Vawter v. United Parcel Service, Inc.
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This appeal stemmed from a worker’s compensation case in which Michael Vawter sought compensation from his employer, United Parcel Service (UPS), for a back injury he claimed he suffered as a result of his employment. UPS attempted to establish that Vawter did not suffer a compensable injury, but if he did the State's Industrial Special Indemnity Fund (ISIF) was liable for a portion of his benefits. Ultimately, the Idaho Industrial Commission found that Vawter was totally and permanently disabled and that UPS was solely responsible for Vawter’s disability benefits because it was estopped from arguing Vawter had a preexisting condition, a necessary element of ISIF liability. UPS appealed, arguing: (1) the accident causing Vawter’s injury did not arise out of his employment; (2) the Commission improperly applied the doctrine of quasi-estoppel to prevent it from asserting a preexisting condition; and (3) the Commission improperly awarded Vawter attorney fees. Vawter and ISIF both cross-appealed. Upon review, the Supreme Court reversed the Industrial Commission’s determination that Vawter was not entitled to recover all medical expenses incurred between the date of the accident and September 27, 2010. The Court affirmed the Industrial Commission in all other respects.
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