Justia Labor & Employment Law Opinion Summaries

Harold Caldwell was injured when he fell at an airport where he worked as manager. The airport's insurer, MACo, paid Caldwell's medical and wage-loss benefits. MACo, however, denied Caldwell rehabilitation benefits based on Mont. Code Ann. 39-71-710. Caldwell challenged the constitutionality of the statute on the basis that its categorical termination of benefits based on a claimant's eligibility for social security violated equal protection principles. The Workers' Compensation Court (WCC) agreed, concluding that the statute creates two similarly situated classes and treats them disparately without being reasonably related to a legitimate government interest. MACo appealed. The Supreme Court affirmed, holding (1) the statute creates two similarly situated classes and treats them differently, and (2) the categorical elimination of rehabilitation benefits in the statute based solely on age-defined eligibility for social security does not rationally relate to any governmental interest. Therefore, the statute violates the Equal Protection clause insofar as it deems disabled workers ineligible to receive rehabilitation benefits based on their eligibility for social security benefits.

In the fall of 2008 William Hartford, a high school science teacher, was fired after his Montana teaching certificate expired by his inadvertence in failing to renew it. Hartford sought to file a grievance, alleging that he had been terminated without just cause in violation of a collective bargaining agreement (CBA) entered into between Kalispell School District (District) and the Kalispell Education Association (KEA). The district superintendent, and later the board of trustees, denied Hartford's request, claiming the matter did not constitute a valid grievance under the CBA on grounds that Hartford was not a member of the bargaining unit at any point during his employment in the fall of 2008 and that he was not a "teacher" as defined under Montana law during his employment in the fall of 2008. Hartford and the KEA filed a petition in the district court to compel arbitration as provided in the CBA. The district court granted summary judgment in favor of Hartford and the KEA and ordered the matter submitted to arbitration. The Supreme Court affirmed, concluding that the questions raised by the matter were properly submitted to arbitration.

Plaintiff Leonard Brown entered into an employment agreement with the Yellowstone Club that employed Brown for a term of three years and provided that Brown's employment could be terminated at any time without cause. After six months, the Club terminated Brown's employment without cause. Brown brought an action for damages against the Club under the Wrongful Discharge from Employment Act. The district court granted the Club's motion to dismiss the action based upon Mont. Code Ann. 39-2-912(2), which exempts from the Act an employee covered by a "written contract of employment for a specified term." The Supreme Court reversed the judgment of the district court, holding that if an employment contract for a specific term also allows the employer to terminate at will, it is not a "written contract for a specific term" under Section 39-2-912. Therefore, a discharged employee covered by such a contract is not excluded by the statute from bringing a claim under the Act.

Appellants, 30 Civil Engineering Technician IV employees, sought reclassification of their positions as Civil Engineering Specialist III from the State Department of Transportation ("DOT"). The State Human Resources Division ("SHRD") determined that Technician IV's were correctly classified as pay band five and DOT changed the classification of Civil Engineering Specialist III from band six to band five, although it did not lower the rate of pay. At issue was whether the district court's findings were supported by substantial evidence when it concluded that the Technician IV and Specialist III positions were not required to receive equal pay. The court held that the district court's findings were supported by substantial evidence where the positions' non-predominant duties were different, education requirements were different, minimum professional experience for the positions was different, and there were also differing market demands for each position, as well as collective-bargaining effects for Technician IV positions.