Justia Labor & Employment Law Opinion Summaries

A long-term employee of a county government began experiencing workplace difficulties after a new supervisor was assigned. The employee alleged that the supervisor engaged in repeated, unwelcome comments about her appearance and closely monitored her, behavior corroborated by coworkers. After reporting the supervisor’s conduct to union representatives, who then informed higher management, the employee was subjected to increased scrutiny, including a performance improvement plan, a written warning, and public criticism of her work. The employee filed internal and external complaints alleging sexual harassment and retaliation. Following these events, her health deteriorated, leading her to take medical leave and ultimately retire early.The Utah Labor Commission’s Antidiscrimination and Labor Division initially found no reasonable cause for her claims. On appeal, an administrative law judge (ALJ) held an evidentiary hearing but was replaced by another ALJ, who dismissed her claims. The Labor Commission Appeals Board reviewed the case, reinstated her retaliation claim using the McDonnell Douglas burden-shifting framework, and remanded for a damages determination. The Board and ALJ denied her request for attorney fees, citing a Utah Supreme Court decision, Injured Workers Ass’n of Utah v. State, as precluding such awards. Both parties appealed aspects of the Board’s decision to the Utah Court of Appeals, which adopted the U.S. Supreme Court’s Burlington Northern standard for “adverse action” in retaliation claims, upheld the retaliation finding, and ruled that attorney fees could be awarded but not assessed for reasonableness.The Supreme Court of the State of Utah reviewed the case. It held that the Burlington Northern standard—defining adverse action as conduct likely to dissuade a reasonable worker from making or supporting a discrimination charge—applies to retaliation claims under the Utah Antidiscrimination Act. However, the court found the Board had not applied this standard or made sufficient factual findings, so it remanded the case for further proceedings. The court also clarified that the McDonnell Douglas framework is a procedural device, not a set of claim elements, and that the Labor Commission may award and assess the reasonableness of attorney fees. The court affirmed in part, reversed in part, and remanded. View "Christensen v. Labor Commission" on Justia Law

Haylee Hinton was injured in a car accident caused by another motorist running a red light. She initially sought compensation from her employer’s workers’ compensation insurer and later settled with the motorist’s insurance carrier. Hinton then filed a claim for underinsured motorist benefits with Midwest Family Mutual Insurance, her underinsured motorist coverage provider, and submitted the claim to arbitration as permitted by Utah law.Midwest sought a declaratory judgment from the district court to limit the categories of damages Hinton could recover in arbitration, citing Utah Code section 31A-22-305.3(4)(c)(i), which excludes benefits paid or payable under the Workers’ Compensation Act from underinsured motorist coverage. The district court interpreted the statute to mean that past and future medical expenses and two-thirds of lost wages were payable under workers’ compensation and ruled that Hinton could not recover these categories of damages from Midwest.Hinton petitioned for interlocutory review, arguing that the district court lacked jurisdiction and misinterpreted the statute. The Utah Supreme Court found that the district court had jurisdiction but misinterpreted the statute. The court concluded that “payable” means benefits that can or may be paid to a specific claimant in a particular case, not just categories of damages generally available under workers’ compensation. The court vacated the district court’s order and remanded the matter for further proceedings to determine what benefits remain payable to Hinton under the Workers’ Compensation Act. View "Hinton v. Midwest Family Mutual Insurance" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Robyn Young's motion to dismiss this action brought by Granite School District regarding settlement proceeds Young had received for industrial injuries, holding that the Labor Commission had exclusive jurisdiction over the factual questions at the heart of this reimbursement dispute.Young, a special education teacher, sought workers' compensation for injuries she received at the hands of her students. An administrative law judge awarded Young benefits, finding that Young was permanently and totally disabled and that Young did not have to reimburse Granite with funds she received from a legal settlement she had obtained against medical debt collectors for violations of the Fair Debt Collection Practices Act. Granite then initiated suit for reimbursement from Young under the Utah Workers' Compensation Act. The district court granted Young's motion to dismiss. The Supreme Court affirmed, holding that the district court did not err when it dismissed Granite's complaint because the Workers' Compensation Act assigned the Commission exclusive jurisdiction over this dispute. View "Granite School District v. Young" on Justia Law

The Supreme Court affirmed the judgment for Defendants on Plaintiffs' respondeat superior-related claims, holding that the district court correctly held that respondeat superior principles did not make the remaining defendants in this case vicariously responsible for the abuse committed by a physician assistant and that the Utah Physician Assistant Act did not change that conclusion.Plaintiff brought an action against Alta Pain Physicians; Oscar Johnson, a physician assistant; and Dr. Michael Chen, Johnson's supervising physician, alleging that Johnson subjected her to sexual harassment and abuse when she saw him for pain treatment at Alta Pain. After Plaintiff settled her claims against Johnson the district court granted the motion for summary judgment filed by Chen and Alta Pain on Plaintiff's claims of sexual assault, sexual battery, and intentional infliction of emotional distress. The Supreme Court affirmed, holding (1) the district court did not err in entering summary judgment on Plaintiff's respondeat superior-based claims; and (2) Plaintiff did not met her burden of convincing the Court to overturn precedent and use a foreseeability test for plaintiffs to recover against employers of abusive employees. View "Burton v. Chen" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's motion to dismiss this lawsuit brought by Plaintiff under the Utah Sales Representative Commission Payment Act for allegedly failing to pay commissions it owed to her, holding that the Act's writing requirement is not a precondition for recovery.In her complaint, Plaintiff claimed that Defendant violated the Act by failing to pay commissions for sales that she made while working as a commissioned sales agent for the company. Defendant filed a motion to dismiss, arguing that because there was no signed writing there could be no recovery under the Act. The district court granted the motion. The Supreme Court reversed, holding (1) under the plain text of the Act, the writing requirement is not a prerequisite for a sales representative to sue a principal under the Act; and (2) therefore, the district court erred in granting Defendant's motion to dismiss. View "Williamson v. MGS By Design, Inc." on Justia Law

The Supreme Court reversed the determination of the court of appeals that Claimant's long drive in a commercial truck was not an unusual or extraordinary activity in comparison to the ordinary activities people perform in their nonworking, everyday lives and vacated the conclusion that there was substantial evidence to support the ALJ's finding that Claimant's "super obesity" was a preexisting condition, holding that Claimant was entitled to benefits.At the end of a three-day drive from Utah to California, Claimant was diagnosed with a blood clot in his left leg, which caused blood clots in his lungs. Claimant could not return to work and sought workers' compensation. Employer disputed the claim, arguing that his injuries were caused by his "super obesity" and that super obesity should be considered a preexisting condition under the circumstances. The ALJ granted benefits, concluding that Claimant had satisfied the Allen v. Industrial Comm'n, 729. P.2d 15 (Utah 1986), test for legal causation. The Labor Commission Appeals Board reversed, concluding that Claimant's work activities were not unusual or extraordinary under Allen. The Supreme Court reversed, holding (1) Claimant's drive to California was an unusual activity; and (2) therefore, Claimant showed legal causation. View "JBS Carriers v. Hickey" on Justia Law

The Supreme Court reversed the decision of the Labor Commission Appeals Board dismissing Appellant's interlocutory objection to the appointment of the medical panel assigned to resolve this dispute, holding that the actual bias standard applied by the Board to resolve Appellant's conflict of interest objection did not comport with the statutory requirements.Appellant sought workers' compensation benefits after he injured his back in a work-related accident. The administrative law judge assigned to the case appointed a medical panel to resolve the dispute and appointed Dr. Jeremy Biggs, an occupational medicine physician, to serve as the panel chair. Appellant moved for interlocutory review, arguing that Dr. Biggs should be disqualified because he had a conflict of interest. The Board rejected Appellant's objections and concluded that the accident had not caused permanent injury. The Supreme Court reversed, holding (1) where a medical panelist's impartiality could be reasonably questioned the requirement of an impartial medical evaluation has not been met; and (2) remand was required on this basis. View "Gamez v. Utah Labor Commission" on Justia Law

The Supreme Court vacated the decision of the district court denying the motion for summary judgment filed by Barnes Bullets asking the district court to rule that the Workers' Compensation Act (WCA) barred Layne Kay's claim, holding that the Occupational Disease Act (ODA) may bar Kay's lawsuit.Kay contracted lead poisoning while working at Barnes and sued Barnes under the exception to the WCA permitting employees like Kay to sue over injuries caused by an employer's intentional act. Barnes moved for summary judgment, arguing that the WCA barred Kay's claim where Kay did not present sufficient evidence that Barnes acted intentionally. The Supreme Court vacated the district court's decision and remanded the case for further proceedings, holding that Utah law recognizing lead poisoning as an occupational disease raises a significant question as to whether the ODA, not the WCA, covered Kay's claim. View "Kay v. Barnes Bullets" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiffs' lawsuit filed against the employer of Kasey Christiansen, who was killed at work, holding that the district court did not err.The district court dismissed Plaintiffs' lawsuit based on a provision of the Workers' Compensation Act that bars employees from suiting their employers over work-related injuries. Plaintiffs appealed, arguing that the district court erred in applying the Act's exclusive remedy provision to dismiss their complaint because the intentional-injury exception applied. The Supreme Court disagreed, holding that Plaintiffs failed to state a claim upon which relief could be granted because it could not reasonably be inferred that Defendant believed Christiansen's fatal injuries were virtually certain to occur. View "Christiansen v. Harrison Western Construction Corp." on Justia Law

The Supreme Court vacated the decision of the district court denying Defendant's motion for summary judgment in this lawsuit over a work-related ailment, holding that remand was required.Plaintiff contracted lead poisoning while working for Defendant. A narrow exception in the Workers' Compensation Act (WCA) allows employees like Plaintiff to sue over injuries caused by an employer's intentional act, and Plaintiff sued Defendant under this exception. Defendant filed a motion for summary judgment, arguing that the WCA barred Plaintiff's claim because he did not present sufficient evidence that Defendant acted intentionally. The district court denied the motion. The Supreme Court vacated the decision below, holding (1) although both parties assumed that the WCA covered Plaintiff's condition, Utah law has frequently recognized lead poisoning as an occupational disease governed exclusively by the Occupational Disease Act; and (2) therefore, remand was required to determine if Plaintiff's lead poisoning was an occupational disease. View "Kay v. Bullets" on Justia Law