Justia Idaho Supreme Court Opinion Summaries

Claimant Amanda Wilson filed a complaint under the Worker’s Compensation Act to obtain benefits for a back injury that she alleged was caused or aggravated in the Spring of 2011. On February 15, 2008, Claimant had visited an emergency room in a hospital in Gilbert, Arizona, complaining that for one year she had back pain and right leg radiculopathy with a recent flare-up. On October 4, 2010, Claimant sought additional treatment for her low-back pain and right-leg sciatica at a health clinic in Twin Falls. On February 7, 2011, Claimant began working for Employer Conagra Foods Lamb Weston in Twin Falls. She had previously worked at Employer’s premises as an employee of a temp agency, performing general manual labor, including shoveling potatoes. On April 5, 2011, Claimant visited a nurse practitioner because of back pain. Claimant described bilateral sciatic pain radiating to her heel that had begun six months earlier. On April 6, 2011, Claimant sought medical care at a hospital emergency room in Twin Falls. She complained of increasing low-back pain over the prior three weeks, which initially started while shoveling potatoes while working for Employer. On April 8, 2011, Employer learned from the hospital and physician of Claimant’s trip to the emergency room regarding a work injury. Employer immediately suspended Claimant pending further investigation of whether she had violated its safety policies (to notify the Plant Manager of any injury, "regardless of how minor it may be at the time"). Employer contacted the emergency-room physician, and he was adamant that Claimant had reported to him that she was injured at work and that his notes so reflected. On April 13, 2011, Claimant visited another physician because of low-back pain and numbness in her legs. Employer terminated Claimant on April 18, 2011, for misconduct by failing to report an on-the-job injury in violation of the employee handbook. Claimant filed for unemployment compensation, but her claim was denied on the ground that her knowing violation of the policy constituted misconduct in connection with her employment. Claimant then applied for workers' compensation benefits. The matter was heard before a referee, who submitted proposed findings of fact, conclusions of law, and recommended order. The Industrial Commission declined to adopt the referee’s recommendation and issued its own findings of fact, conclusions of law, and order, finding that Claimant had failed to prove that she suffered an injury caused by an accident arising out of and in the course of her employment. Claimant appealed, but finding no reversible error in the Commission's decision, the Supreme Court affirmed. View "Wilson v. Conagra Foods Lamb Weston" on Justia Law

Claimant Clarence Copper was an employee of Ace Hardware / Sannan, Inc. from 2004 until he was terminated in 2014. Prior to termination, Claimant was reprimanded numerous times for failing to perform his job duties. Claimant appealed an order of the Industrial Commission that the he was not entitled to unemployment benefits because he was discharged for misconduct in connection with his employment for violating his employer’s written policies. Finding no reversible error after review of the record, the Supreme Court affirmed the Commission's order. View "Copper v. Ace Hardware" on Justia Law

Kelli Sevy sustained a work-related injury on October 31, 2006, and contended that she was totally and permanently disabled. The Industrial Commission found that Sevy failed to meet her burden of establishing total and permanent disability. Although the Commission found that Sevy was “profoundly disabled,” the Commission held that Sevy had failed to demonstrate that the accident contributed to her disability beyond a 2% permanent partial impairment (PPI). Sevy argued on appeal that the Commission’s decision that she did not suffer disability in excess of her impairment is not supported by substantial and competent evidence. Finding no reversible error, the Supreme Court affirmed. View "Kelli Sevy v. SVL Analytical, Inc." on Justia Law

Plaintiff-appellant Jeffrey Huber brought this action against his former employer, Lightforce USA, Inc. (“LFUSA”), for breach of contract and failure to pay wages. Huber’s claims centered on two employment agreements: a Company Share Offer (“CSO”), and a Deed of Non-Disclosure, Non-Competition and Assignment (“NDA”). Huber claimed that upon his termination LFUSA was obligated to pay him the value of 30% of the goodwill of LFUSA under the CSO and twelve months’ pay under the NDA. The parties agreed that the CSO was a deferred compensation plan and was, therefore, governed by the Employee Retirement Income Security Act (“ERISA”). At a bench trial, Huber succeeded only on his breach of contract claim under the NDA. Huber timely appealed the district court’s rulings on summary judgment: (1) holding that the amount owed under the NDA was not wages under the Idaho Wage Claims Act, (2) dismissing his wrongful termination claim, and (3) holding that the CSO was a “top hat” plan under ERISA and, therefore, exempt from ERISA’s vesting and anti-forfeiture provisions. Huber also appealed the district court’s ruling at trial that Huber forfeited the benefit under the CSO, and the district court’s rulings on post-trial motions: (1) denying his claim for equitable relief, (2) calculating Huber’s award of prejudgment interest, and (3) awarding attorney fees and costs to LFUSA. The Supreme Court affirmed the district court in part and reversed in part, finding: (1) the CSO was a top hat plan under ERISA and that Huber forfeited the benefit under the CSO; (2) it was proper to deny Huber’s claim for equitable relief and denying Huber’s motion to amend his complaint to conform to the evidence; (3) the district court erred by ruling that the amount owed under the NDA was not "wages" under the Idaho Wage Claims Act; (4) the district court erred with respect to prejudgment interest and costs and fees to LFUSA. The case was remanded back to the district court to treble the $180,000 judgment. Post-judgment interest shall accrue on the trebled amount of $540,000 from December 10, 2013, the date of entry of the judgment. View "Huber v. Lightforce USA, Inc." on Justia Law

In 2013, claimant Scott Chadwick filed a complaint with the Industrial Commission seeking benefits under the Worker’s Compensation Law from his employer, Multi-State Electric, LLC, and its surety, Idaho State Insurance Fund. Claimant alleged that he had suffered back injuries as a result of two separate accidents at work in 2012. The matter was tried to a referee, but the Commission did not adopt the referee’s recommendations. After considering the Claimant’s prehearing deposition, the testimony presented during the evidentiary hearing before the referee, and the exhibits, the Commission issued its findings of fact, conclusions of law, and order. The Commission found that Claimant failed to prove that he suffered an injury from a workplace accident in a May event and that he failed to prove that a July event occurred. The Commission alternatively found that he had failed to provide timely notice to his employer of both claimed accidents, and that he failed to prove that Employer was not prejudiced by the failure to give timely notice. Therefore, he was denied benefits. Claimant then timely appealed. Finding no reversible error, the Supreme Court affirmed the Commission. View "Chadwick v. Multi-State Electric, LLC" on Justia Law

Claimant Barbara Kelly was an employee of Blue Ribbon Linen Supply, Inc. when a cart rolled over her left foot. She filed for workers’ compensation benefits. Kelly sustained additional injuries in an automobile accident when returning home from an Independent Medical Evaluation (IME) scheduled by the Idaho State Insurance Fund (Surety) in connection with the cart incident. The Industrial Commission concluded that Kelly’s injuries from the automobile accident were not compensable because they did not arise out of and in the course of her employment with Blue Ribbon. The Supreme Court concluded after review that the causal connection between Kelly’s employment and the injuries she sustained as a result of the accident was sufficiently compelling that it held that the injuries arose out of and in the course of her employment. Accordingly, the Court reversed the Commission’s decision and remanded for further proceedings. View "Kelly v. Blue Ribbon Linen Supply, Inc." on Justia Law

On August 13, 2013, the Idaho Department of Labor (IDOL) mailed two Determinations of Overpayment and an Eligibility Determination to Mitchell Kennedy at the address he had provided when filing for unemployment benefits. The Determinations informed Kennedy that he had the right to appeal, or protest, the Determinations and that the last day to do so was August 27, 2013. On August 21, 2013, Kennedy moved to a new residence. He changed his address with the U.S. Postal Service. Kennedy received the Determinations on August 24, 2013, three days before the deadline. He did not read them until either August 26 or 27. The Industrial Commission made no specific finding as to when Kennedy read the letters but did find that “Claimant did not closely review the Determination to realize the applicable appeal dates due to work and other personal priorities.” Kennedy faxed his protest to IDOL on August 29, 2013, two days after the deadline. In the transmission of that protest, Kennedy informed IDOL of his new address. The appeals examiner found that Kennedy’s request for an appeals hearing was not timely and therefore the examiner had no jurisdiction to hear Kennedy’s appeal. Kennedy appealed, and the Commission affirmed the examiner’s decision. Kennedy then requested reconsideration from the Commission. Finding that Kennedy had not presented any further argument on the relevant issues, the Commission denied the motion. Kennedy timely filed this appeal under Idaho Code section 72-1368(9) and Idaho Appellate Rules 11(d) and 14(b). But finding no reversible error in the Commission's decision, the Supreme Court affirmed. View "Kennedy v. Hagadone Hospitality Co." on Justia Law

In 2004 when he was sixteen years old, claimant Terence Fairchild worked for Kentucky Fried Chicken as a cook. While carrying garbage to a dumpster, he slipped on ice and fell onto a concrete barrier, striking his knees. The impact caused his knees to bleed. He went inside the building, bandaged his knees, and informed his supervisor of the accident. Claimant sought medical care. The physician diagnosed his condition as patellofemoral pain following bilateral patella contusions and prescribed knee braces, stretching exercises, Naprosyn, and ice. He saw the physician one week later and continued to suffer pain in both knees. The physician prescribed physical therapy, which failed to alleviate Claimant’s symptoms. The physician ordered an MRI of Claimant’s left knee a few weeks later. The MRI did not reveal any abnormality. After reviewing the results of the MRI with an orthopedist, the physician continued Claimant on physical therapy and anti-inflammatory medication. Approximately one month following the accident, Claimant filed a complaint seeking benefits under the Worker’s Compensation Law. Claimant sought a second, third and fourth opinions, including one from an orthopedic surgeon. These opinions spanned approximately seven years following the initial fall. In 2007, the orthopedic surgeon suspected claimant suffered a partial posterior cruciate ligament injury to his right knee and concluded that Claimant was entitled to a permanent partial impairment of 3%. In 2011, an examining physician agreed Claimant suffered a partial posterior cruciate ligament injury, but estimated the permanent partial impairment of 7%. In a 2012 hearing, the Industrial Commission found Claimant was not a credible witness based upon its observation of him during the hearing and the differences between his hearing testimony and his prior statements in depositions, interviews, and appointments with medical providers. The Commission concluded that it regarded Claimant’s testimony as suspect where it was not supported by other evidence in the record. The Commission found that Claimant had suffered a right posterior cruciate ligament injury in the accident and that as a result of that injury he had a permanent partial impairment rating of 3%. Finally, the Commission found that Claimant had failed to prove that he had a disability in excess of his impairment. Claimant filed a motion for reconsideration, which the Commission denied. Claimant then appealed. Finding no reversible error, the Supreme Court affirmed the Commission's judgment. View "Fairchild v. Kentucky Fried Chicken" on Justia Law

This appeal arose out of a district court’s decision to affirm a magistrate court’s order granting Michelle Campbell relief on her breach of contract claim. This case stemmed from an employment offer Parkway Surgery Center, LLC made to Campbell. The offer included assurances that Parkway would “take care of” a loan Campbell had with her previous employer, Bingham Memorial Hospital (BMH). When Parkway refused to pay the obligation as promised, Campbell filed suit for a breach of contract. Following a bench trial, the magistrate court ruled in favor of Campbell and awarded her damages in the amount of the loan plus interest. Parkway appealed to the district court, which affirmed the magistrate’s order, but remanded to the magistrate court to reform the judgment to grant Campbell specific performance. Parkway appealed to the Idaho Supreme Court. On appeal, Parkway raised several arguments, including that the district court erred when it: (1) affirmed the magistrate court’s order; (2) determined Campbell was entitled to specific performance; (3) determined the statute of frauds did not apply in this case; and (4) awarded attorney fees to Campbell. Upon review, the Supreme Court concluded the trial court erred in reforming the magistrate court's judgment to grant Campbell specific performance. The court affirmed the district court in all other respects. The case was remanded for further proceedings. View "Campbell v. Parkway Surgery" on Justia Law

Appellant Kevin Stokes employed Respondent Sohar Chavez as a part-time irrigator on Stokes's farm. During the course of his employment, Chavez was injured when his finger slipped into the chain of a motor on an irrigation line. Chavez's finger could not be reattached, and a physician amputated it. A few days after the injury, Life Flight billed Chavez $21,201.00 for transport from the farm to the hospital. Chavez then filed a claim for worker's compensation. Stokes, as the employer of Chavez, was uninsured for purposes of worker's compensation law, but paid all medical expenses related to the injury except the Life Flight bill, which he has disputed, contending that the transport was unreasonable. The Idaho Industrial Commission determined that the Life Flight transport was reasonable under Idaho Code section 72-432(1). Stokes appealed the Commission's judgment. Finding no reversible error, the Supreme Court affirmed. View "Chavez v. Stokes" on Justia Law