Justia Idaho Supreme Court Opinion Summaries

Claimant-Appellant Dennis Current appealed the Idaho Industrial Commission's denial of his unemployment benefits. Claimant argued that the Commission erred in finding he willfully made a false statement, and in failing to call one of his witnesses. The Department of Labor argued the Commission's findings were supported by substantial and competent evidence. The Supreme Court found that there was indeed substantial and competent evidence to support the Commission's findings that Claimant willfully made a false statement. The Court also found that the hearing officer did not abuse her discretion in finding that one of Claimant's witnesses would not provide relevant testimony. Accordingly, the Court affirmed the Commission's decision. View "Current v. Haddons Fencing, Inc. " on Justia Law

In Plaintiff T.J.T., Inc.'s second appeal from a summary judgment in favor of Defendant Ulysses Mori, in which the district court found that the non-competition agreement Mori allegedly breached was unenforceable under California law. This case arose from the execution of a non-competition agreement between TJT and Mori in connection with the sale of Mori’s business, Leg-It Tire Company, Inc., to TJT in 1997. Leg-It owned and operated one production facility in Woodland, California. TJT also operated in the tire and axle recycling business, and it had recycling facilities in Idaho, Oregon, and Washington at the time it purchased Leg-It in 1997. At the time of the sale of Leg-It, Mori was hired as the "Senior Vice President and General Manager of the Leg-it Tire Company Division of [TJT]." In 2000, Mori moved to Idaho and took a new position as Corporate Sales Manager. In 2007, Mori resigned as an employee of TJT and several days later, was hired by West States Recycling, Inc., a competitor to TJT, as a tire and axle salesman. In his employment with West States, Mori facilitated the opening of a warehouse facility in Idaho to support local Idaho customers who purchase tires and axles, and also solicited tire and axle business in Oregon, Washington, California, and Idaho. Because the Supreme Court in its review found that the district court erred in failing to consider whether and to what extent the agreement could be "blue penciled" to make it enforceable, the Court vacated the summary judgment and award of attorney fees and remanded the case for further proceedings. View "T.J.T., Inc. v. Mori " on Justia Law

Former engineering professor Plaintiff Habib Sadid appealed the grant of summary judgment in favor of his former employer Defendant Idaho State University which dismissed his retaliation claim. Plaintiff alleged the University retaliated against him because of his comments criticizing the administration that had been published in a local newspaper over several years and that the University had breached his employment contract. Upon review careful review of the issues Plaintiff raised in his appellate brief, the Supreme Court affirmed the judgment of the district court dismissing the amended complaint. The Court vacated the denial of attorney fees to the University and remanded this case for consideration of its request for attorney fees in defending against the breach of employment contract claim. View "Sadid v. Idaho State University" on Justia Law

Defendant Christian Rivas-Del Toro is a Mexican citizen who was residing and working in the United States illegally. In the summer of 2005, he began working as a truck driver for co-defendants Willard, Michael, and Douglas Cranney, who are collectively called "Cranney Farms," the name under which they did business. When he began work for Cranney Farms, Defendant had a valid Mexican chauffeur license. While driving a farm truck, Defendant failed to stop at a stop sign and struck another vehicle in an intersection. He contended that the trailer brakes malfunctioned. Plaintiff Beatriz Nava was driving the other vehicle, and her minor daughter was a passenger. She filed this action seeking to recover for property damage and personal injuries to herself and her daughter. In her amended complaint, she alleged that Cranney Farms was liable because it was the registered owner of the truck and Defendant was driving with Cranney Farms’s permission and that Cranney Farms had recklessly allowed the vehicle to become unsafe to operate. Cranney Farms moved for summary judgment on the ground that pursuant to Idaho Code section 6-1607 it was not liable for the negligence of its employee because he was outside the course and scope of his employment at the time of the accident. After the motion was briefed and argued, the district court held that because Defendant chose a longer route in order to avoid law enforcement because he was in the country illegally, Plaintiffs failed to satisfy Idaho Code section 6-1607(2). It ordered that Cranney Farms was entitled to a judgment dismissing the action as to it. Plaintiffs and Defendant moved for reconsideration, which the court denied. It entered judgment dismissing the action with prejudice as to Cranney Farms, and it certified that judgment as final pursuant to Idaho Rule of Civil Procedure 54(b). Plaintiffs appealed and Defendant cross-appealed. Upon review, the Supreme Court concluded that because the burden never shifted to Plaintiffs to provide evidence regarding their claim of negligent maintenance, the district court erred in granting summary judgment on that claim. Furthermore, the Court found that the ground upon which the trial court dismissed the action against the owners (that Defendant was an employee and was outside the course and scope of his employment) was not a defense to the claims alleged in the complaint, the Court vacated the district court's judgment and remanded the case for further proceedings. View "Nava v. Rivas-Del Toro" on Justia Law

Claimant-Appellant William Rigoli appealed an Industrial Commission's decision that found him ineligible for unemployment benefits because he was discharged for misconduct in connection with his employment. Claimant worked as a toy department manager for Respondent Wal-Mart, and was fired for using foul language and leaving before his assigned shift was completed. Initially, Claimant was determined by the Department of Labor to be eligible for unemployment benefits, but his employer appealed his eligibility. The Department ultimately concluded that Claimant was ineligible, and he appealed to the Industrial Commission. The Commission upheld the Department's conclusion and denied benefits. Upon review, the Supreme Court found that there was substantial and competent evidence the Commission relied upon to conclude that Claimant was discharged for employment-related misconduct, and, therefore, was ineligible for unemployment benefits. View "Rigoli v. Wal-Mart Associates, Inc." on Justia Law

Petitioner Shanna Locker appealed the Industrial Commission’s (Commission) finding that she was insubordinate when she failed to provide a medical release at the request of her employer, Logan’s Foodtown. The Commission found that this constituted employment-related misconduct which rendered Petitioner ineligible for unemployment insurance benefits. Upon review of the record before the Commission, the Supreme Court affirmed the Commission's decision. View "Locker v. How Soel, Inc " on Justia Law

Claimant David Tarbet worked for Employer J.R. Simplot Company for thirty-six years until an accident in 2007 left him totally and permanently disabled. The issue before the Industrial Commission (Commission) was whether Employer was liable for all or only a part of Claimant’s income benefits. If Claimant’s total disability resulted solely from the last accident, Employer would be liable for all of the income benefits. If his total disability resulted from the combined effects of both that injury and impairments that pre-existed that injury, then Employer was liable only for that portion of the income benefits for the disability caused by the accident, and the Industrial Special Indemnity Fund (ISIF) would be liable for the remainder. The Industrial Commission found that the April 2007 accident was Claimant’s final industrial accident, that he was totally and permanently disabled as a result of the final accident, and that the impairments that existed prior to that accident did not contribute to his total disability. It found that ISIF was not liable for Claimant’s benefits and dismissed the complaint against it. Employer then appealed. Upon review of the Commission's record, the Supreme Court affirmed the Industrial Commission's order. View "Tarbet v. J.R. Simplot Co. " on Justia Law

Claimant Floyd Fife appealed a decision of the Industrial Commission that found he had failed to prove that his medical condition requiring back surgery was caused by an industrial accident rather than by pre-existing degenerative changes in his thoracic and lumbar spine. An evidentiary hearing was held before a hearing officer on November 5, 2009, but the hearing officer left the employment of the Industrial Commission before submitting proposed findings of fact and conclusions of law. The Commission then reviewed the record and issued its findings of fact, conclusions of law, and order on June 8, 2010. It found the testimony of Claimant’s surgeon unpersuasive, characterizing it as "unclear, to the point of opacity, as to the actual nature of the injury which he claims is responsible for the need for surgery." When the surgeon had been asked whether he could point to any objective pathological findings in any of the diagnostic studies he had performed on Claimant that related to recent trauma, the surgeon answered that he could not. The Commission found convincing the testimony of the physician who conducted the independent medical examination of Claimant. On appeal, Claimant contended that the Commission erred as a matter of law in rejecting the testimony of his surgeon. Upon review, the Supreme Court concluded that because the Commission, as the trier of fact, was not required to accept the testimony of Claimant’s treating physician, the Court affirmed its decision. View "Fife v. The Home Depot " on Justia Law

Defendant Four Rivers Packing Company operated an onion packing plant and hired Plaintiff Stuart Mackay as the company's "field man." Plaintiff had been in the onion business for decades and knew many onion farmers. Four Rivers through its general manager Randy Smith (Smith) offered Plaintiff a job that involved purchasing enough onions to keep Four Rivers' packing shed stocked at a price that Smith would set. Plaintiff contended that Smith offered him a long-term employment contract. From 2000 to 2002, financial and managerial setbacks made it difficult for Four Rivers to operate its business, and for Plaintiff to acquire onions at prices set by Smith in order to keep the sheds stocked. In 2003, Four Rivers laid Plaintiff off. Plaintiff filed suit in 2004 alleging breach of the employment contract. At trial following a remand, Four Rivers contended that the parties had not entered into an employment contract for any specified term. A jury would return a verdict in favor of Plaintiff. In a special verdict form, the jury found that the parties had entered into a long term contract of "up to ten years, or such time as the Plaintiff retired." Four Rivers timely appealed, challenging jury instructions given at trial and the sufficiency of the evidence. Upon review of the trial record, the Supreme Court found that the trial court properly instructed the jury and that the evidence presented was sufficient to support the verdict. The Court affirmed the trial court's judgment against Four Rivers. View "Mackay v. Four Rivers Packing Co." on Justia Law

Appellant Lynnette Patterson argued that she was constructively discharged from her position with the Fraud Unit of the state Department of Health and Welfare (IDHW) due to her complaints about an intra-office romance between her supervisor and a lateral employee. IDHW had a strict policy regarding romantic relationships between supervisors and employees. Ms. Patterson made multiple complaints regarding the relationship which she alleged resulted in her first negative performance review with the IDHW, culminating in a "constructive discharge." In 2007, she filed a complaint with the Human Rights Commission (IHRC) then with the district court. The court granted summary judgment to the IDHW, finding that Ms. Patterson did not file her claim within a proscribed 180 day period following her initial complaint, and that she failed to demonstrate that her complaint was a "protected activity" in order to sustain her claim. On appeal to the Supreme Court, Ms. Patterson argued that the district court erred in its determination. Upon consideration of the trial record, the Supreme Court affirmed the district court's decision, concluding that the evidence presented at trial was sufficient to support the dismissal of Ms. Patterson's case. View "Patterson v. Dept. of Health & Welfare" on Justia Law