Ayala v. Meyers FarmsAnnotate this Case
Mario Ayala was injured while driving a company truck in 2009, and was injured again in 2013 after falling from a ladder. After the hearing, but before the referee issued “recommended findings and determination” in accordance with Idaho Code section 72-717, the Industrial Commission reassigned the case to itself over Ayala’s objection. Citing the referee’s backlog of cases and a need for efficiency, the Industrial Commission issued an order finding that Ayala’s low-back condition was not causally related to his 2009 truck wreck, that he was not totally and permanently disabled under the odd-lot worker doctrine, and that he suffered disability of 40% of the whole person inclusive of impairment of his 2009 and 2013 industrial accidents. The Idaho Supreme Court set aside the Commission’s findings of fact, conclusions of law and order because Ayala was denied due process when the Industrial Commission reviewed Ayala’s claims and issued a decision without the referee’s recommended findings and determination. The Court also set aside the Industrial Commission’s post-hearing order on motion for reconsideration and order on motion for reconsideration, modification and consolidation, and remanded this matter for a new hearing.