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Burrow v. Caldwell Treasure Valley Rodeo, Inc.
Citations: 129 Idaho 675; 931 P.2d 1193; 1997 Ida. LEXIS 14Docket: No. 22483
Court: Idaho Supreme Court; January 26, 1997; Idaho; State Supreme Court
In a workers’ compensation case, the court addressed whether Caldwell Treasure Valley Rodeo (the employer) was exempt from liability under I.C. 72-212(5), which applies if employment is not conducted for the sake of pecuniary gain. The court concluded that the employer was not exempt because it provided services for which it received remuneration, specifically through admissions to rodeo events. The case involved Don Burrow, an independent welder hired by the employer, who was injured while installing a scoreboard in 1993. The Industrial Commission found that the employer did not meet the exemption criteria, as it generated income from its activities. Although the employer is recognized as a non-profit organization for federal tax purposes, this status does not influence its liability under state law. The court referenced previous rulings, including Modlin v. Twin Falls Canal Co., emphasizing that financial profit or loss is irrelevant to the determination of liability. The court reaffirmed that the key consideration is whether the employer is providing services and receiving remuneration, which was confirmed in Dewey v. Merrill. Ultimately, the court upheld the Commission's decision, awarding the employee benefits, attorney fees, and costs on appeal. The ruling reinforces that non-profit status does not exempt an employer from workers’ compensation liability when remuneration is received for services provided. All justices concurred with the decision.