Justia Labor & Employment Law Opinion Summaries
Articles Posted in Wyoming Supreme Court
Skaf v. Wyo. Cardiopulmonary Services, P.C.
The Supreme Court affirmed the judgment of the district court confirming the arbitration panel's finding that a non-compete clause Dr. Michel Skaf signed in his employment contract with Wyoming Cardiopulmonary Services (WCS) was unenforceable but that a previously-granted liquidation award was still valid, holding that there was no error.After WCS terminated Skaf for cause Skaf opened his own cardiology office. WCS sued Skaf for breaching the non-compete clause in the parties' employment contract. The arbitration found Skaf violated the noncompete clause and awarded WCS liquidated damages. The Supreme Court remanded the case. On remand, the arbitration panel again found in favor of WCS, that the non-compete clause was unenforceable, but that the liquidated damages award was still valid. The district court confirmed the award. The Supreme Court affirmed, holding (1) the panel did not commit manifest error by denying Skaf interest on his deferred compensation award; and (2) because Skaf did not previously appeal the panel's award, he was barred from doing so now. View "Skaf v. Wyo. Cardiopulmonary Services, P.C." on Justia Law
Hensel v. DAPCPA RPO LLC
The Supreme Court affirmed the district court's award of $21,643.65 in attorney fees and costs to DAPCPA RPO, a full-service public accounting firm, after the court concluded that Defendant breached a purchase and sale agreement (PSA) and a covenant not to solicit, holding that there was no error.Defendant, a former employee of DAPCPA RPO, formed a new firm and provided services to former DAPCPA RPO clients. DAPCPA RPO filed suit, alleging several claims. The district court granted summary judgment for DAPCPA RPO in part, concluding that the parties' PSA and covenant not to solicit were valid and enforceable contracts and that Defendant breached them. Ultimately, the Court awarded DAPCPA RPO a total of $21,643.65 in attorney fees and costs. The Supreme Court affirmed, holding that the district court did not abuse its discretion in determining that DAPCPA RPO was entitled to its fees and costs. View "Hensel v. DAPCPA RPO LLC" on Justia Law
Vandom v. State, ex rel. Dep’t of Workforce Services, Workers’ Compensation Division
The Supreme Court affirmed the judgment of the district court affirming the decision of the Office of Administrative Hearings (OAH) denying Workers' Compensation Division benefits for treatment to Appellant's upper back, neck, and arms, holding that the OAH's determination was supported by the evidence and was not arbitrary, capricious, or otherwise not in accordance with the law.Eight days after she twisted her back at work Appellant was in a motorcycle accident. The Division concluded that Appellant had suffered a compensable injury to her lumbar spine but denied payments for treatments for cervical spine, carpal tunnel syndrome, and cervical disc degeneration because those conditions were not related to Appellant's work injury. After a contested case hearing, the OAH upheld the decision. The Supreme Court affirmed, holding that the OAH's decision was supported by substantial evidence and was not arbitrary or capricious. View "Vandom v. State, ex rel. Dep't of Workforce Services, Workers' Compensation Division" on Justia Law
Lovato v. Case
The Supreme Court affirmed the judgment of the district court granting summary judgment to Defendant and dismissing Plaintiff's action alleging that Defendant was liable as his co-employee "for reckless, willful, wanton and/or reprehensible conduct" that led to him being run over with a concrete truck while working on a construction project, holding that there was no error.In granting summary judgment for Defendant, the district court concluded that Defendant was immune from liability because, under Wyoming law, Plaintiff's sole remedy was workers' compensation benefits. On appeal, Plaintiff argued that genuine issues of material fact existed as to whether Defendant lost statutory immunity because his actions were willful and wanton. The Supreme Court disagreed and affirmed, holding that the district court (1) erred by ruling that Defendant was not responsible for Plaintiff's safety and work conditions because he was not Plaintiff's supervisor; (2) did not err in ruling that Plaintiff did not present evidence showing that Defendant knew his actions presented a serious risk to Plaintiff or that it was highly probable harm would result if he disregarded the risk; and (3) did not err by ruling that there were no genuine issues of material fact as to whether Defendant acted willfully and wantonly. View "Lovato v. Case" on Justia Law
Genner v. State, ex rel. Department of Workforce Services, Workers’ Compensation Division
The Supreme Court affirmed the decision of the Medical Commission Hearing Panel (Commission) upholding that decision of the Wyoming Workers' Compensation Division denying Claimant's request for permanent total disability (PTD) benefits for a work-related injury that Claimant asserted made him unemployable, holding that the Commission's decision was supported by substantial evidence and was unaffected by any error of law.At issue was Claimant's request for PTD benefits for a work-related back injury Claimant suffered in 2002. The Division denied Claimant's application for PTD benefits, and the Commission upheld the Division's denial of PTD benefits. The Supreme Court affirmed, holding that the Commission correctly determined that Claimant did not meet his burden of proving he was entitled to PTD benefits under the odd lot doctrine. View "Genner v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law
City of Rawlins v. Schofield
The Supreme Court reversed the decision of the district court determining that the procedures leading to the dismissal of Petitioner from the City of Rawlins Fire Department violated Petitioner's right to due process and ordering her to be reinstated with back pay, holding that the Rawlins Fire Department Civil Service Commission's decision terminating Petitioner's employment was supported by substantial evidence in accordance with law.The Commission concluded that the reason for Petitioner's discharge was "sufficient and established" pursuant to Wyo. Stat. Ann. 15-5-112(b) because Petitioner violated Civil Service Commission Rules 21.3 and 2.7 and ordered Petitioner's employment be terminated. In so concluding, the Commission explicitly rejected Petitioner's argument that she was denied due process. The trial court reversed, finding that Petitioner's due process rights were violated. The Supreme Court reversed, holding (1) Petitioner was afforded due process prior to her discharge by the Commission; and (2) the Commission's decision was supported by substantial evidence and was not arbitrary or capricious. View "City of Rawlins v. Schofield" on Justia Law
McBride v. State, ex rel. Department of Workforce Services
The Supreme Court affirmed the decision of the district court reversing the decision of the Office of Administrative Hearings (OAH) awarding Plaintiff permanent partial disability benefits (PPD) after she injured her back and left hip while working as a registered nurse, holding that the district court did not err.The OAH awarded Plaintiff benefits after finding that she had made a tangible effort to seek suitable employment given her health, education, training, and experience. The district court reversed, finding that Plaintiff did not present sufficient evidence that she actively sought work and did not present expert medical testimony showing she was incapable of working. The Supreme Court affirmed, holding that the OAH decision was not supported by substantial evidence because Plaintiff did not establish by a preponderance of the evidence that there was no suitable work given her health. View "McBride v. State, ex rel. Department of Workforce Services" on Justia Law
Hart v. State of Wyoming, ex rel. Department of Workforce Services, Workers’ Compensation Division
The Supreme Court affirmed the judgment of the Wyoming Workers' Safety and Compensation Division denying coverage for Claimant's thoracic spine treatment, holding that the Medical Commission's decision was supported by the hearing evidence.After the Division denied Claimant's compensation coverage for his thoracic spine treatment Claimant appealed. The Compensation Commission upheld the denial of coverage following a contested pain hearing, and the district court affirmed. The Supreme Court affirmed, holding (1) the record contained substantial evidence to support the Commission's findings that Claimant's thoracic spine injury was unrelated to his work-related accident; and (2) Claimant failed to meet his burden of proving that his thoracic spine evaluation and treatment were compensable under the "rule out" doctrine. View "Hart v. State of Wyoming, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law
McCallister v. State, ex rel. Department of Workforce Services, Workers’ Compensation Division
The Supreme Court affirmed the judgment of the district court affirming the decision of the Office of Administrative Hearings (OAH) upholding the Wyoming Workers' Compensation Division's denial of Appellant's request for an endless pool to treat his work-related injury, holding that there was no error.Appellant requested that the Division preauthorize the purchase of a small pool with an underwater treadmill known as an endless pool to help him manage his medical condition. The Division denied the request in part, and the OAH upheld the determination. The district court affirmed. The Supreme Court affirmed, holding (1) the OAH had authority to decide this case; and (2) the OAH properly determined that Appellant was collaterally estopped from relitigating his right to an endless pool for treatment because the issue was fully decided in an earlier OAH order denying the claim. View "McCallister v. State, ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law
Boylen v. State, ex rel., Department of Workforce Services, Workers’ Compensation Division
The Supreme Court affirmed the decision of the Office of Administrative Hearings (OAH) affirming the denial of Appellant's request for benefits related to her injury, holding that substantial evidence supported the agency's decision.On May 3, 2019, Appellant, a sales associate at Flaming Gorge Harley-Davidson, was moving a motorcycle when her back grabbed and her legs felt weak. On May 6, Appellant was standing in her kitchen and turning slightly to the left when she felt excruciating pain. Appellant filed a claim with the Department of Workforce Services, Workers' Compensation Division for benefits related to her May 6 injury. The Division denied Appellant her requested benefits. The OAH and the district court affirmed. The Supreme Court affirmed, holding (1) the law does not require OAH to reference the "second compensable injury" rule in its decision; and (2) there was substantial evidence to support OAH's conclusion that Appellant failed to prove her May 6 injury was caused by the May 3 injury. View "Boylen v. State, ex rel., Department of Workforce Services, Workers' Compensation Division" on Justia Law