Justia Labor & Employment Law Opinion Summaries

The Wyoming Workers' Safety and Compensation Division issued a final determination awarding Appellant a two percent permanent partial impairment benefit after Appellant was injured in a work-related accident. After a hearing, the Medical Commission upheld the Division's final determination. The district court's issued an order affirming the Medical Commission's decision. The Supreme Court affirmed, holding (1) in light of expert opinions, the criteria set forth in the AMA Guides, Appellant's medical records, and Appellant's symptoms at the time of the hearing, the Medical Commission's findings were supported by substantial evidence; and (2) even if the Court found that the Medical Commission's credibility findings were not supported by the record, substantial evidence would remain to support the Commission's decision. View "Willey v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Petitioner was injured in an accident while driving his motorcycle to work. He filed a claim for worker's compensation benefits asserting that his injuries were covered because he sustained them while traveling to work and his employer reimbursed him for travel expenses. The Wyoming Worker's Compensation Division denied his claim. After a hearing, the Office of Administrative Hearings (OAH) also denied his claim. The district court affirmed the denial. The Supreme Court affirmed, holding that the OAH's conclusion that Petitioner failed to meet his burden of proving he was reimbursed for travel expenses was not contrary to the overwhelming weight of the evidence. View "Bilyeau v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Appellant received disability benefits due to a work-related injury. Those benefits were terminated as a result of Appellant's incarceration. Following his release, Appellant applied for reinstatement of the benefits. Although that application was initially denied, benefits were awarded following a contested case hearing. At that time, Appellant filed one application for retroactive benefits for the period during which his prior claim was contested and two additional applications for separate periods of prospective benefits. The office of administrative hearings denied all three claims for failure to comply with the Wyoming Workers' Compensation Act (Act). The district court affirmed the denial of two of those applications. The Supreme Court affirmed, holding that Appellant's applications for temporary total disability benefits did not comply with the Act because a health care provider did not perform a separate physical examination for each of Appellant's applications as required by the Act. View "Talbot v. State ex rel. Workers' Safety & Comp. Div." on Justia Law

Appellee was sexually assaulted by a county detention officer while she was an inmate at the county detention center. Appellee filed claims under the Wyoming Governmental Claims Act against the officer, the county sheriff, and the county board of commissioners for damages stemming from this assault. The sheriff, county, and county commissioners were the Appellants in these proceedings. The trial court denied the sheriff's and the county's motions for summary judgment on the claims against the sheriff for negligent supervision and training and on the sheriff's motion for qualified immunity and also denied the county's and board's motions as to statutorily imposed liability. The Supreme Court reversed, holding (1) the record did not support the trial court's ruling that the sheriff was not entitled to assert the defense of qualified immunity; and (2) based on the holding that the sheriff was entitled to qualified immunity, the ruling against the county and the board must also be reversed. View "Uinta County v. Pennington" on Justia Law

Appellant, Rodney Shafer, was injured when his tractor-trailer collided with a pickup owned by Appellee, TNT Well Service, Inc. and driven by Melvin Clyde. Shafer and his wife, Brenda, brought suit against TNT, asserting theories of negligence and vicarious liability for damages resulting from the accident. The district court granted summary judgment to TNT on all of the Shafers' claims, concluding (1) Clyde's employment had been terminated prior to the accident, and therefore, no employment relationship existed at the time of the accident; and (2) Clyde's authorization to use the TNT pickup terminated concurrently with the termination of his employment. The Supreme Court reversed, holding that summary judgment was erroneously granted with respect to the Shafers' claims of negligent supervision and negligent entrustment, as (1) TNT demonstrated the absence of a genuine issue as to the existence of each of the elements set forth in Restatement (Second) of Torts, 317; and (2) Appellants raised a genuine issue with respect to their claim that TNT was directly liable under a theory of negligent entrustment. View "Shafer v. TNT Well Serv., Inc." on Justia Law

This appeal arose out of Ryan Dorman's petition for an extension of his worker's compensation temporary total disability (TTD) benefits and for reimbursement of travel expenses incurred in travelling from Idaho to Cheyenne to obtain medical care. In May 2006, Dorman sought treatment from an Idaho physician for treatment of his alleged work-related injury. Due to the nature of Dorman's injury, he consulted multiple physicians, first in Idaho, then in Wyoming. With each consultation, the doctors indicated that the injury was outside of their scope of expertise, and referred Doman to another specialist. During the period that Dorman was changing physicians, the Division and Dorman negotiated a stipulation concerning his TTD benefits and other benefits. This followed OAH and district court decisions that largely reversed the Division's earlier determinations concerning TTD benefits and Dorman's need for continued medical treatment. The Stipulated Order also provided that medical benefits would be paid as directed by the district court's order. After the Division paid the stipulated TTD benefits, Dorman submitted a letter to the Division requesting extended benefits The Division thereafter issued a final determination denying them, and further denied several applications for travel expense reimbursement for Dorman's trips to Idaho and Cheyenne. The matters were referred to the OAH where a combined hearing was held on the denial of TTD benefits, denial of travel reimbursement, and denial of diagnostic testing related to Dorman's injury. The OAH upheld the denial of TTD benefits on the ground that Dorman had failed to make the required showing that the Idaho and Cheyenne doctors were the closest available medical providers. Dorman appealed the portion of the OAH order denying extended TTD benefits and travel reimbursement to the district court. Upon review, the Supreme Court affirmed the OAH denial of the travel reimbursement: Dorman could not prove that reimbursement of travel expenses was not supported by substantial evidence and in accordance with law.

The Wyoming Workers' Safety and Compensation Division awarded benefits to Appellant Gary Mitcheson after he fell at work and injured his tailbone in July of 2007. Approximately two years later, the Division issued a final determination denying payment for medical care that Appellant claimed was related to his workplace injury. Appellant requested a contested case hearing, and the Office of Administrative Hearings (OAH) upheld the Division's determination. Appellant appealed to the district court, which upheld the OAH's order. On appeal, Appellant challenged the OAH order contending: (1) the order was arbitrary and unsupported by substantial evidence; (2) the OAH's denial of payment for treating Appellant's tailbone was arbitrary; and (3) the OAH order denying payment for medical care contrary to the "Rule Out" rule was contrary to law. Finding the issues Appellant raised on appeal to be without merit, the Supreme Court affirmed the OAH's decision.

Appellant in this case attempted to challenge an agency decision denying her claim for unemployment benefits. Appellant filed a timely petition for review of agency action pursuant to Wyo. R. App. P. 12 (Rule 12). The district court dismissed the petition due to procedural deficiencies. Appellant subsequently filed a motion for reconsideration based on Wyo. R. Civ. P. 60 (Rule 60). The district court denied the motion. Appellant then appealed the order denying her motion for reconsideration. At issue on appeal was whether, when a district court enters a final judgment in a Rule 12 agency appeal, a party can file a Rule 60 motion to set aside the court's judgment. The Supreme Court dismissed Appellant's appeal, holding that a Rule 60 motion is not an avenue available to mount a challenge to a district court's final decision in an agency appeal.

Bill Kuhl brought wrongful termination claims against his former employer, Wells Fargo Bank, asserting claims for breach of an express contract of employment, breach of an implied contract of employment, promissory estoppel, and tortious breach of the implied covenant of good faith and fair dealing. After the parties engaged in discovery, Wells Fargo moved for summary judgment. Kuhl resisted that motion. After a hearing, the district court granted summary judgment in favor of Wells Fargo. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of Wells Fargo on any of Kuhl's claims.

Catherine Morris submitted a worker's compensation claim for permanent total disability (PTD) benefits, and the Wyoming Workers' Safety and Compensation Division denied her claim. The Wyoming Medical Commission upheld the Division's denial of benefits. The district court affirmed. The Supreme Court affirmed, holding (1) the Commission did not abuse its discretion in admitting a psychological report produced after the discovery cutoff; and (2) the Commission abused its discretion in limiting the scope of Morris' testimony to matters not discussed in the discovery deposition taken by the Division, but Morris did not object below to that limitation and thus waived her right to appeal that issue.