in his application for a hearing.”
Frank v. Bunker Hill Co., 124 P.3d 1002 (Idaho 2005). · cites it 39× “On June 4,1991, Bunker Hill responded to the application for hearing, asserting that Frank’s claim for additional disability benefits was barred by the statute of limitations in Idaho Code § 72-719 . The parties stipulated to present the following issues for determination: (1)…”
Fowler v. City of Rexburg, 773 P.2d 269 (Idaho 1989). · cites it 66× “For the following reasons, we reject Fowler's contentions and affirm the decision of the Industrial Commission.”
Woodvine v. Triangle Dairy, Inc., 682 P.2d 1263 (Idaho 1984). · cites it 28× “§ 72-706(2), or alternatively, to reopen and modify the third compensation agreement pursuant to I.C. § 72-719. Claimant alleged that he was in fact 100% disabled according to the "odd lot" doctrine.”
Banzhaf v. Carnation Co., 662 P.2d 1144 (Idaho 1983). · cites it 36× “It is well recognized that a compensation agreement approved by the Industrial Commission is equivalent to an award under the Idaho Workmen's Compensation laws.”
Kindred v. Amalgamated Sugar Co., 756 P.2d 401 (Idaho 1988). · cites it 24× “Primarily, there are two issues in this appeal: (1) Whether a claimant can only seek modifications of his worker's compensation award pursuant to I.C. § 72-719, as provided on the face of the compensation agreement; (2) Whether the Industrial Commission inappropriately applied…”
Frank v. Bunker Hill Co., 792 P.2d 815 (Idaho 1990). · cites it 54× “I.C. § 72-719 provides: Modification of awards and agreements — Grounds — Time within which made.”
Iverson v. Gordon Farming Co., Inc., 650 P.2d 669 (Idaho 1982). · cites it 36× “Following this dismissal, Iverson, through new counsel, filed a motion to reopen the case before the Industrial Commission on March 27, 1978, under I.C. § 72-719(3) [1] claiming that the case required reopening in order to correct a manifest injustice.”
Walters v. Blincoe's Magic Valley Packing Co., 787 P.2d 225 (Idaho 1990). · cites it 42× “Blincoe's Magic Valley Packing Company (the employer) and General Insurance Company of America (the employer's surety) contend that *226 I.C. § 72-719 governs the case and that the application was filed too late.”
Sund v. Gambrel, 896 P.2d 329 (Idaho 1995). · cites it 12× “Such “final and conclusive” awards cannot be modified for any reason unless modification is sought under I.C. § 72-719 within five years of the date of the accident causing the injury.”
Reynolds v. Browning Ferris Indus., 751 P.2d 113 (Idaho 1988). · cites it 8× “Also, Reynolds had filed with the Commission on July 22, 1983, an Application for Hearing pursuant to I.C. § 72-719, in order to obtain benefits as the result of a change of condition.”
Welch v. Del Monte Corp., 915 P.2d 1371 (Idaho 1996). · cites it 10× “Section 72-719. Modification of awards and agreements — Grounds—Time within which made.”
Show all 44 citing cases →
— Idaho Code § 72-719(1) — 3 cases
Frank v. Bunker Hill Co., 124 P.3d 1002 (Idaho 2005). “On June 4,1991, Bunker Hill responded to the application for hearing, asserting that Frank’s claim for additional disability benefits was barred by the statute of limitations in Idaho Code § 72-719 . The parties stipulated to present the following issues for determination: (1)…”
Fowler v. City of Rexburg, 773 P.2d 269 (Idaho 1989). “For the following reasons, we reject Fowler's contentions and affirm the decision of the Industrial Commission.”
Davis v. Hammack Mgmt., Inc., 391 P.3d 1261 (Idaho 2017).
— Idaho Code § 72-719(1)(a) — 4 cases
Sines v. Appel, 644 P.2d 331 (Idaho 1982). “The primary issue presented by appellant is that the Commission erred in refusing to grant a modification of the previous award as sought in his application for a hearing.”
Frank v. Bunker Hill Co., 792 P.2d 815 (Idaho 1990). “I.C. § 72-719 provides: Modification of awards and agreements — Grounds — Time within which made.”
Ayala v. Robert J. Meyers Farms, Inc., 445 P.3d 164 (Idaho 2019).
Ayala v. Meyers Farms (Idaho 2019).
— Idaho Code § 72-719(1)(b) — 1 case
Brannon v. Pike, 737 P.2d 459 (Idaho 1987).
— Idaho Code § 72-719(3) — 15 cases
Sines v. Appel, 644 P.2d 331 (Idaho 1982). “The primary issue presented by appellant is that the Commission erred in refusing to grant a modification of the previous award as sought in his application for a hearing.”
Iverson v. Gordon Farming Co., Inc., 650 P.2d 669 (Idaho 1982). “Following this dismissal, Iverson, through new counsel, filed a motion to reopen the case before the Industrial Commission on March 27, 1978, under I.C. § 72-719(3) [1] claiming that the case required reopening in order to correct a manifest injustice.”
Banzhaf v. Carnation Co., 662 P.2d 1144 (Idaho 1983). “It is well recognized that a compensation agreement approved by the Industrial Commission is equivalent to an award under the Idaho Workmen's Compensation laws.”
Charles Hartgrave v. City of Twin Falls & SIF, 413 P.3d 747 (Idaho 2018).
Welch v. Del Monte Corp., 915 P.2d 1371 (Idaho 1996). “Section 72-719. Modification of awards and agreements — Grounds—Time within which made.”
— Idaho Code § 72-719(C) — 1 case
Cheh v. Eg & G Idaho, Inc., 244 P.3d 206 (Idaho 2010).
— Idaho Code § 72-719(a) — 1 case
Magee v. Thompson Creek Mining Co., 268 P.3d 464 (Idaho 2012).
— Idaho Code § 72-719(l)(a) — 5 cases
Sines v. Appel, 644 P.2d 331 (Idaho 1982). “The primary issue presented by appellant is that the Commission erred in refusing to grant a modification of the previous award as sought in his application for a hearing.”
Frank v. Bunker Hill Co., 792 P.2d 815 (Idaho 1990). “I.C. § 72-719 provides: Modification of awards and agreements — Grounds — Time within which made.”
Lampe v. Zamzow's, Inc., 626 P.2d 782 (Idaho 1981).
Magee v. Thompson Creek Mining Co., 268 P.3d 464 (Idaho 2012).
Colpaert v. Larson's, Inc., 771 P.2d 46 (Idaho 1989).
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