Justia Idaho Supreme Court Opinion SummariesArticles Posted in Public Benefits
Woolley v. Idaho Dept. of Labor
Brett Woolley appealed an Idaho Industrial Commission (“Commission”) decision that found him ineligible for unemployment benefits. The Commission determined that Woolley was ineligible for benefits because he was a corporate officer whose claim for benefits was based on wages from a corporation in which he had an ownership interest. The Commission also determined Woolley willfully made a false statement by saying he had not received wages or performed services as a corporate officer. After review, the Idaho Supreme Court affirmed the Commission’s determination that Woolley was ineligible for benefits due to his status as a corporate officer because it was supported by substantial and competent evidence. However, the Court found Woolley did not willfully misrepresent his status as a corporate officer, "The statute makes no mention of a claimant’s performance of services as a corporate officer. To compound the confusion, IDOL provides no information in the unemployment handbook or on its website to explain why it is necessary for claimants to report their corporate officer status when filing a claim for benefits. To serve as the basis for a willful failure to report a material fact, the question to be answered by a claimant must be accurately grounded in the legal requirements of the statute." View "Woolley v. Idaho Dept. of Labor" on Justia Law
Regan v. Denney
On November 20, 2018, the Acting Governor of Idaho issued a proclamation that Proposition 2 had passed, and subsequently the Idaho Code was amended to add section 56-267, a statute to expand Medicaid eligibility in Idaho. Petitioner Brent Regan argued 56-267 violated Idaho’s Constitution by delegating future lawmaking authority regarding Medicaid expansion to the federal government. Regan requested the Idaho Supreme Court declare section 56-267 unconstitutional and issue a writ of mandamus to direct the Secretary of State Lawerence Denney to remove section 56-267 from the Idaho Code. Finding the statute constitutional, the Supreme Court dismissed Regan’s petition and denied his request for a writ of mandamus. View "Regan v. Denney" on Justia Law
Wittkopf v. Idaho Dept of Labor
On July 11, 2013, the Idaho Department of Labor (“IDOL”) mailed an eligibility determination for unemployment benefits (the “2013 determination”) to William Wittkopf. This determination found Wittkopf underreported his wages for several weeks, which resulted in an overpayment in unemployment benefits. As a result, Wittkopf was: (1) ordered to repay the overpayment; (2) ineligible for any unemployment benefits for a fifty-two week period; and (3) assessed a civil penalty. Additionally, Wittkopf was told that he would remain ineligible for unemployment benefits until all amounts were repaid. Pursuant to Idaho Code section 72– 1368(3) the last day for Wittkopf to file a protest to the 2013 determination was July 25, 2013, which he failed to do. IDOL attempted to collect on the 2013 determination over the next year without success. Subsequently in early 2016, Wittkopf filed for Chapter 7 bankruptcy. The debt he owed to the state of Idaho was included in his bankruptcy and was discharged by order of the Bankruptcy Court. In September 2016, Wittkopf began filing new claims for unemployment benefits with IDOL because he worked a seasonal job and was not receiving any income in the winter months. After not receiving benefits for several weeks, Wittkopf called IDOL which informed him he was ineligible for unemployment benefits because he had failed to pay back his overpayment, civil penalty, and interest he owed IDOL, even though those amounts were discharged in bankruptcy. Wittkopf mailed a letter to IDOL protesting the denial of his unemployment benefits. Wittkopf claimed in this letter that he was eligible for unemployment benefits because his bankruptcy discharged any amount he owed to IDOL. An Appeals Examiner construed Wittkopf’s 2016 letter as a protest of the 2013 determination. Two days later the Appeals Examiner issued a written decision finding there was no jurisdiction to hear Wittkopf’s protest because it was not filed within fourteen days of when it was issued on July 25, 2013, as required by Idaho Code section 72-1368. On November 3, 2016, Wittkopf appealed the Appeals Examiner’s decision to the Industrial Commission. On January 27, 2017, the Industrial Commission affirmed the Appeals Examiner’s decision. The Idaho Supreme Court determined the Industrial Commission erred in affirming the examiner without having determined first whether: (1) the bankruptcy discharge voided IDOL's 2013 determination; (2) whether the discharge operated as an injunction against any effort to collect, recover or offset the 2013 debt; and if yes, (3) why the Department's denial of current benefits on the basis of the 2013 debt wasn't a violation of the injunction. The matter was remanded back to the Industrial Commission for further proceedings. View "Wittkopf v. Idaho Dept of Labor" on Justia Law
Barr v. CitiCorp Credit Svc
Jessica Barr appealed an Idaho Industrial Commission (Commission) decision finding her ineligible for unemployment benefits and affirming the decision of an Appeals Examiner for the Idaho Department of Labor’s (IDOL) Appeals Bureau. The Commission found that Barr was discharged by her employer, Citicorp Credit Services, Inc. USA (Citicorp), for misconduct in connection with employment and determined that Barr was not eligible for benefits pursuant to Idaho Code section 72-1366(5). Barr argued that Citicorp representatives provided false information to the Appeals Examiner and her unemployment benefits should have been restored. Finding that the Commission's decision was supported by substantial and competent evidence, the Supreme Court affirmed the IDOL Appeals Examiner's decision. View "Barr v. CitiCorp Credit Svc" on Justia Law
Gerdon v. Con Paulos, Inc.
In 2008, Joseph Gerdon was seriously injured in a motor vehicle accident that arose out of and in the course of his employment. He was a passenger in a vehicle being driven by a coworker, who drove off the road. The Industrial Commission awarded Gerdon benefits. Gerdon requested a hearing to determine whether he was also entitled to benefits for a compensable psychological injury. That issue was heard before a referee, who issued proposed findings of fact, conclusions of law, and a recommendation that Gerdon had failed to prove that he was entitled to additional psychological care. The Commission adopted the referee’s proposed findings of fact and conclusions of law and issued an order. Gerdon appealed to the Idaho Supreme Court. Because the Commission’s decision was based upon its constitutional right to weigh the evidence and determine the credibility of conflicting expert opinions, the Supreme Court affirmed the Commission's order. View "Gerdon v. Con Paulos, Inc." on Justia Law
Weible v. Dept of Labor
While claimant-appellant Judith Weible was employed by Safeway, Inc., she requested time off because she had to have surgery. Safeway granted her request and agreed to hold her job until she was able to return to work, which she intended to do. She was gone for approximately six weeks. While on leave, claimant applied for unemployment benefits. She was denied because during her leave of absence she was still employed, even though she was not working. An appeals examiner upheld the denial, and the Industrial Commission upheld the appeals examiner. Finding no reversible error, the Supreme Court affirmed the Industrial Commission. View "Weible v. Dept of Labor" on Justia Law
Bringman v. New Albertsons, Inc.
Appellant Billy J. Bringman appealed an Idaho Industrial Commission decision in favor of Respondents New Albertsons, Inc. and the Idaho Department of Labor. The Commission determined Bringman willfully made a false statement or failed to report a material fact regarding his separation from Albertsons to obtain unemployment benefits from the Department and ordered Bringman to repay the benefits he received and pay a civil penalty. Finding no reversible error with that decision, the Supreme Court affirmed. View "Bringman v. New Albertsons, Inc." on Justia Law
Dept. of Health & Welfare v. Peterson
Melvin Peterson died in 2007. Prior to his death, he owned some residential real property. In 2001, Peterson executed a Gift Deed of his real property to his daughter, Cathie Peterson, retaining for himself a life estate in the property. Shortly thereafter, he applied for Medicaid and began receiving Medicaid benefits in March 2003. At the time of his death, Melvin Peterson had received a total of $171,386.94 in Medicaid benefits. Cathie was appointed personal representative. IDHW filed a timely Claim Against Estate and later an Amended Claim Against Estate in the amount of $171,386.94. Cathie disallowed the claims without stating a reason. In response, IDHW filed a Petition for Allowance of Amended Claim. After a hearing, the court granted IDHW's petition. After receiving no response to its claim against the estate, IDHW filed a Petition to Require Payment of Claim, setting forth its demand for payment of the value of Melvin Peterson's life estate. After a hearing, the magistrate court entered an order requiring payment of IDHW's claim. The Order held that the life estate was an asset of the estate for purposes of Medicaid recovery and ordered the personal representative to add the life estate interest to the estate's inventory and assign it an appropriate value. However, the personal representative instead filed and was granted a motion to hire an appraiser to determine the fee simple value of the residential real property. After the personal representative failed to file an appraisal, IDHW filed various motions relative to the appraisal, sale of the property, and payment of its claim. The magistrate court granted IDHW's motions to compel appraisal, sale of the property, and payment of the Medicaid claim, which the personal representative subsequently appealed. The district court vacated the magistrate's Order and remanded the matter for additional findings of fact and conclusions of law. Shortly after the ruling on appeal was entered, Cathie Peterson sought permission from the magistrate court to sell the property, liquidate an escrow account, and pay counsel for the personal representative of the estate. On the same day, she also filed an Amended Personal Representative's Inventory assigning the life estate zero value. Attorney Brent Featherston filed a Demand for Notice and Special Appearance on behalf of "Cathie Peterson, individually,"stating that he was seeking to vacate and dismiss all orders entered by the magistrate court regarding her real property. IDHW responded by filing a petition to remove Cathie Peterson as personal representative of the estate, which the magistrate court granted. Following a court trial, the magistrate court held that the life estate remainder interest was an estate asset of value for purposes of Medicaid reimbursement and that its value was to be determined in accordance with IDAPA 16.03.05.837.01. On appeal, the district court affirmed the magistrate court. Cathie Peterson appealed. The Supreme Court found that both the magistrate court and the district court had subject matter jurisdiction over this case and personal jurisdiction over Cathie Peterson individually, and that the entire residential property that Cathie Peterson received from her father was an asset of his estate and subject to Medicaid recovery. Thus, the district court erred to the extent it held that only the remainder interest in the estate was subject to Medicaid recovery. Furthermore, the Court held that Cathie Peterson failed to show that the district court's decision denying her claim for offsets was unsupported by the evidence. View "Dept. of Health & Welfare v. Peterson" on Justia Law
Muchow v. Varsity Contractors, Inc.
Claimant DeAnne Muchow began working for Varsity Contractors, Inc in 2011 as a human resources assistant. During her employment, the claimant had an ongoing conflict with her supervisor and had lodged several complaints about her supervisor with the director of the department. In an effort to resolve the conflict, the director held a meeting with claimant and her supervisor. The claimant and her supervisor both stated that they had documentation outlining their complaints. The director told them to get their documentation and bring it back to his office. The claimant asked if they could do so the following day because she wanted time to look over her documentation, but the director denied that request because he was leaving the next day on a business trip. He did give the claimant a few minutes to look over her documentation. She returned to her desk and after a few minutes printed her documentation. She took the documents and walked toward the director, who was standing outside his office. The claimant waved the documents in the air, told the director she had them and was going to shred them, and walked past him toward the shredder. He told her not to shred them, but she continued to the shredder and shredded them. The director then discharged her for insubordination. The claimant applied for unemployment benefits, which were initially denied. She appealed, and an appeals examiner reversed the ruling that the claimant was not entitled to unemployment benefits. He held that as a matter of law there was no insubordination. The basis of his ruling was that the director’s order not to shred the documents was not a directive that the director was authorized to give and entitled to have obeyed, because the documents belonged to the claimant and contained her personal notations about issues and problems she was having with a coworker. The employer then appealed to the Industrial Commission. The commission adopted the findings of fact made by the appeals examiner. However, the commission disagreed with the conclusions of law made by the appeals examiner. The commission concluded that her conduct constituted employment-related misconduct, and it reversed the decision of the appeals examiner and held that the claimant was not eligible for unemployment benefits. Upon review of the matter, the Supreme Court found no reversible error in the Commission's decision and affirmed. View "Muchow v. Varsity Contractors, Inc." on Justia Law
In re Estate of Wiggins
The Department of Health and Welfare appealed an order that disallowed its attempt to recover assets in a probate proceeding. The Department sought to recover assets of a dead Medicaid recipient for medical assistance payments made on the decedent's behalf from her widower. The magistrate court held that the Department could not reach the separate property of the decedent's spouse. Upon review, the Supreme Court concluded the Department was permitted to seek recovery from the decedent's community property that was transmuted to her widow as his separate property. View "In re Estate of Wiggins" on Justia Law