Justia Labor & Employment Law Opinion Summaries

Michael Richardson was injured while working, and attempted to recover personal injury damages outside of the worker’s compensation system. Hayden Homes subcontracted with Z&H Construction, LLC, Plumbing Unlimited, LLC, and Alignment Construction, LLC for various aspects of a new construction project. Richardson was employed by Alignment, and worked on Hayden’s construction project. He was injured when he fell through a crawl space cover at the construction site. He received a worker’s compensation award from the worker’s compensation insurer for his direct employer, Alignment. After Richardson received his worker’s compensation award, he sued Z&H, Hernandez Framing, LLC (a subcontractor of Z&H), and Plumbing Unlimited (collectively, “Respondent LLCs”), alleging negligence in the construction of the crawl space cover. The district court granted the Respondent LLCs’ motion for summary judgment, determining that the Respondent LLCs were Richardson’s statutory co-employees and immune from suit pursuant to Idaho Code section 72- 209(3). Finding no reversible error in that reasoning, the Idaho Supreme Court affirmed the district court’s order granting summary judgment. View "Richardson v. Z&H Construction, LLC" on Justia Law

Siranoush Hiatt appealed an Idaho Industrial Commission decision that affirmed the Idaho Department of Labor’s denial of her request for unemployment benefits. The Commission determined that Hiatt was ineligible for benefits because she was terminated from Health Care Idaho Credit Union (“HCICU”) for workplace-related misconduct. After review, the Idaho Supreme Court affirmed based on the substantial evidence in the record which supported the Commission’s decision. View "Hiatt v. Health Care ID Credit Union" on Justia Law

Francisca Gomez died as the result of a horrific industrial accident that occurred while she was cleaning a seed sorting machine as part of her employment with the Crookham Company (“Crookham”). Her family (the Gomezes) received worker’s compensation benefits and also brought a wrongful death action. The Gomezes appealed a district court’s grant of summary judgment to Crookham on all claims relating to Mrs. Gomez’s death. The district court held that Mrs. Gomez was working within the scope of her employment at the time of the accident, that all of the Gomezes’ claims were barred by the exclusive remedy rule of Idaho worker’s compensation law, that the exception to the exclusive remedy rule provided by Idaho Code section 72-209(3) did not apply, and that the Gomezes’ product liability claims fail as a matter of law because Crookham is not a “manufacturer.” The Idaho Supreme Court determined that given the totality of the evidence in this case, which included prior OSHA violations for similar safety issues, the district court erred by failing to consider whether Crookham consciously disregarded information suggesting a significant risk to its employees working at or under the picking tables, which were neither locked nor tagged out, as they existed on the date of the accident. On this basis, the decision of the district court granting summary judgment to Crookham was reversed and the matter remanded for the trial court to apply the proper standard for proving an act of unprovoked physical aggression, and to determine whether there was a genuine issue of material fact as to whether Crookham consciously disregarded knowledge of a serious risk to Mrs. Gomez. View "Gomez v. Crookham" on Justia Law

Primera Beef, LLC appealed a district court’s grant of summary judgment in favor of Allan Ward. Primera Beef alleged Ward breached the confidentiality provision of a settlement agreement between him and Primera Beef when Ward’s attorney disclosed the terms of the agreement to a prosecutor in a related criminal action. Ward moved for summary judgment, arguing that he was not liable for his attorney’s actions because his attorney was not acting within the scope of his authority when he disclosed the terms. The district court agreed. The Idaho Supreme Court concurred and affirmed the district court. View "Primera Beef v. Ward" on Justia Law

Francisca Gomez died as the result of a horrific industrial accident while she was cleaning a seed sorting machine as part of her employment with the Crookham Company (“Crookham”). Her family (the Gomezes) received worker’s compensation benefits and also brought a wrongful death action. The Gomezes appealed the district court's decision to grant Crookham’s motion for summary judgment on all claims relating to Mrs. Gomez’s death. The district court held that Mrs. Gomez was working within the scope of her employment at the time of the accident, that all of the Gomezes’ claims were barred by the exclusive remedy rule of Idaho worker’s compensation law, that the exception to the exclusive remedy rule provided by Idaho Code section 72-209(3) did not apply, and that the Gomezes’ product liability claims failed as a matter of law because Crookham was not a “manufacturer.” In affirming in part and reversing in part, the Idaho Supreme Court determined the trial court erred when it failed to consider whether Crookham committed an act of unprovoked physical aggression upon Mrs. Gomez by consciously disregarding knowledge that an injury would result. As such, the matter was remanded to the district court for further proceedings. View "Gomez v. Crookham" on Justia Law

In December 1995, Brian Trumble entered into a Career Agent’s Contract (“Agent Contract”) with Farm Bureau Mutual Insurance Company of Idaho. Under the Agent Contract, Trumble was an independent contractor who procured insurance from interested buyers on Farm Bureau’s behalf. The Agent Contract included a non-competition clause. This case was about whether Trumble could collect service bonus commissions that were credited to him during his career, but which became forfeitable after his termination if he competed with Farm Bureau within one year of the termination. In addition, this case is about Farm Bureau’s counterclaims against the agent, alleging the agent misappropriated trade secrets and intentionally interfered with Farm Bureau’s prospective economic advantage after his termination. The district court held that Trumble forfeited his commissions by competing with Farm Bureau in violation of the one-year non-competition requirement. And the district court held that the agent was blameless for his actions after termination and dismissed Farm Bureau’s counterclaims. After review, the Idaho Supreme Court agreed, affirming the district court’s judgment dismissing the agent’s claims and the insurance company's counterclaims. View "Trumble v. Farm Bureau" on Justia Law

This case arose out of the termination of Ryan and Lanie Berrett (“the Berretts”) from their jobs with Clark County School District No. 161 (the “School District”), and raised issues regarding the “law of the case” doctrine, the Idaho Protection of Public Employees Act (“Whistleblower Act”), and wrongful termination in violation of public policy. The Berretts sued the School District, alleging that both of their terminations were in retaliation for Ryan Berrett reporting a building code violation to the School District’s board of trustees (the “board”). The district court granted the School District’s motion for summary judgment, finding that Ryan Berrett did not engage in a protected activity under the Whistleblower Act, and that Idaho’s public policy did not extend to protect Lanie Berrett in a termination in violation of public policy claim. The district court also denied the Berretts’ motion for reconsideration. The Berretts timely appealed. The Idaho Supreme Court concluded after review the law of the case doctrine did not preclude the district court from considering the School District’s motion for summary judgment, however, the Court erred in granting summary judgment on Ryan Berrett’s Whistleblower Act claim; the Court found genuine issues of material fact regarding whether Ryan Berrett engaged in a protected activity and causation. The trial court did not err in granting summary judgment on Lanie Berrett’s termination in violation of public policy claim. The matter was remanded for further proceedings. View "Berrett v. Clark County School District" on Justia Law

Dale Johnson maintained roller coasters for Silverwood, Inc. Among rising contentions and a dispute with Silverwood’s new director of construction and maintenance, Johnson resigned his position on June 8, 2015. He subsequently applied for unemployment benefits, but his claim was denied. Johnson challenged the denial with the Appeals Bureau of the Idaho Department of Labor, and a hearing was held on August 5, 2015. When denied again, Johnson appealed to the Industrial Commission. While the appeal was pending, Johnson learned that his hearing’s recording was lost. The Industrial Commission remanded the case to the Appeals Bureau for a new hearing. Ultimately, after two additional hearings and a second appeal to the Industrial Commission, Johnson won his claim for benefits with the Commission finding that Johnson was eligible for benefits. Johnson subsequently filed suit against the Department of Labor for unnecessary delays and other alleged improprieties in the handling of his claim. The district court dismissed the case for failure to file a notice of tort claim pursuant to the Idaho Tort Claims Act and then denied Johnson’s post-judgment motions. Finding no reversible error in the district court’s judgment, the Idaho Supreme Court affirmed the district court. View "Johnson v. Idaho Dept of Labor" on Justia Law

Mario Ayala was injured while driving a company truck in 2009, and was injured again in 2013 after falling from a ladder. After the hearing, but before the referee issued “recommended findings and determination” in accordance with Idaho Code section 72-717, the Industrial Commission reassigned the case to itself over Ayala’s objection. Citing the referee’s backlog of cases and a need for efficiency, the Industrial Commission issued an order finding that Ayala’s low-back condition was not causally related to his 2009 truck wreck, that he was not totally and permanently disabled under the odd-lot worker doctrine, and that he suffered disability of 40% of the whole person inclusive of impairment of his 2009 and 2013 industrial accidents. The Idaho Supreme Court set aside the Commission’s findings of fact, conclusions of law and order because Ayala was denied due process when the Industrial Commission reviewed Ayala’s claims and issued a decision without the referee’s recommended findings and determination. The Court also set aside the Industrial Commission’s post-hearing order on motion for reconsideration and order on motion for reconsideration, modification and consolidation, and remanded this matter for a new hearing. View "Ayala v. Meyers Farms" on Justia Law

At issue in this case was whether Brent Austin filed a timely complaint for additional worker's compensation benefits with the Idaho Industrial Commission when it was filed more than a year after his employer, Bio Tech Nutrients, and its surety, Employers Compensation Insurance Company, (collectively “Defendants”) stopped paying worker’s compensation benefits. The Commission held that the one-year statute of limitations to file a complaint was tolled because the Defendants did not send a Notice of Claim Status (“NOCS”) when they submitted Austin’s final payment; as such, the Commission concluded Austin’s complaint was timely filed. After review, the Idaho Supreme Court determined the Commission was correct in tolling the statute of limitations, and affirmed. View "Austin v. Bio Tech Nutrients" on Justia Law