Williams v. Blue Cross of Idaho
Annotate this CaseClaimant Patrick Williams appealed the Industrial Commission's determination that I.C. 72-802 does not prohibit Respondent Blue cross of Idaho from seeking to exercise its contractual right of subrogation against his lump sum settlement proceeds. Claimant's insurance contract with Blue Cross contained several subrogation and reimbursement provisions. In addition to seeking payment from Blue Cross, Williams filed a complaint with the Industrial Commission seeking workers’ compensation for the medical expenses incurred as a result of two shoulder surgeries, as well as benefits for temporary and permanent disability as a result of such injuries. Claimant entered into a lump sum settlement agreement with the State Insurance Fund. After the agreement was finalized before the Commission, Blue Cross sent a letter to counsel for Williams demanding that, pursuant to Blue Cross’ right of subrogation, he withhold money from the workers’ compensation proceeds for payment to Blue Cross. The Commission ultimately concluded that I.C. 72-802 did not prohibit Blue Cross from seeking to exercise a contractual right of subrogation because Blue Cross is a subrogee, and not a creditor, within the meaning of the statute. However, the Commission found it did not have jurisdiction to consider a breach of contract claim by Blue Cross against Williams and, therefore, determined that Blue Cross must pursue its remedy in district court. Upon review of the applicable legal authority and the Commission's record, the Supreme Court affirmed the Commission’s determination that Blue Cross was a subrogee under I.C. 72-802.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.