In 2019, Cameron DeMott Tyler was severely injured while working for Masterpiece Floors, Inc., in Boise, Idaho, when a table saw without a safety guard caused the amputation of his right index finger and severe damage to the other fingers on that hand. He later won a default judgment of $380,159 after the employer failed to defend against a civil lawsuit. In 2025, the Idaho Supreme Court ruled the district court did have subject-matter jurisdiction to decide whether Tyler’s injury fell under an exception to the workers’ compensation “exclusive remedy” rule and ordered the default judgment reinstated.
Legal Accountability and Public Safety
The court’s decision shows that, despite the workers’ compensation system, Idaho law provides narrow circumstances in which employees can also file a civil lawsuit. The court held that conduct like requiring an employee to operate unsafe equipment without required safety guards may amount to willful or unprovoked physical aggression and thus fall outside the exclusive protections usually granted to employers under the workers’ compensation system.
Compensation and Recovery
Tyler’s case resulted in a judgment of just over $380,000. This sum was calculated based on his medical expenses, permanent disability, lost income, and other damages created by the significant loss of function in his hand. In cases of workplace injury resulting from egregious negligence, such as failing to provide safety guards, injured workers may recover compensation that reflects both the tangible and long-term effects of their physical loss and suffering.
Legal Framework in Idaho
Under Idaho law, the exclusive remedy provision usually bars an injured employee from bringing a civil suit if the matter is already addressed through workers’ compensation. However, Idaho Code § 72-209(3) has an exception for “willful or unprovoked physical aggression.” This means that if the employer’s actions are found to meet that standard, the injured worker can bring a separate civil lawsuit. In Tyler’s case, the Supreme Court determined that a district court could decide whether this exception applies even while the workers’ compensation claim is still pending.
Cases like Tyler’s illustrate that the law can provide paths to justice even when official compensation systems are already in play. When an employer’s conduct goes beyond inadvertence and when safety requirements are ignored and harm results, workers may be able to recover more complete compensation through civil claims. For anyone in Idaho facing similar circumstances, consulting with a knowledgeable attorney can be essential to understand all legal options, protect their rights, and secure the full recovery they deserve.
Source: https://isc.idaho.gov/opinions/51520.pdf
