Justia Labor & Employment Law Opinion Summaries

Articles Posted in Utah Supreme Court
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The Supreme Court affirmed the decision of the Labor Commission awarding Appellant permanent partial disability under the Workers' Compensation Act (WCA), Utah Code 34A-2-101 to -1005, holding that the Commission's process for determining permanent partial disability benefits is constitutional and that the administrative law judge (ALJ) was not permitted to increase the amount of the award based on Appellant's subjective pain.Based on Commission guidelines, the ALJ based the amount of Appellant's award on a report provided by an assigned medical panel. Appellant argued on appeal that the process for determining permanent partial disability benefits was unconstitutional and that the ALJ erred in failing to augment the medical panel's impairment rating by three percent, resulting in an increased compensation award. The Supreme Court disagreed, holding (1) the adjudicative authority of ALJs has not been unconstitutionally delegated to medical panels; and (2) the Commission expressly precludes ALJs from augmenting an impairment rating based on a claimant's subjective pain. View "Ramos v. Cobblestone Centre" on Justia Law

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The Supreme Court reversed the judgment of the district court granting Albertson's LLC's motion for partial summary judgment concluding that the Utah Occupational Safety and Health Act (UOSHA) preempted Plaintiff's wrongful termination claim, holding that UOSHA does not reflect a clear legislative intent to preempt common law remedies.In his complaint, Plaintiff alleged that Albertson's fired him because he reported a workplace injury. Plaintiff asserted three causes of action - wrongful termination in violation of public policy, breach of contract, and breach of the implied covenant of good faith and fair dealing. The district court concluded that UOSHA preempted Plaintiff's claim for wrongful termination. The Supreme Court reversed, holding that where UOSHA contains no exclusive remedy provision and where Utah Code 34A-6-110(1) instructs that UOSHA does not limit or repeal other legal obligations, it cannot be concluded that UOSHA's structure and purpose demonstrate a legislative intent to preempt common law causes of action. View "Graham v. Albertsons" on Justia Law

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The Supreme Court reversed the decision of the district court granting summary judgment in favor of Plaintiffs in this action seeking to recover delinquent contributions to various trust funds for construction on a state construction project, holding that the right of action under a payment bond statute extends to any amount due an employee, meaning any amount that is traceable specifically to an employee.One of the subcontractors hired to work on the project failed to make contributions to various trust funds for its employees' work on the project, as required by trust agreements and a collective bargaining agreement. The trusts (Plaintiffs) sought to recover the delinquent contributions from the public payment bond associated with the project by suing Defendant, the surety for the payment bond. The district court granted summary judgment for Plaintiffs. On appeal, the parties disputed whether Utah Code 63G-6-505(4) limits the right of action on a payment bond to amounts due to an employee or encompasses claims for any amounts due for an employee or on the employee's behalf. The Supreme Court reversed, holding that the right of action under the public payment bond statute contemplates recovery of any specific benefit that is due a person in the sense of being traceable to that person. View "McDonald v. Fidelity & Deposit Co. of Maryland" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court dismissing Plaintiff's claims that Defendant, his employer, fired him in violation of the implied covenant of good faith and fair dealing in his compensation agreement with Defendant, holding that the court of appeals' application of the covenant was improper.In his complaint, Plaintiff claimed that Defendant fired him in an effort to avoid payment of commissions and that, even though he was an at-will employee, his termination violated the implied covenant of good faith and fair dealing. In dismissing the claims, the district court concluded that the covenant could did not apply in this context. The court of appeals reversed, concluding that the covenant can be invoked to prevent employers form using at-will termination to avoid obligations under the compensation agreement. The Supreme Court reversed, holding (1) the covenant of good faith and fair dealing may not be applied to contradict express contractual terms; and (2) the court of appeals' application was inconsistent with the express terms of the compensation agreement and with the parties' course of dealings. View "Vander Veur v. Groove Entertainment Technologies" on Justia Law

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The Supreme Court affirmed the award of benefits entered by the Utah Labor Commission in favor of Jessica Wilson, holding that the Commission did not err in concluding that Wilson's injuries arose out of, and in the course of, her employment with her employer, Intercontinental Hotels Group (IHG).Wilson sustained injuries after tripping and falling in a parking lot while walking into work. Wilson requested benefits from IHG. IHG denied Wilson's claim, concluding that, under the going-and-coming rule, Wilson's accident did not arise out of and in the course of her employment. An ALJ with the Commission reviewed Wilson's claim and concluded that Wilson was entitled to benefits under the premises rule. The Commission affirmed, concluding that the communal parking area where the accident occurred was proof IHG's premises for purposes of determining compensability. The Supreme Court affirmed, holding that the Commission properly determined that Wilson's accident occurred on IHG's premises and that, under case law, this constituted an accident in the course of her employment. View "Intercontinental Hotels Group v. Utah Labor Commission" on Justia Law

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The Supreme Court affirmed the judgment of the district court allowing Alarm Protection Technology (APT) to substitute itself as the plaintiff in this case and extinguishing Ryan Bradburn's claims against it, holding that the district court did not abuse its discretion in permitting APT's substitution as plaintiff.After Bradburn's employment with APT as a sales representative ended he sued APT for alleged unpaid commissions. Executing on a confession of judgment it had previously obtained from Bradburn, APT initiated a constable sale and purchased Bradburn's legal right to sue APT. APT then substituted itself into this case for Bradburn and dismissed all claims against itself. The Supreme Court affirmed, holding that the district court did not abuse its discretion in allowing complete substitution because Utah law permits the tactic used by APT in this case. View "Bradburn v. Alarm Protection Technology, LLC" on Justia Law

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The Supreme Court dismissed the appeal in this labor dispute and vacated the the district court’s judgment, holding that the case was moot.A group of supervisors working for Utah Transit Authority (UTA) coordinated with a labor organization in an effort to unionize, which the UTA resisted. The union and supervisors subsequently filed an action seeking a declaration of their right to organize. After the district court entered a non-final order concluding that the supervisors had collective bargaining rights under Utah law, the supervisors voted not to unionize. Because the district court had not entered a final judgment, the case became moot. The district court then entered its final judgment, and UTA appealed. The Supreme Court dismissed the appeal and vacated the judgment below, holding that the controversy became moot before the district court had entered its final judgment, and the district court should have dismissed the case as moot at that point. View "Teamsters Local 222 v. Utah Transit Authority" on Justia Law

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The Supreme Court affirmed the district court’s ruling that Plaintiff, a municipal employee, had forfeited her merit protection status through contract, estoppel, and waiver without reaching the merits of Plaintiff’s claims because she failed to carry her burden of challenging all of the district court’s rulings, each of which was an independent basis for summary judgment.On appeal, Plaintiff argued that Supreme Court precedent allowing a contract in conflict with a statute to survive, provided it does not violate public policy, does not extend to contracts involving government employees. The Supreme Court held that, although it was possible that Plaintiff was correct, Plaintiff was not entitled to relief because she failed to challenge the district court’s ruling that she was equitably estopped from claiming merit status. View "Howick v. Salt Lake City Corp." on Justia Law

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A notice of termination may be an adverse employment action independent of an actual termination under the Utah Protection of Public Employees Act (UPPEA).Plaintiff filed suit against Employer, claiming infringement of her free speech rights under the Utah Constitution and under the UPPEA. Employer moved for summary judgment, arguing, inter alia, that the UPPEA claim was time-barred because Plaintiff suffered an “adverse employment action” triggering the 180-day filing requirement under the UPPEA. The United States District Court certified three questions for the Utah Supreme Court’s review. The Supreme Court declined to exercise its discretion to resolve the first two questions and instead answered only the third question. The court answered the question as set forth above and set forth an analytical framework for assessing whether such employment actions are independent of each other under the UPPEA. View "Zimmerman v. University of Utah" on Justia Law

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A notice of termination may be an adverse employment action independent of an actual termination under the Utah Protection of Public Employees Act (UPPEA).Plaintiff filed suit against Employer, claiming infringement of her free speech rights under the Utah Constitution and under the UPPEA. Employer moved for summary judgment, arguing, inter alia, that the UPPEA claim was time-barred because Plaintiff suffered an “adverse employment action” triggering the 180-day filing requirement under the UPPEA. The United States District Court certified three questions for the Utah Supreme Court’s review. The Supreme Court declined to exercise its discretion to resolve the first two questions and instead answered only the third question. The court answered the question as set forth above and set forth an analytical framework for assessing whether such employment actions are independent of each other under the UPPEA. View "Zimmerman v. University of Utah" on Justia Law