Justia Labor & Employment Law Opinion Summaries

While claimant-appellant Judith Weible was employed by Safeway, Inc., she requested time off because she had to have surgery. Safeway granted her request and agreed to hold her job until she was able to return to work, which she intended to do. She was gone for approximately six weeks. While on leave, claimant applied for unemployment benefits. She was denied because during her leave of absence she was still employed, even though she was not working. An appeals examiner upheld the denial, and the Industrial Commission upheld the appeals examiner. Finding no reversible error, the Supreme Court affirmed the Industrial Commission. View "Weible v. Dept of Labor" on Justia Law

Before 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. View "Mayer v. TPC Holdings, Inc." on Justia Law

Claimant Amanda Wilson filed a complaint under the Worker’s Compensation Act to obtain benefits for a back injury that she alleged was caused or aggravated in the Spring of 2011. On February 15, 2008, Claimant had visited an emergency room in a hospital in Gilbert, Arizona, complaining that for one year she had back pain and right leg radiculopathy with a recent flare-up. On October 4, 2010, Claimant sought additional treatment for her low-back pain and right-leg sciatica at a health clinic in Twin Falls. On February 7, 2011, Claimant began working for Employer Conagra Foods Lamb Weston in Twin Falls. She had previously worked at Employer’s premises as an employee of a temp agency, performing general manual labor, including shoveling potatoes. On April 5, 2011, Claimant visited a nurse practitioner because of back pain. Claimant described bilateral sciatic pain radiating to her heel that had begun six months earlier. On April 6, 2011, Claimant sought medical care at a hospital emergency room in Twin Falls. She complained of increasing low-back pain over the prior three weeks, which initially started while shoveling potatoes while working for Employer. On April 8, 2011, Employer learned from the hospital and physician of Claimant’s trip to the emergency room regarding a work injury. Employer immediately suspended Claimant pending further investigation of whether she had violated its safety policies (to notify the Plant Manager of any injury, "regardless of how minor it may be at the time"). Employer contacted the emergency-room physician, and he was adamant that Claimant had reported to him that she was injured at work and that his notes so reflected. On April 13, 2011, Claimant visited another physician because of low-back pain and numbness in her legs. Employer terminated Claimant on April 18, 2011, for misconduct by failing to report an on-the-job injury in violation of the employee handbook. Claimant filed for unemployment compensation, but her claim was denied on the ground that her knowing violation of the policy constituted misconduct in connection with her employment. Claimant then applied for workers' compensation benefits. The matter was heard before a referee, who submitted proposed findings of fact, conclusions of law, and recommended order. The Industrial Commission declined to adopt the referee’s recommendation and issued its own findings of fact, conclusions of law, and order, finding that Claimant had failed to prove that she suffered an injury caused by an accident arising out of and in the course of her employment. Claimant appealed, but finding no reversible error in the Commission's decision, the Supreme Court affirmed. View "Wilson v. Conagra Foods Lamb Weston" on Justia Law

Claimant Clarence Copper was an employee of Ace Hardware / Sannan, Inc. from 2004 until he was terminated in 2014. Prior to termination, Claimant was reprimanded numerous times for failing to perform his job duties. Claimant appealed an order of the Industrial Commission that the he was not entitled to unemployment benefits because he was discharged for misconduct in connection with his employment for violating his employer’s written policies. Finding no reversible error after review of the record, the Supreme Court affirmed the Commission's order. View "Copper v. Ace Hardware" on Justia Law

Kelli Sevy sustained a work-related injury on October 31, 2006, and contended that she was totally and permanently disabled. The Industrial Commission found that Sevy failed to meet her burden of establishing total and permanent disability. Although the Commission found that Sevy was “profoundly disabled,” the Commission held that Sevy had failed to demonstrate that the accident contributed to her disability beyond a 2% permanent partial impairment (PPI). Sevy argued on appeal that the Commission’s decision that she did not suffer disability in excess of her impairment is not supported by substantial and competent evidence. Finding no reversible error, the Supreme Court affirmed. View "Kelli Sevy v. SVL Analytical, Inc." on Justia Law

Plaintiff-appellant Jeffrey Huber brought this action against his former employer, Lightforce USA, Inc. (“LFUSA”), for breach of contract and failure to pay wages. Huber’s claims centered on two employment agreements: a Company Share Offer (“CSO”), and a Deed of Non-Disclosure, Non-Competition and Assignment (“NDA”). Huber claimed that upon his termination LFUSA was obligated to pay him the value of 30% of the goodwill of LFUSA under the CSO and twelve months’ pay under the NDA. The parties agreed that the CSO was a deferred compensation plan and was, therefore, governed by the Employee Retirement Income Security Act (“ERISA”). At a bench trial, Huber succeeded only on his breach of contract claim under the NDA. Huber timely appealed the district court’s rulings on summary judgment: (1) holding that the amount owed under the NDA was not wages under the Idaho Wage Claims Act, (2) dismissing his wrongful termination claim, and (3) holding that the CSO was a “top hat” plan under ERISA and, therefore, exempt from ERISA’s vesting and anti-forfeiture provisions. Huber also appealed the district court’s ruling at trial that Huber forfeited the benefit under the CSO, and the district court’s rulings on post-trial motions: (1) denying his claim for equitable relief, (2) calculating Huber’s award of prejudgment interest, and (3) awarding attorney fees and costs to LFUSA. The Supreme Court affirmed the district court in part and reversed in part, finding: (1) the CSO was a top hat plan under ERISA and that Huber forfeited the benefit under the CSO; (2) it was proper to deny Huber’s claim for equitable relief and denying Huber’s motion to amend his complaint to conform to the evidence; (3) the district court erred by ruling that the amount owed under the NDA was not "wages" under the Idaho Wage Claims Act; (4) the district court erred with respect to prejudgment interest and costs and fees to LFUSA. The case was remanded back to the district court to treble the $180,000 judgment. Post-judgment interest shall accrue on the trebled amount of $540,000 from December 10, 2013, the date of entry of the judgment. View "Huber v. Lightforce USA, Inc." on Justia Law

In 2013, claimant Scott Chadwick filed a complaint with the Industrial Commission seeking benefits under the Worker’s Compensation Law from his employer, Multi-State Electric, LLC, and its surety, Idaho State Insurance Fund. Claimant alleged that he had suffered back injuries as a result of two separate accidents at work in 2012. The matter was tried to a referee, but the Commission did not adopt the referee’s recommendations. After considering the Claimant’s prehearing deposition, the testimony presented during the evidentiary hearing before the referee, and the exhibits, the Commission issued its findings of fact, conclusions of law, and order. The Commission found that Claimant failed to prove that he suffered an injury from a workplace accident in a May event and that he failed to prove that a July event occurred. The Commission alternatively found that he had failed to provide timely notice to his employer of both claimed accidents, and that he failed to prove that Employer was not prejudiced by the failure to give timely notice. Therefore, he was denied benefits. Claimant then timely appealed. Finding no reversible error, the Supreme Court affirmed the Commission. View "Chadwick v. Multi-State Electric, LLC" on Justia Law

Claimant Barbara Kelly was an employee of Blue Ribbon Linen Supply, Inc. when a cart rolled over her left foot. She filed for workers’ compensation benefits. Kelly sustained additional injuries in an automobile accident when returning home from an Independent Medical Evaluation (IME) scheduled by the Idaho State Insurance Fund (Surety) in connection with the cart incident. The Industrial Commission concluded that Kelly’s injuries from the automobile accident were not compensable because they did not arise out of and in the course of her employment with Blue Ribbon. The Supreme Court concluded after review that the causal connection between Kelly’s employment and the injuries she sustained as a result of the accident was sufficiently compelling that it held that the injuries arose out of and in the course of her employment. Accordingly, the Court reversed the Commission’s decision and remanded for further proceedings. View "Kelly v. Blue Ribbon Linen Supply, Inc." on Justia Law

Joseph Talbot worked at Desert View Care Center as a nurse and was discharged due to a Facebook post that Desert View found violated its Social and Electronic Media Conduct Policy. Talbot applied for unemployment benefits, and an Idaho Department of Labor Appeals Examiner awarded him benefits. The Idaho Industrial Commission reversed, concluding that Talbot engaged in employment-related misconduct. Talbot appealed, arguing that Desert View never communicated its Social Media Policy to him. Finding no reversible error, the Supreme Court affirmed the Industrial Commission's decision. View "Talbot v. Desert View Care Center" on Justia Law

Internet Auto Rent & Sales, Inc., an automobile dealership, hired Tina Venable as an Internet Manager in 2011. Venable stated that after she began working for Internet Auto, she observed violations of the Idaho Consumer Protection Act (ICPA) and the federal Truth in Lending Act. Venable said she reported her concerns to the General Sales Manager and other members of the management team but was first told that she should mind my own business and was later told that "this is how ‘we do business’ and to get on board or words to that affect." Venable claimed that “[s]hortly after reporting the deceptive acts and practices to [the General Sales Manager],” she “discovered” that her “access to key programs used by the dealership had been denied which made it more difficult” for her “to complete sales transactions on behalf of Internet Auto.” A little over a month after hiring Venable, Internet Auto discharged her. After her termination, Venable filed a complaint against Internet Auto alleging breach of contract claims, wrongful discharge in violation of public policy, and negligent and intentional infliction of emotional distress. She later filed an amended complaint to additionally allege slander. Internet Auto was granted summary judgment on all of Venable’s claims except for slander and negligent infliction of emotional distress. Venable filed a motion for reconsideration of the wrongful discharge claim, which was denied. At trial, the jury found for Internet Auto on both of her remaining claims. Following the jury verdict, Venable filed a second motion for reconsideration of the wrongful discharge claim, which was denied. Venable timely appealed. Finding no reversible error, the Supreme Court affirmed the grant of summary judgment in favor of Internet Auto. View "Venable v. Internet Auto" on Justia Law