Justia Labor & Employment Law Opinion Summaries

The Supreme Court reversed the judgment of the circuit court affirming the decision of the South Dakota Department of Labor and Regulation (Department) concluding that it lacked jurisdiction over Plaintiff's claim seeking workers' compensation benefits, holding that the Department had the authority to adjudicate Plaintiff's claim.Plaintiff was injured in Wyoming while working at a job for Defendant, a corporation formed and headquartered in South Dakota. Plaintiff applied for and received workers' compensation benefits in Wyoming. Later, Plaintiff sought benefits in South Dakota, which has more favorable workers' compensation statutes. The South Dakota Department of Labor and Regulation dismissed the petition, concluding that it lacked jurisdiction. The circuit court affirmed. The Supreme Court reversed, holding that South Dakota had a substantial connection to the parties' employment relationship sufficient to provide the Department with authority to adjudicate Plaintiff's claim. View "Anderson v. Tri State Construction, LLC" on Justia Law

The Supreme Court affirmed the judgment of the circuit court affirming the decision of the Department of Labor and Regulation determining that a copy of a letter to Appellant's insurer seeking a review of his workers' compensation benefits did not constitute a petition for a hearing, holding that the Department and the circuit court did not err.Appellant injured his left and right shoulder at work. Western National Insurance (Insurer), the workers' compensation for Appellant's employers, paid workers' compensation benefits. Five years later, Appellant sent a letter to Insurer seeking a review of his workers' compensation benefits and sent a copy of this letter to the Department requesting that the Department determine that the letter constituted a petition for hearing. The Department concluded that the letter was not a petition for hearing because it lacked the information required by ARSD 47:03:01:02. The circuit court affirmed. The Supreme Court affirmed, holding that the circuit court did not err in concluding that Appellant's letter did not satisfy ARSD 47:03:01:02. View "May v. Spearfish Pellett Co." on Justia Law

The Supreme Court affirmed the judgment of the circuit court reversing the decision of the Department of Labor denying Taylor Hughes's workers' compensation claim for an alleged work-related back injury, holding that the circuit court correctly held that Hughes was entitled to recover for his injury.After a hearing, the Department determined that Hughes had not proven by a preponderance of the evidence that his disability was caused by a workplace injury and that his work activities were a major contributing cause of his disability. The circuit court reversed, determining (1) the Department erred by applying the incorrect standard to the causation of the injury, and (2) the Department's finding that Hughes failed to establish causation was clearly erroneous. The Supreme Court affirmed, holding that the circuit court properly overturned the Department's decision because Hughes proved by a preponderance of the evidence that his injury was work-related and that his employment was a major contributing cause of his current condition. View "Hughes v. Dakota Mill & Grain" on Justia Law

The Supreme Court reversed the judgment of the circuit court affirming the decision of the Department of Labor and Regulation denying Steven Billman's application for permanent total disability benefits, holding that the Department's determination that Billman was not obviously unemployable was clearly erroneous.During his employment, Billman suffered a work-related injury that required the amputation of his left leg just below the knee. The Department denied Billman's application for benefits, finding that Billman was not obviously unemployable and that he failed to conduct a reasonable job search. The circuit court affirmed the Department's findings. The Supreme Court reversed, holding that Billman established that he was obviously unemployable, and therefore, he was entitled to odd-lot disability benefits. View "Billman v. Clarke Machine, Inc." on Justia Law

In this insurance dispute arising from an employee's death, the Supreme Court remanded the determination that the employer's insurer providing underinsured motorist coverage and workers' compensation insurance was entitled to a lien on a portion of settlement proceeds received by the estate, holding that, given a lack of factual findings, there was no way to evaluate whether the court clearly erred in its assessment of the various factors impacting an equitable allocation.Charles Luze died in a work-related accident. His employer paid his wife, Jeanette Luze, workers' compensation benefits. Jeanette, as the representative of Charles's estate, then brought suit against the negligent driver and settled the claim. The estate also settled a claim against the New FB's insurer providing underinsured motorist coverage, Zurich American Insurance Company, which was also New FB's workers' compensation carrier. The circuit court determined that Zurich was entitled to a statutory workers' compensation lien on fifty percent of the settlement proceeds received by the estate and was able to subrogate against its own settlement payment of underinsured benefits. The Supreme Court remanded in part, holding (1) this Court was unable meaningfully to review the circuit court's allocation determination; and (2) the circuit court properly allowed Zurich to subrogate against the amount it paid in underinsured motorist benefits. View "Luze v. New FB Co." on Justia Law

The Supreme Court reversed the decision of the circuit court reversing the decision of the Department of Labor determining that sergeants in the Yankton Police Department are ineligible for membership in a collective bargaining unit because they have authority to hire or effectively recommend hiring decisions, holding that the circuit court erred in disturbing the Department's findings and conclusions.The City of Yankton filed a request with the Department to define the membership of a collective bargaining unit. After a hearing, the Department found that police sergeants have authority to hire or effectively recommend hiring and are thus excluded from membership in the collective bargaining unit. The circuit court reversed, holding that sergeants should be included in bargaining unit membership. The Supreme Court affirmed, holding (1) the circuit court erred in determining that the Department's relevant findings of fact were inadequate and that its conclusions of law were incorrect; and (2) the circuit court erred in determining that sergeants have no authority to hire or effectively recommend hiring decisions. View "Fraternal Order Of Police v. City Of Yankton" on Justia Law

The Supreme Court reversed the circuit court's award of employee benefits to Plaintiff, holding that Plaintiff was not entitled to employee benefits under the City of Edgemont's Personnel Manual.Plaintiff sued the City of Edgemont alleging that he was owed employee benefits under the Manual. The circuit court found that Plaintiff was a City employee as of December 3, 2012 but only awarded employee benefits under the Manual after Plaintiff was appointed City Engineer/Code Officer on May 6, 2014. The Supreme Court affirmed in part and reversed in part, holding (1) the circuit court correctly denied Plaintiff any additional employee benefits under the Manual from December 3, 2012 to May 6, 2014; (2) the circuit court erred in granting benefits under the Manual from May 6, 2014 through May 5, 2015 because, as a temporary or seasonal employee, Plaintiff did not qualify for the benefits afforded to regular full-time or part-time employees; and (3) Plaintiff was not entitled to attorney fees because he did not prevail on his wage claim. View "Koopman v. City Of Edgemont" on Justia Law

The Supreme Court reversed the judgment of the circuit court in favor of Appellee in this workers' compensation case, holding that an error led to the exclusion of relevant evidence and incorrect jury instructions that impacted the jury's verdict, which prejudiced Appellants.Fern Johnson sued her former employer and its workers' compensation carrier (collectively, Appellants) alleging bad faith and conversion based on their denial of previously ordered workers' compensation medical benefits. A jury returned a verdict for Johnson. The Supreme Court reversed and remanded the case for a new trial, holding (1) the circuit court did not err when it concluded that Appellants' legal obligation to pay Johnson's benefits was not fairly debatable; but (2) the circuit court erred when it determined that the lack of a reasonable basis to deny benefits necessarily impacted the jury's consideration of the separate bad faith element concerning Appellants' knowledge. View "Johnson v. United Parcel Service, Inc." on Justia Law

The Supreme Court affirmed the order of the circuit court granting summary judgment for Hospital on Nurse's claims for wrongful discharge, breach of contract, and defamation, holding that summary judgment was proper.Hospital terminated Nurse after it discovered errors in Nurse's documentation of controlled substances and Nurse's inability to account for controlled substances revamped from the dispensing system. Nurse brought suit against Hospital alleging several claims. The circuit court granted summary judgment for Hospital on all claims. The Supreme Court affirmed, holding that summary judgment was properly granted in favor of Hospital. View "Henning v. Avera McKennan Hospital" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Plaintiff's request for attorney fees under S.D. Codified Laws 60-11-24 after Plaintiff prevailed in an action seeking unpaid wages, holding that because this case was removed for a bench trial section 60-11-24 did not apply and Plaintiff was not entitled to recover attorney fees.After Defendant fired Plaintiff, Plaintiff brought an action in small claims court for unpaid wages. Defendant removed the action to circuit court, which ruled in favor of Plaintiff. Plaintiff requested attorney fees under section 60-11-24. The circuit court denied the request because the removal statute referenced in section 60-11-24 had been repealed. The Supreme Court affirmed, holding (1) the circuit court did not err in concluding that it could not award reasonable attorney fees under section 60-11-24 because of the repeal of S.D. Codified Laws 15-39-59; and (2) while attorney fees remain recoverable under section 60-11-24 for small claims cases removed to circuit court for a jury trial, this case was removed for a bench trial. View "Goin v. Houdashelt" on Justia Law