Justia Labor & Employment Law Opinion Summaries

In 2005, the Department of Environmental Quality (DEQ) hired Plaintiff. In 2007, the DEQ terminated Plaintiff on the ground that he improperly incurred $2,500 in personal charges on a state-issued cell phone. Plaintiff challenged his termination, claiming the ground was pretext, and the Office of Administrative Hearings reinstated Plaintiff to his original position. The DEQ sought review of that position in district court and made an offer to settle, to which Plaintiff did not respond. The DEQ subsequently notified Plaintiff it was accepting his resignation because he had taken a job in Montana. The DEQ then withdrew its petition for review. In 2009, Plaintiff filed suit in federal district court, claiming the DEQ's failure to comply with the conditions of his proffered resignation constituted wrongful termination. The federal court dismissed the lawsuit. Plaintiff then filed suit in district court, alleging, inter alia, breach of contract and breach of the purported settlement agreement. The district court dismissed the case, ruling that Plaintiff's claims were time-barred. The Supreme Court dismissed Plaintiff's appeal for failure to follow the Wyoming Rules of Appellate Procedure. View "Armstrong v. Wyo. Dep't of Envtl. Quality" on Justia Law

Appellant injured her neck and shoulder in a work-related accident. The Workers' Safety and Compensation Division approved Appellant's application for temporary total disability benefits but denied payments of two medical bills related to Appellant's lower back, concluding that the case was only left open for shoulder and neck injury. The office of administrative hearings (OAH) upheld the Division's denial of benefits. Appellant appealed. While on review in the district court, Appellant's counsel discovered documentation of a physical therapy session held approximately one month after Appellant's workplace accident that indicated she was experiencing pain in the middle of her back. Appellant unsuccessfully filed a motion to supplement the record with the physical therapy record. Appellant subsequently dismissed her appeal. Appellant then filed a Wyo. R. Civ. P. 60(b) motion for relief from final judgment based on the physical therapy record. The OAH denied the motion. The district court affirmed. The Supreme Court affirmed, holding (1) Appellant provided no evidence to support her claim that the failure to introduce the physical therapy record was caused by her trial counsel's mistake or inadvertence, and (2) Appellant failed to prove the significance of the medical record to her claim for benefits relating to her low back. View "Tegeler v. State ex rel. Workers' Safety & Comp. Div" on Justia Law

Sheridan Fire Fighters Local No. 276 filed suit against the City of Sheridan alleging that the City breached the parties' collective bargaining agreement when it failed to provide pay raises to five firefighters who had qualified for a "step increase" in salary. The City responded that the raises were not required and that, under the terms of the agreement, the City retained discretion in the award of pay raises. The district court granted summary judgment for the City. The Supreme Court reversed and remanded for entry of summary judgment in favor of Local 276, holding (1) the agreement was ambiguous about whether step increases in salary were mandatory or left to the City's discretion; and (2) because Local 276 presented evidence in support of its summary judgment motion consistent with the union's interpretation that the agreement required the City to give step increases to all eligible firefighters, and the City offered no evidence to the contrary, there were no genuine issues of material fact, and Local 276 showed it was entitled to judgment in its favor. View "Sheridan Fire Fighters Local No. 276 v. City of Sheridan" on Justia Law

Appellant, who worked for the Wyoming Department of Corrections, sustained significant injuries during a vehicle rollover while driving to pick up a prisoner. The Workers' Safety and Compensation Division awarded Appellant a partial impairment award, after which Appellant applied for permanent total disability (PTD) benefits. The Division denied her application, finding that she did not meet the statutory definition of PTD. The Medical Commission concluded that Appellant did not meet her burden of proving that she was entitled to PTD benefits. The district court affirmed. The Supreme Court reversed, holding that Appellant presented a prima facie case showing that she was unemployable in her community due to her injuries, and the Division failed to rebut this showing by demonstrating that there was in fact gainful employment available to her within a reasonable geographic area. Remanded. View "Stallman v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Appellee sustained a compensable neck injury and, despite four separate surgeries to address it, never returned to work. The Workers' Safety and Compensation Division paid Appellee temporary total disability (TTD) benefits for thirty-six months, the maximum period allowed by Wyo. Stat. Ann. 27-14-404(a) and the Division's rules. The Office of Administrative Hearings (OAH) awarded additional TTD benefits to Appellee, finding that each of Appellee's four separate surgeries was a second compensable injury, thus extending the amount of time the Division could pay TTD benefits. The district court affirmed the OAH's orders, and the Division appealed. The Supreme Court reversed and remanded, holding (1) under section 27-14-404(a) and the Division's rules, receipt of temporary total disability benefits is limited to a maximum period of thirty-six months; (2) under section 404(a), this limitation applies to all injuries resulting from any one incident or accident, encompassing situations in which the claimant receives multiple injuries simultaneously or a subsequent compensable injury as the result of a single workplace accident; and (3) because Appellee received benefits for a period of thirty-six months as a result of a single workplace accident, he was not entitled to receive additional TTD benefits. View "State ex rel. Wyo. Workers' Safety & Comp. Div. v. Smith" on Justia Law

The Wyoming Workers' Safety and Compensation Division determined that Appellant suffered a compensable injury while employed by Employer. The lodge filed an objection to that determination and requested a hearing with the Office of Administrative Hearings (OAH). Appellant filed a motion to dismiss that objection on the grounds that the objection was invalid because Employer was not a proper party to the action. The OAH denied Appellant's motion and concluded that Appellant had not suffered a compensable injury. The district court affirmed. At issue on appeal was whether Employer properly filed an objection to the Division's final determination of compensability. The Supreme Court affirmed, holding that Employer was a proper party to the action because it was the identified employer and paid the necessary contributions under Wyoming Worker's Compensation Act. View "Heikkila v. Signal Mountain Lodge" on Justia Law

Appellant was injured in a work-related accident in 1996. In 2009, Appellant was diagnosed with a labral tear in his left shoulder. The Workers' Safety and Compensation Division denied Appellant's request for payments for the treatment of the labral tear, determining that the current condition of Appellant's left shoulder was not due to the 1996 work-related accident. The Office of Administrative Hearings affirmed the denial. The district court affirmed. The Supreme Court affirmed, holding that the Division's decision that the injury was not causally connected to a work-related accident was supported by substantial evidence. View "Hampton v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

After Appellant was terminated from his employment with Employer, Appellant applied for and was granted unemployment benefits. Employer appealed. After a hearing, a hearing examiner affirmed and found that Appellant was entitled to unemployment benefits. The Unemployment Insurance Commission reversed, finding that Appellant was not entitled to unemployment benefits. The district court affirmed. The Supreme Court affirmed, holding (1) as a matter of law, the Commission acted within its authority when it reviewed and reversed the hearing examiner's decision to grant Appellant unemployment benefits; and (2) the Commission's determination that Appellant was terminated for engaging in misconduct and was thereby not entitled to unemployment benefits was supported by substantial evidence in the record. View "Koch v. Dep't of Employment, Unemployment Ins. Comm'n" on Justia Law

In 1994, while working on a drilling rig, Appellant fell and injured his back. Consequently, Appellant had three back surgeries between 1995 and 2004. The Worker's Compensation Division paid Appellant worker's compensation benefits for his treatment from the date of his injury through the 2004 surgery. In 2009, Appellant fell on the ice at his home and underwent a fourth back surgery, for which he sought benefits. The Division denied Appellant's claim, and the Medical Commission upheld the denial, concluding that Appellant failed to prove the 2009 surgery was causally connected to his 1994 work injury. The district court affirmed the denial. The Supreme Court reversed, holding (1) the Commission applied the incorrect legal standard in determining whether Appellant proved that his 2009 surgery was causally connected to his 1994 work injury; and (2) under the correct legal standard, the decision to reject Appellant's evidence was contrary to the overwhelming weight of the evidence. Remanded. View "Hoffman v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

Appellant was injured in an accident that occurred during the course of her employment. After receiving a permanent partial impairment award from the Wyoming Worker's Compensation Division, Appellant sought permanent partial disability benefits. The Division denied Appellant's application, stating that she had not complied with the statutory work search requirements. After a contested case hearing, the Office of Administrative Hearings granted summary judgment for the Division, concluding that Appellant had not timely submitted documentation showing she had sought work. The district court affirmed. The Supreme Court reversed, holding (1) Appellant's work search submission was timely; and (2) Appellant was entitled to a hearing and the opportunity to present evidence showing that she actively sought work. View "Stallman v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law