Justia Labor & Employment Law Opinion Summaries

Appellant received worker’s compensation benefits in 1996 and 2004 for work-related injuries to his back. In 2008 and 2011, Appellant underwent surgeries to treat a herniated disc in his low back. The Wyoming Workers’ Compensation Division denied Appellant’s application for benefits to cover the two surgeries and any other expenses incurred after 2005. On appeal, Appellant contended that the herniated disc was a direct result of his 1996 and 2004 injuries and was therefore a second compensable injury. The Office of Administrative Hearings (OAH) upheld the Division’s denial of benefits. The district court affirmed. The Supreme Court affirmed, holding that the OAH’s decision upholding the denial of benefits was supported by substantial evidence and not contrary to the overwhelming weight of the evidence. View "Bodily v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

In 2005, Tara Kobielusz began working for Circle C Resources, which provides living assistance for persons with developmental disabilities. In 2010, Kobielusz began working for Circle C as a “host family provider.” That same year, Kobielusz fell and broke her ankle when entering Circle C’s office to pick up Kobielusz’s clients from their day habilitation program. The Workers’ Safety and Compensation Division found Kobielusz had suffered a compensable injury. Circle C requested a contested case hearing before the Office of Administrative Hearings (OAH), arguing that Kobielusz was not an employee, but rather, an independent contractor. The OAH upheld the Division’s determination. The district court affirmed. The Supreme Court affirmed, holding that Kobielusz did not qualify as an “independent contractor” under the meaning of the Worker’s Compensation Act. View "In re Worker's Comp. Claim of Kobielusz" on Justia Law

Appellant first received benefits for work-related injuries he received to his knees in 1992. In 2009, Appellant requested preauthorization to perform total knee replacement on both knees. The Workers’ Safety and Compensation Division denied the request and also denied payment of continued treatment of Appellant’s knees, concluding that the treatment and total knee replacements were not associated with the 1992 work injury. After a contested case hearing, the Medical Commission upheld the Division’s decision. The Supreme Court affirmed, holding (1) the Medical Commission did not commit prejudicial error during the hearing by admitting into evidence, over Appellant’s objection, three exhibits; and (2) substantial evidence supported the Commission’s decision. View "Johnson v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

Appellant was originally injured in 1975 while working for his employer. Appellant’s injuries resulted in the amputation of his right leg, below the knee. The Wyoming Workers’ Safety and Compensation Division paid a number of benefits over the years. Years later, Appellant began receiving chiropractic treatment, including cold laser therapy, from Utah Spine and Disc Clinic in Murray Utah. Appellant sought reimbursement for travel to and from the clinic. In 2011, the Division denied Appellant’s request for reimbursement because (1) traditional types of chiropractic care, manipulation, and traction could have been obtained at a location in Wyoming closer to Appellant’s home; and (2) cold laser therapy was considered experimental and was therefore not a covered treatment for which the Division would pay travel expenses. The Supreme Court affirmed, holding that the Division did not err in its interpretation of the applicable Wyoming statutes, and the Division’s decision contained adequate findings of fact, which findings were supported by substantial record evidence. View "Birch v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law

In 1999, Appellant experienced a workplace injury to her back, for which she received benefits awarded by the Wyoming Workers’ Safety and Compensation Division (“Division”). In 2008, while employed in Nebraska, Appellant suffered a second workplace injury. Appellant filed a worker’s compensation claim in Nebraska relating to her 2008 injury and subsequently settled that claim. In 2010, Appellant sought payment for prescription medication for headaches she was experiencing, claiming that the treatment was related to her 1999 injury. The Division denied benefits, concluding that the treatment and medications were unrelated to the original compensable 1999 injury. After a contested case hearing, the Office of Administrative Hearings upheld the Division’s denial of benefits. The district court affirmed. The Supreme Court affirmed, holding that substantial evidence supported the hearing examiner’s finding that there was no causal connection between Appellant’s headaches and her 1999 workplace injury. View "Landwehr v. State ex rel. Workers' Safety & Comp. Div. " on Justia Law

In 1994, Appellant suffered modest physical injuries while working as a psychiatric aide at the Wyoming State Hospital. Four years later, Appellant was denied permanent total disability (PTD) benefits. Appellant continued seeking medical treatment. Appellant reapplied for PTD benefits in 2009, but the Wyoming Workers’ Safety and Compensation Division denied her claim. After a case hearing, a panel of the Medical Commission denied the subsequent application for PTD benefits, concluding that Appellant’s only disabling condition was psychological and not related to any compensable physical injury. The district court affirmed. The Supreme Court affirmed, holding that the Commission reasonably concluded that Appellant did not establish entitlement to PTD benefits under the Wyoming Workers’ Compensation Act or the odd lot doctrine, and the Commission’s conclusions were in accordance with applicable law. View "In re Worker's Comp. Claim of Hathaway" on Justia Law

A school district (District) notified Plaintiff, a continuing contract teacher in the District, that his contract would be terminated on grounds of incompetence, insubordination, and poor work performance. Following a hearing, an independent hearing officer concluded that good cause existed for the termination of Plaintiff’s teaching contract and recommended that the contract be terminated for insubordination. The school district board of trustees (Board) accepted the hearing officer’s recommendation and conclusion. Plaintiff appealed, arguing that the Board’s order was entered in violation of the Wyoming Administrative Procedure Act (APA) and his due process rights because some members of the Board did not attend the entire hearing or otherwise review all of the evidence submitted to the hearing officer. The Supreme Court affirmed, holding that the Board did not err by accepting the hearing officer’s recommended decision without independently reviewing the entire evidentiary record received by the hearing officer. View "Wadsworth v. Bd. of Trs. of Lincoln County Sch. Dist. No. Two" on Justia Law

Plaintiffs filed a medical malpractice action against the Campbell County Memorial Hospital under the Wyoming Governmental Claims Act (Act), alleging that Amanda Phillips, a certified nurse anesthetist for Northern Plains Anesthesia Associates, which provided anesthesia services for the hospital, acted as an employee or agent of the hospital, making the hospital vicariously liable for Phillips’ alleged negligence. The hospital filed a motion for partial summary judgment, arguing that a government hospital could not be vicariously liable for acts of non-employees or independent contractors under the doctrine of ostensible agency. The district court denied the motion based on Sharsmith v. Hill. The Supreme Court reversed, holding that the district court erred in its interpretation of Sharsmith and that Sharsmith did not create an implied waiver of sovereign immunity under the Act. View "Campbell County Memorial Hosp. v. Pfeifle" on Justia Law

When the Union and the City entered into negotiations regarding the 2012-2013 wages and other employment terms for the City's fire department members, the City included in its negotiating team the mayor, one city council member, and other members of the City's administration and staff. The Union eventually filed a declaratory judgment seeking a ruling that a quorum of the city council was required to negotiate with the Union, the City could not unilaterally decide to conduct the negotiating sessions in public, and the proposals exchanged by the parties were not public records. The district court granted summary judgment declaring that a quorum of the city council was not obligated to participate in the negotiations and that the other two issues were not justiciable. The Supreme Court reversed in part and affirmed in part, holding that the statutes mandate a quorum of the city council to negotiate with the Union and that the other two issues were not justiciable. View "Int'l Ass'n of Firefighters Local Union No. 279 v. City of Cheyenne" on Justia Law

After Appellant suffered a workplace injury to his knees in 1993, the Wyoming Workers' Safety and Compensation Division (Division) awarded him benefits. In 2009, Appellant sought payment for a left knee arthroscopy, claiming the treatment was related to his workplace injury. The Division denied benefits relating to treatment of Appellant's left knee. After a contested case hearing before the Office of Administrative Hearings (OAH), the hearing examiner upheld the Division's decision. The district court affirmed the hearing examiner's order. The Supreme Court affirmed, holding (1) the hearing examiner's finding was supported by substantial evidence; and (2) the OAH did not abuse its discretion in excluding hearsay testimony from Appellant regarding the medical opinion of his treating physician. View "Trump v. State ex rel. Wyo. Workers' Safety & Comp. Div." on Justia Law