Mayer v. TPC Holdings, Inc.
Annotate this CaseBefore the Supreme Court in this case was an appeal of an Industrial Commission decision relating to the survivability of claims for permanent partial disability when a claimant died for reasons unrelated to the work accident. While receiving benefits based on his impairment rating, Keith Mayer died of a heart attack unrelated to his work accident. Mayer’s impairment rating was paid out in full following his death. However, Mayer died before a determination was made as to what permanent disability benefits he may have been entitled to in excess of his impairment rating. The parties submitted the issue on stipulated facts and the Industrial Commission concluded that permanent partial disability less than total survived the death of an injured worker when the death was unrelated to the work accident. The Industrial Commission also determined that the disability of the deceased worker should be evaluated as of the time immediately preceding the worker’s death. TPC Holdings, Inc. (TPC) appealed, arguing that Mayer’s claim for permanent partial disability did not survive death. Because the plain language of Idaho Code section 72-431 allowed for the survival of income benefits for workers who have suffered “permanent disability less than total,” the Supreme Court affirmed the Industrial Commission’s decision.
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