Justia Labor & Employment Law Opinion Summaries

In 2013, William Rogers was working for Russell Construction Company (Russell) when he claimed to have fallen against a ledge of old concrete. In 2014, the Workers' Compensation Division issued a determination that Rogers had suffered a compensable injury. Russell objected to that determination, arguing that the claim was fraudulent. A hearing officer with the Office of Administrative Hearing denied Rogers’s claim for worker’s compensation benefits, concluding that Rogers had not proved that he suffered a compensable injury in 2013. The district court affirmed. The Supreme Court affirmed, holding that the hearing examiner’s determinations of fact were reasonable and based on substantial evidence. View "Rogers v. Russell Constr. Co., Inc." on Justia Law

Petitioner was discharged from her position as high school principal of the St. Stephens Indian School for “not promptly assessing a student who was potentially intoxicated and allowing the student to remain in class while [Petitioner] left the building.” Petitioner applied for unemployment insurance benefits. A deputy for the Unemployment Insurance Division denied Petitioner’s claim, determining that she was discharged for misconduct connected with her work. On appeal, a hearing officer ruled that Petitioner was discharged from her unemployment but not for misconduct connected with her work. The Department of Workforce Services, Unemployment Insurance Commission reversed. The district court reversed, ruling that the Commission’s decision was not supported by substantial evidence. The Supreme Court affirmed, holding that the record did not support a conclusion that Petitioner’s action was anything more than ordinary negligence or a good faith error in judgment. View "State ex rel., Dep’t of Workforce Servs., Unemployment Ins. Comm’n v. Kinneman" on Justia Law

Appellant Mary Leib sought benefits from the Wyoming Workers’ Compensation Division after she developed abscesses in her breasts. Leib was employed as a maintenance worker for Laramie County Community College in Cheyenne. She began working on the grounds of the College in April 2012. As part of her duties as a groundskeeper, Leib was required to work with dirt that was mixed with untreated manure from livestock kept on campus and from traveling circus animals. In June 2012, approximately two weeks after she began planting flowers using the dirt and manure mixture, Leib experienced pain and swelling in both of her breasts. She sought treatment at the emergency room, where she was diagnosed with mastitis. Upon returning to work, the swelling developed again. The second time she sought treatment, her surgical incisions split open. Subsequent cultures indicated that several different types of peptostreptococcus bacteria were present. The Division denied the claim. The Medical Commission upheld the Division’s determination after finding that she had not met her burden of proving that her condition was related to her employment. Leib appealed to the district court, which affirmed the Medical Commission’s order. She challenged the district court’s decision in this appeal. Finding no reversible error, the Supreme Court affirmed. View "In the Matter of the Worker's Compensation Claim of: Leib v. Wyoming, ex rel., Department of Workforce Services, Workers' Compensation Division" on Justia Law

Charley Collins and his son, Brett, were both employed by COP Wyoming, LLC. Roger Ross, a job superintendent, was operating a track hoe when he struck Brett in the head, severely injuring him. Brett died from his injuries. Charley sued COP Wyoming and Ross, alleging that he suffered emotional injuries after he witnessed his son’s death. The district court concluded that Charley’s claims were derivative of the covered death of the son and were therefore barred by worker’s compensation immunity. The Supreme Court reversed, holding that Charley’s claim for emotional injury is based upon a duty to him that is independent of the covered death of his son and is not barred by worker’s compensation immunity. View "Collins v. COP Wyoming, LLC" on Justia Law

Appellant, a long-term Game & Fish employee, was terminated after two disciplinary suspensions and her filing of a complaint alleging hostile work environment sexual harassment, grieving the disciplinary suspensions, and filing a charge of discrimination. The Office of Administrative Hearings concluded that “good cause” supported the disciplinary actions and that they were supported by substantial evidence. The district court affirmed. The Supreme Court affirmed, holding (1) no facts asserted by Appellant adequately supported a due process claim “of such a fundamental nature that it must be considered” for the first time on appeal; and (2) Appellant failed to preserve her claim that her suspensions were issued without authority. View "Crofts v. State ex rel. Dep’t of Game & Fish" on Justia Law

During the 2011-2012 school year, Plaintiff was a continuing contract teacher who worked for the Laramie County School District No. One. In spring of 2012, the District Superintendent gave Plaintiff notice that he proposed that Kinstler be terminated. On September 4, 2012, a hearing officer recommended that the District accept the Superintendent’s proposal. On September 17, 2012, the District’s Board of Trustees voted to accept the recommendation. Kinstler was paid his normal salary from August 15, 2012, the date he would have started to work, through the date that the Board acted on the recommendation to terminate him. Kinstler subsequently sued the District, asserting that the District failed to pay him the salary and value of benefits allegedly owed him for the 2012-2013 academic year. The district court partially granted Kinstler’s motion for summary judgment and entered an order with respect to his salary and benefits claim. The Supreme Court reversed and vacated the award, holding that because Kinstler’s termination was effective at the end of the 2011-2012 school year, he had no statutory right to compensation following that date. View "Laramie County Sch. Dist. v. Kinstler" on Justia Law

Erin Clements was injured at work and received temporary total disability (TTD) benefits for twelve months. Clements subsequently obtained an extension of TTD benefits for the statutory maximum of twelve months. When Clements applied for additional TTD benefits, the Worker’s Safety and Compensation Division denied her claim because she had received all the TTD benefits to which she was entitled under Wyoming law and Division rules. Clements filed a declaratory judgment action seeking a declaration that the Division exceeded its authority when it limited the extension of TTD benefits to twelve months. The district court granted declaratory relief. The Supreme Court affirmed, holding that the Division exceeded its authority when it adopted a rule setting a maximum number of months TTD benefits are payable under any circumstances. View "State ex rel. Dep't of Workforce Servs. v. Clements" on Justia Law

In 2004, Appellant fell while working and strained her back. Appellant was awarded worker’s compensation benefits. In 2009, Appellant slipped and fell at work and injured her ankle. In 2010, Appellant sought temporary total disability and medical pay benefits from the Workers Compensation Division, which denied Appellant’s requests. After a contested case hearing, the Office of Administrative Hearings (OAH) upheld the Division’s denial of Appellant’s request for benefits, concluding Appellant did not meet her burden of proving that she suffered aggravation of a preexisting back condition as a result of a work related injury or that she suffered a second compensable injury. The district court affirmed. The Supreme Court affirmed, holding that the OAH did not err by failing to find a causal connection between the 2009 workplace incident and Appellant’s delayed back pain. View "Hirsch v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Robert Carson and his passenger, Hugh Sharp, were involved in a car accident in which Carson sustained multiple injuries and Sharp was killed. Carson filed a claim for worker’s compensation benefits. The Wyoming Workers’ Safety and Compensation Division denied benefits, finding that Carson’s injuries did not arise out of and in the course of his employment with Metrocities Mortgage, LLC. The Office of Administrative Hearings (OAH) upheld the denial of Carson’s claim. Meanwhile, Sharp’s widow filed a wrongful death action against Carson and Metrocities. After a trial, a federal jury entered judgment against Metrocities under the theory of respondeat superior, concluding that Carson was acting within the course of scope of his employment when the accident occurred. On the basis of the federal judgment, Carson submitted a motion to reopen his claim with the OAH, contending that there was newly discovered evidence he was acting within the course of his employment at the time of the accident. The OAH eventually affirmed its earlier decision. The Supreme Court affirmed, holding that the OAH did not err when it failed to apply collateral estoppel to the issue of whether Carson was in the course and scope of his employment at the time of his injury. View "Carson v. State ex rel., Wyo. Workers' Safety & Comp. Div." on Justia Law

In 2007, Appellant suffered a work-related injury to his right hip. In 2009, the Wyoming Workers’ Safety and Compensation Division denied Appellant’s requests for testing and treatment of pain in his back on the grounds that the requests were unrelated to Appellant’s work injury. The Office of Administrative Hearings (OAH) reversed and ordered that one additional test be performed to determine whether Appellant’s back problems were associated with his work injury. After the results of the test came back normal, the hearing examiner ordered that Appellant was not entitled to further benefits for his back. The district court affirmed. The Supreme Court affirmed as modified, holding (1) substantial evidence supported the OAH decision that Appellant did not satisfy his burden of proving additional testing and treatment of his back were related to his work injury; but (2) future treatment associated with the original hip injury could be submitted for administrative review. View "Delacastro v. State ex rel., Wyo. Workers' Safety & Comp. Div." on Justia Law