Justia Labor & Employment Law Opinion Summaries

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

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

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

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

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

Petitioner was working as a park ranger for Utah State Parks and Recreation when he suffered pain in his lower back after losing then regaining his balance on a boat dock while preparing to go on boating patrol. The Utah Labor Commission denied Petitioner's claim for benefits, concluding that the accident had aggravated a preexisting lower back condition and but that the unexpected wave that caused Petitioner to slightly lose his balance was not the legal cause of Petitioner's injury. The court of appeals affirmed. The Supreme Court upheld the court of appeals' ultimate decision to deny Petitioner compensation benefits; holding (1) the court of appeals erred in applying an abuse of discretion standard of review to the Commission's decision; but (2) even under a nondeferential standard of review, Petitioner failed to establish that his boat accident, rather than his preexisting back condition, was the legal cause of his injury. View "Murray v. Utah Labor Comm'n" on Justia Law

While employed with Employer, Employee agreed to arbitrate any disputes arising from his employment. Employee's employment was later terminated. Employee filed a charge of discrimination with the Utah Anti-Discrimination and Labor Division of the Utah Labor Commission (UALD), alleging that Employer discriminated against him, retaliated against him, and harassed him. The UALD dismissed Employee's discrimination claims. Employee appealed to the Utah Labor Commission. The district court subsequently granted Employer's motion to compel arbitration and ordered Employee to submit to arbitration. The Supreme Court vacated the order compelling arbitration, holding that the district court erred in compelling arbitration because the plain language of the arbitration clause in Employee's employment contract allowed him to pursue administrative remedies prior to submitting to arbitration. View "Zions Mgmt. Servs. v. Record" on Justia Law

An industrial accident occurred while Employer was insured under two separate workers compensation insurance policies, one with the Workers Compensation Fund (WCF) and one with the Utah Business Insurance Company (UBIC). WCF paid all of Employee's medical expenses and weekly compensation benefits, but when WCF became aware of the overlapping coverage, WCF filed a complaint against UBIC, alleging that UBIC was either solely or jointly liable for Employee's insurance benefits. The district court granted WCF's motion for partial summary judgment. The Supreme Court affirmed, holding that both insurers were liable for Employee's claim, and therefore, WCF was entitled to equitable contribution from UBIC for reasonable past and future costs associated with the claim. Remanded for resolution for the remaining claims. View "Workers Comp. Fund v. Utah Bus. Ins. Co." on Justia Law

On November 12, 2009, City dismissed Petitioner from his position as a city police officer. Petitioner appealed his termination to the City appeal board, which, after a hearing, affirmed the City's termination decision in a ruling dated June 7, 2010. On June 10, 2010, the City's recorder certified the order as final and mailed a copy to Petitioner. Petitioner filed a petition for review on July 9, 2010. The court of appeals dismissed for lack of jurisdiction, concluding the petition was untimely because it had been filed more than thirty days after the date (June 7, 2010) appearing on the appeal board's decision and order. The Supreme Court reversed, holding that Petitioner's petition was timely under a clarified statutory standard, as the order was not issued until June 10, 2010. Remanded. View "Perez v. South Jordan City" on Justia Law

This case arose out of collective bargaining negotiations between the Utah Transit Authority (UTA) and Local 382 of the Amalgamated Transit Union (Union). Those negotiations came to a standstill in 2009 when the parties entered into arbitration and litigation to resolve their disputes. The district court granted UTA's partial motion for summary judgment in the ensuing litigation, and the Union appealed. Before the matter could be addressed on appeal, however, the arbitrator entered a binding ruling largely in favor of the Union. With this ruling in hand, the parties once again entered into negotiations and successfully hammered out a new collective bargaining agreement. The Supreme Court dismissed the Union's appeal because the dispute had been resolved and the case was moot. View "Utah Transit Auth. v. Local 382 of Amalgamated Transit Union" on Justia Law