Justia Labor & Employment Law Opinion Summaries

Former engineering professor Plaintiff Habib Sadid appealed the grant of summary judgment in favor of his former employer Defendant Idaho State University which dismissed his retaliation claim. Plaintiff alleged the University retaliated against him because of his comments criticizing the administration that had been published in a local newspaper over several years and that the University had breached his employment contract. Upon review careful review of the issues Plaintiff raised in his appellate brief, the Supreme Court affirmed the judgment of the district court dismissing the amended complaint. The Court vacated the denial of attorney fees to the University and remanded this case for consideration of its request for attorney fees in defending against the breach of employment contract claim.

Defendant Christian Rivas-Del Toro is a Mexican citizen who was residing and working in the United States illegally. In the summer of 2005, he began working as a truck driver for co-defendants Willard, Michael, and Douglas Cranney, who are collectively called "Cranney Farms," the name under which they did business. When he began work for Cranney Farms, Defendant had a valid Mexican chauffeur license. While driving a farm truck, Defendant failed to stop at a stop sign and struck another vehicle in an intersection. He contended that the trailer brakes malfunctioned. Plaintiff Beatriz Nava was driving the other vehicle, and her minor daughter was a passenger. She filed this action seeking to recover for property damage and personal injuries to herself and her daughter. In her amended complaint, she alleged that Cranney Farms was liable because it was the registered owner of the truck and Defendant was driving with Cranney Farms’s permission and that Cranney Farms had recklessly allowed the vehicle to become unsafe to operate. Cranney Farms moved for summary judgment on the ground that pursuant to Idaho Code section 6-1607 it was not liable for the negligence of its employee because he was outside the course and scope of his employment at the time of the accident. After the motion was briefed and argued, the district court held that because Defendant chose a longer route in order to avoid law enforcement because he was in the country illegally, Plaintiffs failed to satisfy Idaho Code section 6-1607(2). It ordered that Cranney Farms was entitled to a judgment dismissing the action as to it. Plaintiffs and Defendant moved for reconsideration, which the court denied. It entered judgment dismissing the action with prejudice as to Cranney Farms, and it certified that judgment as final pursuant to Idaho Rule of Civil Procedure 54(b). Plaintiffs appealed and Defendant cross-appealed. Upon review, the Supreme Court concluded that because the burden never shifted to Plaintiffs to provide evidence regarding their claim of negligent maintenance, the district court erred in granting summary judgment on that claim. Furthermore, the Court found that the ground upon which the trial court dismissed the action against the owners (that Defendant was an employee and was outside the course and scope of his employment) was not a defense to the claims alleged in the complaint, the Court vacated the district court's judgment and remanded the case for further proceedings.

Claimant Floyd Fife appealed a decision of the Industrial Commission that found he had failed to prove that his medical condition requiring back surgery was caused by an industrial accident rather than by pre-existing degenerative changes in his thoracic and lumbar spine. An evidentiary hearing was held before a hearing officer on November 5, 2009, but the hearing officer left the employment of the Industrial Commission before submitting proposed findings of fact and conclusions of law. The Commission then reviewed the record and issued its findings of fact, conclusions of law, and order on June 8, 2010. It found the testimony of Claimantâs surgeon unpersuasive, characterizing it as "unclear, to the point of opacity, as to the actual nature of the injury which he claims is responsible for the need for surgery." When the surgeon had been asked whether he could point to any objective pathological findings in any of the diagnostic studies he had performed on Claimant that related to recent trauma, the surgeon answered that he could not. The Commission found convincing the testimony of the physician who conducted the independent medical examination of Claimant. On appeal, Claimant contended that the Commission erred as a matter of law in rejecting the testimony of his surgeon. Upon review, the Supreme Court concluded that because the Commission, as the trier of fact, was not required to accept the testimony of Claimantâs treating physician, the Court affirmed its decision.

Defendant Four Rivers Packing Company operated an onion packing plant and hired Plaintiff Stuart Mackay as the company's "field man." Plaintiff had been in the onion business for decades and knew many onion farmers. Four Rivers through its general manager Randy Smith (Smith) offered Plaintiff a job that involved purchasing enough onions to keep Four Rivers' packing shed stocked at a price that Smith would set. Plaintiff contended that Smith offered him a long-term employment contract. From 2000 to 2002, financial and managerial setbacks made it difficult for Four Rivers to operate its business, and for Plaintiff to acquire onions at prices set by Smith in order to keep the sheds stocked. In 2003, Four Rivers laid Plaintiff off. Plaintiff filed suit in 2004 alleging breach of the employment contract. At trial following a remand, Four Rivers contended that the parties had not entered into an employment contract for any specified term. A jury would return a verdict in favor of Plaintiff. In a special verdict form, the jury found that the parties had entered into a long term contract of "up to ten years, or such time as the Plaintiff retired." Four Rivers timely appealed, challenging jury instructions given at trial and the sufficiency of the evidence. Upon review of the trial record, the Supreme Court found that the trial court properly instructed the jury and that the evidence presented was sufficient to support the verdict. The Court affirmed the trial court's judgment against Four Rivers.

Appellant Lynnette Patterson argued that she was constructively discharged from her position with the Fraud Unit of the state Department of Health and Welfare (IDHW) due to her complaints about an intra-office romance between her supervisor and a lateral employee. IDHW had a strict policy regarding romantic relationships between supervisors and employees. Ms. Patterson made multiple complaints regarding the relationship which she alleged resulted in her first negative performance review with the IDHW, culminating in a "constructive discharge." In 2007, she filed a complaint with the Human Rights Commission (IHRC) then with the district court. The court granted summary judgment to the IDHW, finding that Ms. Patterson did not file her claim within a proscribed 180 day period following her initial complaint, and that she failed to demonstrate that her complaint was a "protected activity" in order to sustain her claim. On appeal to the Supreme Court, Ms. Patterson argued that the district court erred in its determination. Upon consideration of the trial record, the Supreme Court affirmed the district court's decision, concluding that the evidence presented at trial was sufficient to support the dismissal of Ms. Patterson's case.

Appellants David and Marsha Steed are the former employers of Claimant Marsha Fearn. Ms. Fearn resigned from her job in April 2009, and sent an email with her personal contact information to approximately 7500 of the Steedsâ sales contacts. Upon finding out about this email, the Steeds terminated Ms. Fearn's employment. A state Department of Labor (DOL) appeals examiner and the Industrial Commission (Commission) both determined that the Steeds failed to show that Ms. Fearn was discharged for misconduct. The Steeds appealed the decisions of both the DOL and the Commission. Upon consideration of the record and the applicable legal authority, the Supreme Court found that the DOL's and Commission's decisions were supported by substantial and competent evidence. The Court affirmed the decisions.