Justia Idaho Supreme Court Opinion Summaries

Todd Hamilton died in an automobile accident while employed by Alpha Services, LLC. The Idaho Industrial Commission found that the accident arose out of and in the course of Hamilton’s employment and determined that Hamilton’s widow and two children were entitled to statutory death benefits under Idaho’s worker’s compensation laws. Alpha and its surety, Dallas National Insurance Company, argued on appeal to the Supreme Court that the Commission’s decision was not supported by substantial and competent evidence. Finding no reversible error, the Supreme Court affirmed. View "Hamilton v. Alpha Services, LLC" on Justia Law

Claimant Gina Poledna was employed by Thorne Research, Inc. (Employer). Her work required repetitive tasks, and over time she began experiencing pain in her wrists. She saw a physician who diagnosed her as having ganglion cysts in both wrists. Her physician stated that Claimant could return to work and recommended that she wear a brace. The physician saw Claimant again and noted that her pain “fairly well quieted down” and that she has “slight discomfort with excessive twisting . . . otherwise she can do what she wants.” Claimant’s wrist pain worsened, and she returned to her physician a few years later, who informed her that she had bilateral carpal tunnel syndrome and that her work caused the pain to get worse. After receiving that diagnosis, Claimant met with Employer and requested other work duties that did not require the repetitive motion of her current job. Employer told her that no other type of work was available. Claimant decided that she would quit her employment. She went on vacation on Thursday, December 19, 2013, and on December 30, 2013, she gave Employer a clinic note from her physician. Employer told Claimant that there were no light duty positions available. Claimant decided not to return to work with Employer, so her last day of employment was December 18, 2013. Claimant filed a claim for unemployment benefits, which was denied. She appealed to an appeals examiner. In a report prepared by Claimant's physician, the physician stated that he did not advise Claimant to “[t]ake time off from work,” to “[c]hange occupations,” to “[m]ove to another area,” or to “[d]iscontinue working.” He further stated that the only limitation of which he advised her regarding the kind, amount, conditions, or place of her work was that she was to wear a brace at work. Finally, he stated that Claimant could work full time. During the hearing, Claimant admitted that her physician never told her that she needed to quit her job. The appeals examiner issued a decision denying Claimant unemployment benefits because “there is no evidence in the record to suggest her medical condition made work impossible,” which Claimant was required to prove in order to establish that she quit work with good cause connected to her employment. Claimant the appealed to the Industrial Commission, which later upheld the appeals examiner’s decision not to reopen the hearing, and it concluded that Claimant voluntarily quit her job without good cause because she failed to prove that her job was unsuitable due to her medical condition. The Commission found that the medical records from Claimant’s treating physician were more credible than Claimant’s assertions. Claimant then appealed to the Supreme Court. Finding no reversible error, the Supreme Court affirmed the Commission. View "Poledna v. Dept of Labor" on Justia Law

Elmore County’s decided to terminate employee, plaintiff-appellant Cherri Nix, without providing her a pre-termination hearing pursuant to the Elmore County Personnel Policy (ECPP). Nix filed suit alleging, among other claims, that Elmore County violated the ECPP and breached the covenant of good faith and fair dealing when it terminated her employment without giving her a pre-termination hearing. The district court granted Elmore County’s summary judgment motion on the basis that Nix was an at-will employee subject to termination at any time and for any reason, and that Nix failed to show a contractual relationship with Elmore County that would entitle her to a pre-termination hearing. Nix appealed, but finding no reversible error, the Supreme Court affirmed. View "Nix v. Elmore County" on Justia Law

LuAnn Shubert fell and injured her lower back while working at a Macy’s store. She appealed the Idaho Industrial Commission’s order holding that she was: (1) medically stable on November 21, 2007; (2) not entitled to medical benefits beyond that date; (3) not entitled to temporary disability benefits; (4) entitled to a permanent partial impairment rating of 5% of the whole person; and (5) entitled to a 10% permanent partial disability rating. Shubert argued that she was entitled to ongoing medical care, temporary disability benefits, and total permanent disability benefits over 10%. Macy’s West (Macy’s) and Liberty Insurance Corporation argued that Shubert was rearguing the facts. Finding no reversible error in the Commission's decision, the Idaho Supreme Court affirmed. View "Shubert v. Macy's West, Inc." on Justia Law

The Nampa Education Association was the local education organization representing teachers within Nampa School District No. 131 for the 2012-13 school year. The Association and the School District attempted unsuccessfully to negotiate the terms of a master employment contract for teachers in the School District. As a result, each teacher was given a contract in a form approved by the state superintendent of public instruction, which stated an amount of compensation for the teacher's services that was the last best offer by the School District. The teachers signed their contracts and began teaching pursuant to them in the fall of 2012. The School District later faced a budget shortfall. The District offered an addendum to the standard teachers' contract by which a teacher could agree to contribute one to four specified furlough days to the District. The addendum also provided that no reduction would be made for any benefits available or accruing for or on behalf of the teacher. Approximately 500 certified teachers signed an addendum to his or her standard contract, volunteering to donate one or more furlough days. After the addenda were signed, about 24 of those teachers later modified his or her respective addendum to increase or reduce the number of days being donated. On March 25, 2013, the Association filed this action seeking a declaratory judgment that the addendum contracts were unlawful and unenforceable. The District moved for summary judgment on the grounds that the Association lacked standing, the issues were moot, and they were not ripe for adjudication. The Association also moved for summary judgment on the ground that the addenda to the teachers' contracts were illegal because they had not been approved by the state superintendent of public instruction as required by Idaho Code section 33-513 and IDAPA 08.02.01.150. The district court granted the Association's motion for summary judgment and denied the School District's motion for summary judgment. The court held that the Association had standing and the issue was not moot. On the merits, the court held that the addenda modified the terms of the teachers' contracts in violation of Idaho Code section 33-513 because the addenda had not been approved by the state superintendent of public instruction. The court also held that the School District negotiating directly with the teachers to modify the terms of their contracts violated the statutory procedures for negotiating the teachers' compensation. The court entered a judgment declaring that the addenda were unlawful and unenforceable, and the School District appealed. Finding no reversible error, the Supreme Court affirmed. View "Nampa Education Association v. Nampa School District No. 131" on Justia Law

Claimant-appellant Terri Boyd-Davis filed for unemployment compensation on January 27, 2013, and began receiving benefits. IDOL claims to have mailed an "online review letter" to Boyd-Davis' listed address on March 6, 2013. The Online Review Letter indicated that Boyd-Davis had been selected to provide additional information concerning her unemployment insurance claim for the week of March 2, 2013. The Online Review Letter instructed Boyd-Davis that she would need to complete work search documentation online. The letter also indicated that failure to complete the online eligibility review by 5:00 p.m. on March 15, 2013, would result in the denial of her benefits. Boyd-Davis claimed she did not receive the Online Review Letter. When Boyd-Davis had not provided the requested information by the deadline, IDOL issued an Eligibility Determination on March 19, 2013, indicating that Boyd-Davis had failed to complete the online eligibility review and as a result was ineligible for benefits effective March 10, 2013. Boyd-Davis filed a protest. A telephonic hearing was scheduled for April 18, 2013. On April 1, 2013, Boyd-Davis provided the information IDOL had requested in the Online Review Letter. As soon as the requested information was provided, Boyd-Davis' benefits were reinstated for the week beginning March 31, 2013. However, benefits were not reinstated for the period of March 10 through March 30, 2013. Boyd-Davis proceeded with the April 18, 2013, hearing seeking restoration of her benefits for the period of March 10 through March 30, 2013. Following the hearing, an IDOL Appeals Examiner affirmed the original eligibility determination and concluded that Boyd-Davis' benefits had been properly denied. After review, the Supreme Court reversed and remanded the case for further proceedings, finding that Boyd-Davis presented evidence that "would permit reasonable minds to conclude that the Online Review Letter was not received." The Court concluded that the Commission erred in its application of the presumption of delivery articulated in Idaho Code section 72-1368(5) of the online letter. Furthermore, the Commission abused its discretion in determining that Boyd-Davis was ineligible for unemployment benefits for the period from March 10, 2013, through March 30, 2013. View "Boyd-Davis v. Macomber Law, PLLC" on Justia Law

Joan Thrall appealed an Idaho Industrial Commission decision denying her unemployment benefits. The Commission concluded that Thrall was not entitled to benefits because she voluntarily resigned from St. Luke's Regional Medical Center without good cause. Thrall timely appealed, arguing that she was discharged and that St. Luke's failed to show the discharge was for misconduct. The Supreme Court reversed and remanded this case for further proceedings. Because the Commission's factual findings demonstrate that Thrall satisfied her burden to show that she was discharged, Thrall was entitled to benefits unless the discharge was for misconduct in connection with her employment, with St. Luke's carrying the burden to show the discharge was for misconduct. When the Commission mistakenly concluded that Thrall voluntarily resigned, it improperly placed the burden on Thrall to show that she was not discharged for misconduct. "Though the Commission's order includes a variety of statements regarding misconduct and Thrall's errors in the performance of her job duties, it is unclear to what extent those statements were a consequence of its misallocation of the burden of proof." View "Thrall v. St. Luke's Regional Med Cntr" on Justia Law

Charles Bell was employed by Sears from September 25, 2012, to May 16, 2013. During that period, Bell regularly filed for unemployment benefits with the Idaho Department of Labor (DOL). He received benefits for each week beginning with the week ending on Sept. 29, 2012, through the week ending on March 23, 2013. On March 26, 2013, the DOL discovered discrepancies between the weekly gross wages reported by Bell in his unemployment filings and the gross wages reported to the DOL by Sears. Based on the information provided by Bell, the DOL determined that Bell willfully misstated his gross wages for nineteen weeks in which he received benefits and that he was ineligible for benefits for nine weeks in which he claimed to have worked part-time hours despite working at least forty hours. Bell was disqualified from receiving benefits for fifty-two weeks, ordered to repay benefits he received for the relevant periods, and ordered to pay penalties for willfully misrepresenting his gross wages and the hours he worked in particular weeks. Bell appealed the Idaho Industrial Commission's holding that he willfully made false statements or willfully failed to report material facts for the purpose of obtaining unemployment benefits. Because the Commission’s decision was supported by substantial and competent evidence, the Supreme Court affirmed. View "Charles Bell v. Idaho Dept. of Labor" on Justia Law

Claimant Newman K. ("Kal") Giles was involved in a one-vehicle accident during the course of his employment. The evidence was undisputed that Kal was driving at approximately 123 mph in a 50 mph zone at the time of the accident, that he was legally intoxicated with a blood alcohol concentration (BAC) of .11%, that he was very familiar with the road and the particular curve where the accident happened, and that he was not wearing a seatbelt. Kal also claimed to have been texting in the time leading up to the accident, though evidence of the alleged texting was not raised until opening argument at the evidentiary hearing nearly four years after the accident. The Idaho Industrial Commission conducted the hearing on the sole issue of whether Kal was barred from receiving income benefits by Idaho Code section 72-208. The referee found intoxication was a reasonable and substantial cause of the accident and injuries and concluded that Kal was barred from receiving income benefits under Idaho Code section 72-208. The Commission adopted the referee’s findings as its own. Kal appealed and finding no reversible error, the Supreme Court affirmed. View "Giles v. Eagle Farms, Inc." on Justia Law

Mercedes Turner filed suit against her former employer, the City of Lapwai, claiming that she was owed unpaid compensation and reimbursement for certain expenses incurred during her employment. The City moved for summary judgment, arguing that Turner’s claim for unpaid compensation was barred by the applicable statute of limitations and that both claims were barred because Turner failed to provide adequate notice of her claims as required by Idaho Code section 50-219. The district court granted summary judgment in favor of the City, holding that Turner failed to provide adequate notice of her claims. Turner appealed. Upon review, the Supreme Court affirmed because Turner failed to file her claim with the city clerk as required by Idaho Code sections 50-219 and 6-906. Consequently, the other issues raised on appeal by Turner and the City were not addressed. View "Turner v. City of Lapwai" on Justia Law