Justia Labor & Employment Law Opinion SummariesArticles Posted in Utah Supreme Court
Quast v. Utah Labor Commission
The Supreme Court reversed the judgment of the court of appeals, which set aside the order of the Labor Commission concluding that Respondent had failed to make out a permanent total disability claim against her former employer, the University of Utah Huntsman Cancer Hospital. The Commission reversed the order of an administrative law judge (ALJ), which awarded Respondent permanent total disability benefits. In denying Respondent’s application for permanent total disability benefits, the Commission concluded that Respondent had failed to show that she was limited in her ability to do basic work activities. The court of appeals reversed, concluding that Respondent was not limited in her ability to perform basic work activities because her impairments did not “reasonably” limit her. The Supreme Court disagreed and affirmed the Commission’s order denying Respondent’s application for permanent total disability benefits, holding (1) both the court of appeals and the Commission misstated the burden of proof on the “other work reasonably available” element of a permanent total disability claim; and (2) the court of appeals erred in reversing the Commission’s determination that Respondent was limited in her ability to do basic work activities. View "Quast v. Utah Labor Commission" on Justia Law
Oliver v. Utah Labor Commission
The Supreme Court reversed the judgment of the court of appeals reversing the order of the Labor Commission denying Respondent’s application for permanent total disability benefits under Utah Code 34A-2-413, the permanent total disability portion of the Workers’ Compensation Act. The Commission denied the application based on Respondent’s failure to prove two elements of a permanent total disability claim. The Supreme Court held (1) the court of appeals erred in its interpretation of section 34A-2-413(1)(c)(ii); (2) the court of appeals misallocated the burden of proof and improperly considered information not contained in the record in reversing the Commission’s determination that Respondent failed to prove the “essential functions” element of a permanent total disability claim; and (3) the Commission correctly denied Respondent’s application for permanent total disability benefits. View "Oliver v. Utah Labor Commission" on Justia Law
Nichols v. Jacobsen
Plaintiff was seriously injured during the course of his employment with Defendant. Plaintiff filed suit alleging that Defendant’s negligence caused his injuries. Defendant moved for summary judgment asserting that it was immune from suit under the exclusive remedy provision of the Utah Workers’ Compensation Act. The district court granted the motion, determining that Defendant qualified for immunity under the “eligible employer” statute. The court of appeals reversed, concluding that Defendant did not “secure the payment” of workers’ compensation benefits for Plaintiff as required by the statute. The Supreme Court reversed, holding that Defendant qualified as an “eligible employer” under the workers’ compensation statutes and fulfilled all of the statutory requirements. View "Nichols v. Jacobsen" on Justia Law
Dorsey v. Dep’t of Workforce Servs.
John Dorsey filed a series of unemployment claims for time periods when he was in Mexico during the offseason of his employment at a Utah resort. Because he was considered a seasonal employee Dorsey was granted a deferral from the requirement of search for work as a prerequisite to eligibility for benefits. The Department of Workforce Services later concluded that Dorsey had been ineligible to receive unemployment benefits during his trips to Mexico under its rule deeming unemployment claimants ineligible for benefits if they travel outside the United States for more than two weeks. The Workforce Appeals Board affirmed. The court of appeals reversed. The Supreme Court affirmed, holding (1) the Department's rule as extended to a seasonal worker not required to search for work is incompatible with the governing statutory position; and (2) because Dorsey was “able” and “available” for work he was eligible for unemployment benefits under the statute. View "Dorsey v. Dep't of Workforce Servs." on Justia Law
Colvin v. Giguere
Kelly Colvin was killed in an automobile accident while returning to Utah from a work project in Maryland. The accident occurred when Colvin was a passenger in a vehicle driven by his coworker, Joseph Giguere. Colvin’s widow and son sued Giguere, claiming that Colvin’s death was proximately caused by Giguere’s negligent driving. Giguere moved for summary judgment, asserting that the exclusive remedy provision of the Workers’ Compensation Act barred this suit because the accident occurred in the course of his and Colvin’s employment. The district court agreed and granted Giguere’s motion for summary judgment. The Supreme Court affirmed, holding that because the accident occurred while Colvin and Giguere were carrying out a special errand for their employer, this action was barred under the Act’s exclusive remedy provision. View "Colvin v. Giguere" on Justia Law
Ramsay v. Kane County Human Res. Special Serv. Dist.
Plaintiffs, employees of Kane County Hospital, sued various parties, including Utah Retirement Systems (URS), based on the Hospital’s alleged failure to adequately fund their retirement benefits as required by the Utah State Retirement and Insurance Benefit Act (“Act”). Before Plaintiffs filed their lawsuit, URS initiated an administrative proceeding against the Hospital, pursuant to the Act, seeking recovery of unpaid benefit contributions for Hospital employees. The district court dismissed Plaintiffs’ claims for lack of jurisdiction because Plaintiffs had not exhausted their administrative remedies. The court of appeals reversed and ordered that the case be stayed pending resolution of URS’s administrative action against the Hospital, concluding that it was impossible to ascertain which claims were subject to the exhaustion requirement until the pending administrative action was resolved. The Supreme Court reversed, holding that it lacked jurisdiction over Plaintiffs’ claims based on their failure to exhaust their administrative remedies because all of the claims fell within the scope of the Act and none of the exceptions to exhaustion applied. View "Ramsay v. Kane County Human Res. Special Serv. Dist." on Justia Law
Hughes Gen. Contractors, Inc. v. Utah Labor Comm’n
The Utah Occupational Safety and Health Division (UOSH) cited and fined Hughes General Contractors, which oversaw a construction project involving over 100 subcontractors, for a subcontractor’s violation on the project. In determining that Hughes was responsible for safety conditions for the subcontractor’s employees, the UOSH invoked the multi-employer worksite doctrine, which makes a general contractor responsible for the occupational safety of all workers on a worksite, including those who are not the contractor’s employees. Both an administrative law judge and the Labor Commission’s Appeals Board upheld the citation and the multi-employer worksite doctrine, which federal OSHA regulations have adopted and federal courts have upheld. The Supreme Court reversed the citation and penalty, holding (1) the multi-employer worksite doctrine is incompatible with the governing Utah statute, Utah Code 34A-6-201(1; (2) the responsibility for ensuring occupational safety under the governing statute is limited to an employer’s responsibility to its employees; and (3) because Hughes was not an employer of the workers in question in this case, Hughes was improperly cited and sanctioned. View "Hughes Gen. Contractors, Inc. v. Utah Labor Comm'n" on Justia Law
Posted in: Construction Law, Government & Administrative Law, Labor & Employment Law, Utah Supreme Court
Nelson v. City of Orem
Officer Dennis Nelson, a police officer with the Orem City Police Department (OCPD), was terminated from his position for using excessive force during a booking at the Orem City Jail. The Orem City Employee Appeals Board (Board) upheld the termination. The court of appeals upheld the Board's decision, concluding (1) the OCPD's decision to terminate Nelson was not inconsistent with prior instances of discipline under OCPD's excessive force policy; (2) alternatively, the Board justified any disparate application of OCPD's policy; and (3) the Board did not violate Nelson's procedural due process rights at his hearing before the Board. The Supreme Court affirmed, holding (1) the court of appeals did not err in applying an abuse of discretion standard of review; and (2) the court of appeals correctly found that any procedural due process violations at the hearing were harmless. View "Nelson v. City of Orem" on Justia Law
Posted in: Civil Rights, Constitutional Law, Government & Administrative Law, Labor & Employment Law, Utah Supreme Court
Jex v. Utah Labor Comm’n
Petitioner was traveling home from work in his personal vehicle when he sustained back injuries in a car accident. Petitioner applied for workers' compensation benefits, but his application was denied under the "going and coming rule," which deems injuries occurring during a work commute outside the course of employment and thus not compensable. Petitioner appealed, arguing that in light of the benefits his employer received through various work-related uses of his vehicle, he was "in the course of employment" during the accident. The labor commission and court of appeals rejected Petitioner's claim that he qualified under the "instrumentality" exception of the going and coming rule. The Supreme Court affirmed, holding that Petitioner fell within the rule and not the exception. View "Jex v. Utah Labor Comm'n" on Justia Law
Posted in: Government & Administrative Law, Insurance Law, Labor & Employment Law, Utah Supreme Court
Carbon County v. Workforce Appeals Bd.
Wade Marinoni was employed as a first-response emergency medical technician (EMT) for Carbon County. After an incident involving an immediate transport of a patient having a heart attack, Marinoni was fired for failing to immediately respond to the transport request. Marinoni applied for and was awarded unemployment benefits. The ALJ affirmed, finding that Marinoni had acted in good faith according to his understanding of his employer's protocol. The Workforce Board of Appeals affirmed, concluding that Carbon County did not meet its burden to demonstrate just cause for termination. The Supreme Court affirmed the court of appeals' ultimate determination upholding the award of unemployment benefits, holding (1) the court of appeals erred in declining to consider in its legal analysis the uncontested fact that Marinoni knew the patient was having a heart attack; but (2) the Board's legal conclusions regarding culpability were within the scope of the deference granted to the Board's decision. View "Carbon County v. Workforce Appeals Bd." on Justia Law