Justia Labor & Employment Law Opinion Summaries

Appellant, a vocational agricultural teacher at a high school, served as faculty advisor for the school's chapter of the National FFA Organization. Appellant obtained a loan on behalf of the school FFA and opened a checking account into which she deposited the loan proceeds. Because Appellant did not deposit the funds in an account maintained by the school district, Appellant violated the school district financial policy and was suspended. Appellant then made out a check to herself to purportedly reimburse herself for expenses incurred in setting up a hay cutting business. The Board of Trustees subsequently terminated Appellant's employment. The Montana Department of Labor and Industry determined that Appellant was eligible to receive benefits, but a hearing officer concluded that Appellant had been discharged for misconduct and was ineligible to receive unemployment insurance benefits. The Board of Labor Appeals affirmed the determination. The Supreme Court affirmed, holding that Appellant's actions constituted misconduct, and she was therefore ineligible to receive unemployment insurance benefits. View "Roberts v. State Bd. of Labor Appeals" on Justia Law

After leaving her job as a bus driver, Plaintiff applied for unemployment benefits with the Montana Department of Labor and Industry. The Department determined that Plaintiff was not qualified to receive unemployment benefits. The Boar of Labor Appeals affirmed. Plaintiff subsequently filed a petition for review in the district court. The district court denied Plaintiff's petition for failure to comply with Rule 2 of the Montana Uniform District Court Rules because Plaintiff had not filed a supporting brief or stated issues of law for review. The Supreme Court reversed, holding that the district court erred when it denied Plaintiff's petition for failure to include a supplemental brief because the provisions of Rule 2 do not apply to a petition for judicial review. View "Jacky v. Avitus Group" on Justia Law

Plaintiff worked for Union Pacific Railroad Company as a locomotive engineer until his retirement in 2008. After an MRI showed evidence that Plaintiff suffered from a degenerative disc disease, Plaintiff filed a report of personal injury with Union Pacific. Three years later, Plaintiff filed a complaint against Union Pacific under the Federal Employers' Liability act (FELA) for the back and leg injuries he allegedly sustained during his employment. Union Pacific filed a motion for summary judgment arguing that Plaintiff's claim was time-barred under FELA's three-year statute of limitations because Plaintiff sought medical help as early as 2000. The district court granted Union Pacific's motion. The Supreme Court affirmed, holding that Plaintiff's claim was time-barred, and Union Pacific was entitled to judgment as a matter of law. View "Bridgman v. Union Pac. R.R. Co" on Justia Law

Appellant worked at Pine Hills Youth Correctional Facility as a correctional officer for approximately three years. Appellant worked in the sex offender unit during the majority of her employment with Pine Hills. After quitting her job, Appellant filed an action against Pine Hills for sexual harassment, hostile work environment, and retaliation. After a bench trial, the district court entered judgment for Pine Hills on all claims. The Supreme Court affirmed, holding (1) substantial credible evidence supported the district court's determination that Pine Hills held open an offer for Appellant to transfer units for one year until Appellant quit; (2) the district court correctly determined that Pine Hills reasonably and promptly offered a solution to end one inmate's harassment of Appellant; and (3) the district court correctly dismissed Appellant's retaliation claim against Pine Hills. View "Puskas v. Pine Hills Youth Corr. Facility" on Justia Law

Employee contracted an occupational disease arising out of her employment with Employer. In 2006, Employee began seeking medical treatment. Employee received treatment periodically until 2011 when her doctor informed her that she had an occupational disease. Employee subsequently initiated a workers' compensation claim. Montana State Fund denied Employee's claim, asserting that the claim was not timely filed under the twelve-month statute of limitations. Employee appealed. The Workers' Compensation Court granted summary judgment for State Fund, concluding that the undisputed facts demonstrated that Employee knew or should have known that she was suffering from occupational disease as early as 2006. The Supreme Court reversed, holding that a material question of fact existed as to when Employee should have known she was suffering from an occupational disease. Remanded for a trial to determine when Employee knew or should have known she was suffering from an occupational disease. View "Dvorak v. State Fund" on Justia Law

Plaintiff injured his shoulder while working for his employer, who was insured by the Montana State Fund. The State Fund paid for Plaintiff's two shoulder injuries and paid temporary total disability (TTD) benefits after informing Plaintiff that if he returned to gainful employment without the State Fund's knowledge and continued to receive benefits, he would be subject to legal action or criminal prosecution. After the State Fund discovered that Plaintiff had built and sold furniture and worked at a vacuum cleaner store while receiving TTD benefits, the assistant attorney general charged Plaintiff with theft, a felony. The State Fund subsequently terminated Plaintiff's TTD benefits. Plaintiff filed suit against the State fund and its private investigators, alleging that Defendants violated Montana's Insurance Code regarding unfair claim settlement practices and pleaded a variety of common law causes of action. The district court ruled in favor of Defendants. The Supreme Court affirmed the district court's entry of judgment in favor of the State Fund, holding that the district court did not err in (1) granting the State Fund's motion to dismiss Defendant's claims under the Insurance Code; and (2) granting the State Fund's motion for summary judgment regarding Plaintiff's common law claims. View "White v. State ex rel. Mont. State Fund" on Justia Law

Employee was fired by employer after allegations that Employee had a sexual relationship with a co-worker. Employee was found eligible to receive unemployment benefits. The Board of Labor Appeals affirmed. Employee subsequently filed this suit, alleging that Employer discharged him in violation of the Wrongful Discharge From Employment Act. After a trial, the jury found Employer did not wrongfully terminate Employee. The Supreme Court affirmed, holding that the district court did not err in (1) failing to grant summary judgment to Employee on liability and allowing Employer to proceed to trial on the question of whether it had good cause to discharge Employee; (2) failing to sanction Employer for discovery abuse and destruction of evidence; (3) denying Employee's motion to amend the pleadings to add a claim for punitive damages; (4) allowing Employer's expert witness to testify, as she did not testify as to ultimate issues of fact and law; and (5) allowing witnesses to testify to rumors heard at the workplace about Employee. View "Cartwright v. Scheels All Sports, Inc." on Justia Law

Plaintiff worked for Employer as a construction site supervisor. When Plaintiff left Montana for a vacation, a group of employees complained about Plaintiff as their supervisor. After an investigation, Employer terminated Plaintiff's employment. Plaintiff filed an action alleging that Employer violated the Montana Wrongful Discharge from Employment Act. The district court granted summary judgment for Employer. The Supreme Court affirmed, holding (1) the district court properly concluded that Employer had good cause to terminate Plaintiff's employment; (2) Employer properly considered hearsay evidence in deciding to terminate Plaintiff's employment; (3) the district court properly considered employee statements contained in reports in concluding that Employer had good cause to terminate Plaintiff's employment; and (4) the district court properly concluded that Employer did not violate the provisions of its employee handbook when it terminated Plaintiff's employment. View "Sullivan v. Continental Constr. of Mont., LLC " on Justia Law

Plaintiff suffered an injury in the course and scope of her employment with Employer. Employer's insurer (Insurer) accepted liability for Plaintiff's injury and paid wage loss and medical benefits. Plaintiff was later informed that Insurer would no longer approve or cover the expense of the pain patches she had been using for several years. Plaintiff filed a petition for expedited declaratory relief to reinstate medical benefits, seeking reinstatement of medical benefits for the pain patches as well as attorneys' fees and penalties. The Workers Compensation Court (WCC) determined that Plaintiff was entitled to continued payment of benefits for the pain patches but denied Plaintiff's request for attorneys' fees and for payment of the statutory penalty. The Supreme Court affirmed, holding that the WCC did not err (1) in determining Plaintiff was entitled to continued payment for the pain patches; (2) in determining Plaintiff was not entitled to reimbursement for her attorneys' fees; and (3) when it failed to impose the statutory penalty on Insurer. View "Stewart v. Liberty Northwest Ins. Corp." on Justia Law

After Employee failed to ask a shopper for a loyalty card per Employer's policy, Employee was fired. Employee brought a wrongful discharge claim against Employer under Montana's Wrongful Discharge From Employment Act (WDEA). Employee accepted Employer's offer to arbitrate the dispute because she said Mont. Code Ann. 39-915 would force her to pay Employer's attorney fees if she declined the offer and later lost at trial. Employee then successfully moved to amend her complaint to add destruction of evidence and declaratory judgment claims, alleging, inter alia, that section 39-2-915 was unconstitutional. The district court subsequently dismissed Employee's amended complaint, concluding that it had lost jurisdiction over Employee's claim once she accepted the offer to arbitrate. The court also ruled that 39-2-915 was constitutional. The Supreme Court (1) affirmed the dismissal of Employee's amended complaint, as the court lost its ability to consider Employee's claim once she agreed to arbitration; and (2) set aside the district court's determination of Employee's constitutional claim, as the court lost its authority to act further once Employee agreed to arbitrate. View "Ensey v. Mini Mart, Inc." on Justia Law