Justia Labor & Employment Law Opinion Summaries

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

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

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

The Supreme Court affirmed the judgment of the Medical Commission Panel denying Appellant's application for additional benefits and an increase to her impairment rating, holding that the Medical Panel's decision was not arbitrary, capricious, or otherwise not in accordance with the law.In 2014, Appellant suffered a workplace injury. In 2019, Appellant applied for additional benefits, including surgery for carpal tunnel syndrome, and an increase to her impairment rating. The Medical Panel denied both requests, determining (1) Appellant's carpal tunnel syndrome was not related to her workplace injury, and (2) Appellant's claim for an increased impairment rating was unsubstantiated. The Supreme Court affirmed, holding that the Medical Panel's ultimate determinations were supported by substantial evidence and were not arbitrary, capricious, or otherwise not in accordance with law. View "Reichenberg v. State, ex rel., Department of Workforce Services" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that Charlene Hassler had breached a court-modified agreement and granting summary judgment for Circle C Resources on its breach of a noncompete agreement claim, holding that the blue pencil rule is no longer permitted to make noncompete agreements reasonable.When she was hired by Circle C as a nursing assistant Hassler signed a noncompetition agreement prohibiting Hassler from soliciting Circle C's clients for twenty-four months after their employment relationship ended. After Hassler was hired by a new provider Circle C brought this action seeking damages for breach of the noncompete agreement. The district court granted summary judgment for Circle C, concluding that the noncompete agreement was reasonable enforceable if the geographical area subject to restriction were narrowed. The court then narrowed the restrictions accordingly. The Supreme Court reversed, holding (1) this Court no longer permits use of the blue pencil rule to make noncompete agreements reasonable; and (2) because the duration and geographical terms of the noncompete agreement were unreasonable the entire agreement was void in violation of public policy. View "Hassler v. Circle C Resources" on Justia Law

The Supreme Court affirmed the decision of the district court reversing the decision of the Board of Trustees of Lincoln County School District Number Two dismissing Wyatt Earling from his teaching position pursuant to Wyo. Stat. Ann. 21-7-110(a)(ix), holding that there was no error.When Earling was hired in 2004, the District issued him an Apple laptop. Earling created an Apple ID and used that same ID on District-issued Apple devices for the next fifteen years. In 2018, personal photos and images from Earling's iPhone began synching to an iPad. When Superintendent Matt Erickson discovered inappropriate photos and images on the iPad, Earling was terminated. The district court reversed the Board's decision, concluding that substantial evidence did not support the decision. The Supreme Court affirmed, holding (1) the Board failed to furnish Earling a clear standard of conduct; and (2) the Board could not dismiss Earling for "[a]ny other good or just cause relating to the educational process" under Wyo. Stat. Ann. 21-7-110(a)(ix). View "Board of Trustees of Lincoln County School District Number Two v. Earling" on Justia Law

The Supreme Court reversed the judgment of the district court ruling that Western Wyoming Beverages, Inc. (WWB) would likely succeed on the merits of its claim that Jorge Malave, its employee, had breached his noncompete agreement that the WWB would suffer irreparable harm of Malave were not enjoined from continuing to work for WWB's competitor, holding that the district court erred.The district court concluded that there was a valid and reasonable noncompete agreement between the parties and that WWB would likely succeed on the merits of its claim that Malave had violated the agreement and would suffer possible irreparable injury if no injunction were entered. The Supreme Court reversed, holding that WWB did not meet its burden of proving probable success on the merits of the reasonableness of its noncompete agreement with Malave. View "Malave v. Western Wyoming Beverages, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Medical Commission upholding the denial of Appellant's request for benefits, holding that there was substantial evidence to support the Commission's denial of coverage.In 2007, Appellant suffered a compensable injury to her left knee. More than a decade later, Appellant submitted requests to the Department of Workforce Services, Workers' Compensation Division to cover treatment for her right knee, ankles and back and further applied for permanent total disability (PTD) benefits. The Division denied both requests, and the Commission affirmed the ruling. The Supreme Court affirmed, holding that that there was substantial evidence to support the Commission's findings that (1) Appellant's right knee, ankle, and back injuries were not second compensable injuries; and (2) Appellant did not qualify for PTD benefits under the odd lot doctrine. View "Ross v. State, ex rel., Department of Workforce Services, Workers' Compensation Division" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the determination of the Medical Commission Hearing Panel that Scott Triplett failed to meet his burden to show entitlement to a right hip replacement, holding that the Medical Panel's decision was neither arbitrary or capricious.The Medical Panel determined that Triplett did not meet his burden of proof to establish that the hip replacement surgery was a reasonable and necessary medical treatment for any injury related to his work injury. The district court affirmed. The Supreme Court affirmed, holding that the Medical Panel's determination was supported by substantial evidence and was not arbitrary, capricious, or otherwise contrary to law. View "Triplett v. State, ex rel. Department of Workforce Services" on Justia Law

The Supreme Court reversed the judgment of the district court granting a preliminary injunction sought by Best Home Health & Hospice, LLC (Best Home) to prohibit three registered nurses (collectively, the Nurses) who left Best Home's employ and began working for a competing company, from working for Best Home's competitor, holding that the district court abused its discretion.The Nurses in this case quit working for Best Home and went to work for one of Best Home's competitors. Best Home sued them for breach of the non-compete provision in their employment contracts and requested a preliminary injunction to prohibit them from working for its competitors. The district court enjoined the Nurses from working for Best Home's competitors. The Supreme Court reversed, holding (1) Best Home did not show it was likely to succeed in establishing that the non-compete provision was consistent with public policy, and therefore, the district court abused its discretion by enjoining the Nurses from working for Best Home's competitors; and (2) the district court abused its discretion in refusing to allow the Nurses to present evidence on how enforcement of the non-compete provision would harm the public interest. View "Brown v. Best Home Health & Hospice, LLC" on Justia Law