Justia Labor & Employment Law Opinion Summaries

Appellant John Stem was helping to load a forklift at his place of work when another employee backed the forklift over a water meter cover which broke under the weight of the forklift. The forklift toppled and pinned Appellant to the ground, resulting in severe injuries and the amputation of his right leg. He sued Respondent Wesley Prouty, the owner and landlord of the property where the accident occurred, for negligence under a theory of premises liability for failing to keep the premises safe. Appellant alleged that the water meter cover was a light duty cover and was inadequate to support heavy duty vehicles such as forklifts. He later amended his complaint to include a negligence-per-se claim against Respondent for failing to obtain a building permit in violation of city and state codes, which he argued would have likely led to the discovery of the defective water meter cover. The district court granted Respondent's Motion for Partial Summary Judgment, dismissing the negligence claim based on premises liability. Respondent filed a second Motion for Summary Judgment on the negligence-per-se claim which was originally denied by the court. Then, upon Motion for Reconsideration, the court granted Respondent summary judgment. Appellant appealed the judgments in favor of Respondent. Upon review, the Supreme Court found no genuine issues of material facts. Accordingly, the district court did not err in granting summary judgment in favor of Respondent.

On June 28, 2010, Appellant Maria Gomez filed a Worker’s Compensation Complaint with the Industrial Commission (Commission) claiming benefits for an accident that occurred in 2009, when she injured her lower back lifting sixty-pound boxes. The injury occurred at Blackfoot Brass (Dura Mark). Appellant had previously suffered two work-related accidents while working with Dura Mark, one in 2002, the other in 2006, but had returned to work without restrictions after participating in physical therapy for both injuries. The issue before the Supreme Court centered on a Commission order denying reconsideration of Appellant's motion to reopen the record to allow for additional evidence on the issue of causation. The Industrial Commission previously ordered that Appellant had failed to prove the medical treatment she received for a back injury was related to an industrial accident and injury. At the emergency hearing pursuant to the Judicial Rules of Practice and Procedure adopted by the Commission, Appellant introduced evidence regarding her entitlement to reasonable and necessary medical care pursuant to I.C. 72-432, but the referee denied Appellant's claim on the grounds of causation. Upon review, the Supreme Court affirmed the Commission's judgment. In doing so, the Court wanted to provide a "clear message that without a specific stipulation that causation will be a contested issue at the hearing pursuant to I.C. 72-713, and especially if there is a difference of opinion as to causation by opposing parties and their experts, claimant’s attorneys should no longer be lulled by anything other than a stipulation to all legal prerequisites and elements for recovery and be prepared to present evidence of a causal connection between the industrial injury or sickness and the required treatment."

Plaintiff-Counterdefendant-Appellant David Oakes, M.D. was employed as a cardiologist by Defendant-Counterclaimant-Respondent Boise Heart Clinic Physicians, PLLC (BHC) from January 2000 until the end of July 2008, when he left to pursue other employment opportunities. While employed by BHC, Plaintiff had an employment agreement that entitled him to half the adjusted gross charges he generated. Because of his complicated arrangements with other service providers, Plaintiff's final payment was not calculated until after his departure. After his employment ended, Plaintiff corresponded with BHC regarding his final payment. Plaintiff never received payment. Instead, he received a series of letters that detailed the evolving computation of his final payment. BHC's last letter to Plaintiff included a demand for repayment. Plaintiff then sued claiming that BHC still owed him money under the employment agreement. In rendering its verdict, the jury was given a choice between three special verdict forms that corresponded with the three possible verdicts: one finding that neither party is entitled to recover from the other; one that finding that BHC owed money to Plaintiff; and one finding that Plaintiff owed money to BHC. The jury returned with a verdict in favor of Plaintiff, and against BHC, that awarded Plaintiff $2,043.92. Ultimately the district court entered a final judgment that awarded Plaintiff $2,043.92 and declared that neither party was the prevailing party for purposes of costs and attorney fees. Plaintiff appealed the "prevailing party" decision to the Supreme Court. e sought. The district court entered a judgment conferring to Oakes the amount awarded by the jury, but found that neither party was the prevailing party for purposes of costs or attorney fees. Upon review, the Supreme Court held that the district court abused its discretion by not finding Plaintiff to be the prevailing party. The case was remanded for a determination of costs and fees.

Fall River Rural Electric Cooperative hired Plaintiff-Appellant Suzette Bollinger as a cashier and receptionist at its Ashton headquarters in 1988. She was terminated in 2009 despite having satisfactory performance without cause. Plaintiff alleged in her complaint that she signed an employment contract at the time of her hiring, but she failed to produce the contract at trial. In 2009, Fall River adopted an "at-will" employment policy which expressly superseded any prior conflicting policy. Plaintiff ultimately sued Fall River for: (1) breach of express and implied contract, including breach of the covenant of good faith and fair dealing; (2) retaliatory discharge and wrongful termination in violation of public policy; and (3) negligent and intentional infliction of emotional distress. The district court granted summary judgment to Fall River on all of Plaintiff's claims. The district court also denied her motion for reconsideration, and she timely appealed to the Supreme Court. Finding that Plaintiff's claims were properly dismissed, the Supreme Court affirmed the district court's ruling.

Claimant Brooke Stark worked for Assisted Living Concepts, Inc. from 2008 to 2010 as a "residence director" of one of Assisted Living's facilities. Claimant was called into the sales director's office one day, and the two talked about a rumor that one of Assisted Living's other facilities was imminently closing. Later that evening, Assisted Living's divisional director of human resources called Claimant to ask where Claimant heard of the closing rumor. Claimant did not disclose her source. Five minutes following that call, Assisted Living's chief executive officer called Claimant (with the director of HR on the call) to ask about the rumor. Claimant said she talked to a number of people, but that she did not want to share the information. The CEO emphasized the importance of knowing who started the rumor so that the company could reassure those involved that the facility in question would not close. Still declining to reveal her source, the CEO suspended Claimant. The human resources director, after a little investigation, found that Claimant violated company policy by refusing a direct order from her supervisor. Claimant was then terminated in the fall of 2010. The issue before the Supreme Court involved whether Claimant's refusal to respond to the CEO's question. The Industrial Commission held that Claimant's refusal to obey the direct order did not constitute misconduct under the Employment Security Law. The Supreme Court held as a matter of law, Claimant's conduct was indeed misconduct under the Employment Security Law, and reversed the Industrial Commission.

In 2006, Appellant V. J. Magee sustained a work-related injury causing harm to his lumbar spine and impacting the use of his right leg, leaving him in chronic pain. The Idaho Industrial Commission found that Appellant suffered a compensable industrial accident, that he sustained a ten percent permanent partial impairment to the whole body, and sustained a twenty percent permanent partial disability to the whole body. Magee appealed to the Supreme Court, which affirmed the Commission's 2004 decision. While that appeal was still pending, Appellant filed a second complaint with the Commission, arguing that the Commission's 2004 decision should be modified because of a change in his condition. The Commission held a second hearing, additional evidence was presented, and the Commission issued a final decision, concluding that Appellant failed to prove that a change in condition had occurred. The Commission also found that its earlier 2004 decision did not result in manifest injustice and that the benefit claims, which were previously litigated, were barred by res judicata. Upon review, the Supreme Court concluded that Appellant failed to establish a change in condition, that the 2004 decision did not result in manifest injustice, and that the issues regarding his medical benefits were barred under res judicata.

Plaintiff-Appellant Dr. John Noak was dismissed as the medical director for Prison Health Services, Inc. (PHS). He appealed the district court's grant of summary judgment in favor of the Idaho Department of Correction (IDOC) on claims of breach of an implied covenant of good faith, intentional and negligent infliction of emotional distress, defamation, and intentional interference with contract. A 2004 investigation into how Plaintiff treated a female inmate at an IDOC facility lead to IDOC demanding that PHS replace Plaintiff as medical director. Finding no error in the district court's judgment, the Supreme Court affirmed the grant of summary judgment in favor of IDOC.

Respondent-Appellant Pneumotech, Inc. appealed the Industrial Commission's determination that its former employee, Petitioner-Appellee Angela Hopkins, was eligible for unemployment benefits. Pneumotech hired Petitioner as a bookkeeper and receptionist on July 3, 1995. She worked at Pneumotech until June 22, 2010, when her supervisor fired her. The same month, Petitioner filed a claim for unemployment benefits with the Idaho Department of Labor. At the hearing, Pneumotech presented testimony that Petitioner was discharged because: (1) for two years she had been habitually late for work; (2) she took time off without supervisor permission; (3) she took sick time off but went to the water park instead; (4) she spent time at work playing video games and talking on her cell phone; and (5) she failed to help train a new employee when asked. Petitioner denied all of these accusations, including that her supervisor had repeatedly warned her that her conduct was unacceptable. In fact, the supervisor testified that Petitioner never received a written warning or suspension, and in January 2009, she received a $2-per-hour raise. Upon review, the Supreme Court found that the Commission did not abuse its discretion or violate Pneumotech's right to procedural due process in denying the company's request for a new hearing. Furthermore, substantial and competent evidence supported the Commission's decision to uphold Petitioner's award of unemployment benefits. Accordingly, the Court affirmed.

Claimant-Appellant Dennis Current appealed the Idaho Industrial Commission's denial of his unemployment benefits. Claimant argued that the Commission erred in finding he willfully made a false statement, and in failing to call one of his witnesses. The Department of Labor argued the Commission's findings were supported by substantial and competent evidence. The Supreme Court found that there was indeed substantial and competent evidence to support the Commission's findings that Claimant willfully made a false statement. The Court also found that the hearing officer did not abuse her discretion in finding that one of Claimant's witnesses would not provide relevant testimony. Accordingly, the Court affirmed the Commission's decision.

In Plaintiff T.J.T., Inc.'s second appeal from a summary judgment in favor of Defendant Ulysses Mori, in which the district court found that the non-competition agreement Mori allegedly breached was unenforceable under California law. This case arose from the execution of a non-competition agreement between TJT and Mori in connection with the sale of Mori’s business, Leg-It Tire Company, Inc., to TJT in 1997. Leg-It owned and operated one production facility in Woodland, California. TJT also operated in the tire and axle recycling business, and it had recycling facilities in Idaho, Oregon, and Washington at the time it purchased Leg-It in 1997. At the time of the sale of Leg-It, Mori was hired as the "Senior Vice President and General Manager of the Leg-it Tire Company Division of [TJT]." In 2000, Mori moved to Idaho and took a new position as Corporate Sales Manager. In 2007, Mori resigned as an employee of TJT and several days later, was hired by West States Recycling, Inc., a competitor to TJT, as a tire and axle salesman. In his employment with West States, Mori facilitated the opening of a warehouse facility in Idaho to support local Idaho customers who purchase tires and axles, and also solicited tire and axle business in Oregon, Washington, California, and Idaho. Because the Supreme Court in its review found that the district court erred in failing to consider whether and to what extent the agreement could be "blue penciled" to make it enforceable, the Court vacated the summary judgment and award of attorney fees and remanded the case for further proceedings.