Justia Wyoming Supreme Court Opinion Summaries

Horsley Company, LLC was a Florida contractor hired to install equipment at the Jackson, Wyoming airport. Cody Beazer, Horsley’s employee, was injured while he was working on the airport project. The Workers’ Safety and Compensation Division notified Horsley that it was liable to the State for all payments made to Beazer because Horsley had not filed an “employee report” for the period in which Beazer’s injury occurred. Horsley objected to the Division’s determination that it was required to reimburse the Division for payments made to Beazer. The Office of Administrative Hearings granted summary judgment for Horsley, determining that Horsley had complied with the Worker’s Compensation Act in all respects and was not liable for payments made to Beazer by the Division. The district court affirmed. The Supreme Court affirmed, holding (1) the Division’s challenge to the finding that the Division was estopped from seeking reimbursement for payments made to the claimant did not provide a sufficient basis to overturn the award of summary judgment; and (2) the Supreme Court was deprived of jurisdiction to consider the Division’s challenge to the award of attorney’s fees to Horsley. View "State ex rel. Wyoming Department of Workforce Services, Workers' Compensation Division v. Beazer" on Justia Law

Appellant was discharged from his position as a firefighter with the City of Laramie after random breathalyzer tests performed while he was on duty detected alcohol in his system. The Civil Service Commission reduced Appellant’s discipline from discharge to a suspension. The district court reversed and remanded for further agency proceedings, concluding that the Commission had applied the wrong legal standard. On remand, the Commission found that the breathalyzer tests were invalid and ruled in favor of Appellant. The district court again reversed on remanded, concluding that the law and the record did not support the Commission’s conclusion. On remand, the Commission consented to Appellant’s discharge. The district court dismissed Appellant’s petition for review. The Supreme Court dismissed Appellant’s appeal, holding (1) the district court did not have subject matter jurisdiction to consider the City’s petition for review of the Commission’s second decision because the legislature did not grant cities the right to judicial review of commission decisions refusing to consent to employee discharges; and (2) because the district court lacked jurisdiction to review the Commission’s second decision, it was final, and all of the proceedings that followed the Commission’s second decision were improper. View "Vance v. City of Laramie" on Justia Law

Appellant, a former fuel truck driver for Homax Oil Sales, Inc., was discharged from his position for unloading the incorrect fuels into tanks at various locations. Appellant applied for unemployment insurance benefits. The Department of Workforce Services, Unemployment Insurance Commission ruled that Appellant was disqualified from benefits because he was discharged for misconduct connect with his work. The district court affirmed. The Supreme Court affirmed, holding (1) serious and/or repeated negligence qualifies as misconduct under Wyoming law; and (2) substantial evidence supported the Commission’s decision that Appellant committed misconduct connected with his work. View "Clark v. State, ex rel., Dep’t of Workforce Servs., Unemployment Ins. Comm’n" on Justia Law

Appellant fractured his right hip when, during the course of his employment, he climbed from the bed of a dump truck and fell onto a rock. After surgery was performed on the hip, Appellant had constant pain in both hips and finally had a total hip replacement. After his hip replacement, Appellant was pigeon-toed. Appellant was later in an automobile accident that resulted in injuries. Appellant sought worker’s compensation benefits for the injuries sustained in the automobile accident, claiming that, due to his work-related hip injury, his foot was not functioning properly and slipped off the brake pedal and got stuck between the brake and gas pedals. The Office of Administrative Hearings (OAH) denied Appellant’s worker’s compensation claim, finding that Appellant failed to prove a causal relationship between his automobile accident and his prior work-related accident. The Supreme Court affirmed, holding (1) the OAH properly applied the second compensable injury rule; and (2) the OAH’s reasonably concluded that Appellant had not established by a preponderance of the evidence that his automobile accident was casually connected to his original work-related injury. View "Jensen v. State, ex rel., Dep’t of Workforce Servs., Workers' Comp. Div." on Justia Law

In 2013, William Rogers was working for Russell Construction Company (Russell) when he claimed to have fallen against a ledge of old concrete. In 2014, the Workers' Compensation Division issued a determination that Rogers had suffered a compensable injury. Russell objected to that determination, arguing that the claim was fraudulent. A hearing officer with the Office of Administrative Hearing denied Rogers’s claim for worker’s compensation benefits, concluding that Rogers had not proved that he suffered a compensable injury in 2013. The district court affirmed. The Supreme Court affirmed, holding that the hearing examiner’s determinations of fact were reasonable and based on substantial evidence. View "Rogers v. Russell Constr. Co., Inc." on Justia Law

Petitioner was discharged from her position as high school principal of the St. Stephens Indian School for “not promptly assessing a student who was potentially intoxicated and allowing the student to remain in class while [Petitioner] left the building.” Petitioner applied for unemployment insurance benefits. A deputy for the Unemployment Insurance Division denied Petitioner’s claim, determining that she was discharged for misconduct connected with her work. On appeal, a hearing officer ruled that Petitioner was discharged from her unemployment but not for misconduct connected with her work. The Department of Workforce Services, Unemployment Insurance Commission reversed. The district court reversed, ruling that the Commission’s decision was not supported by substantial evidence. The Supreme Court affirmed, holding that the record did not support a conclusion that Petitioner’s action was anything more than ordinary negligence or a good faith error in judgment. View "State ex rel., Dep’t of Workforce Servs., Unemployment Ins. Comm’n v. Kinneman" on Justia Law

Appellant Mary Leib sought benefits from the Wyoming Workers’ Compensation Division after she developed abscesses in her breasts. Leib was employed as a maintenance worker for Laramie County Community College in Cheyenne. She began working on the grounds of the College in April 2012. As part of her duties as a groundskeeper, Leib was required to work with dirt that was mixed with untreated manure from livestock kept on campus and from traveling circus animals. In June 2012, approximately two weeks after she began planting flowers using the dirt and manure mixture, Leib experienced pain and swelling in both of her breasts. She sought treatment at the emergency room, where she was diagnosed with mastitis. Upon returning to work, the swelling developed again. The second time she sought treatment, her surgical incisions split open. Subsequent cultures indicated that several different types of peptostreptococcus bacteria were present. The Division denied the claim. The Medical Commission upheld the Division’s determination after finding that she had not met her burden of proving that her condition was related to her employment. Leib appealed to the district court, which affirmed the Medical Commission’s order. She challenged the district court’s decision in this appeal. Finding no reversible error, the Supreme Court affirmed. View "In the Matter of the Worker's Compensation Claim of: Leib v. Wyoming, ex rel., Department of Workforce Services, Workers' Compensation Division" on Justia Law

Appellant, a long-term Game & Fish employee, was terminated after two disciplinary suspensions and her filing of a complaint alleging hostile work environment sexual harassment, grieving the disciplinary suspensions, and filing a charge of discrimination. The Office of Administrative Hearings concluded that “good cause” supported the disciplinary actions and that they were supported by substantial evidence. The district court affirmed. The Supreme Court affirmed, holding (1) no facts asserted by Appellant adequately supported a due process claim “of such a fundamental nature that it must be considered” for the first time on appeal; and (2) Appellant failed to preserve her claim that her suspensions were issued without authority. View "Crofts v. State ex rel. Dep’t of Game & Fish" on Justia Law

During the 2011-2012 school year, Plaintiff was a continuing contract teacher who worked for the Laramie County School District No. One. In spring of 2012, the District Superintendent gave Plaintiff notice that he proposed that Kinstler be terminated. On September 4, 2012, a hearing officer recommended that the District accept the Superintendent’s proposal. On September 17, 2012, the District’s Board of Trustees voted to accept the recommendation. Kinstler was paid his normal salary from August 15, 2012, the date he would have started to work, through the date that the Board acted on the recommendation to terminate him. Kinstler subsequently sued the District, asserting that the District failed to pay him the salary and value of benefits allegedly owed him for the 2012-2013 academic year. The district court partially granted Kinstler’s motion for summary judgment and entered an order with respect to his salary and benefits claim. The Supreme Court reversed and vacated the award, holding that because Kinstler’s termination was effective at the end of the 2011-2012 school year, he had no statutory right to compensation following that date. View "Laramie County Sch. Dist. v. Kinstler" on Justia Law

Appellant suffered a work-related injury while working for Employer and filed an injury report with the Wyoming Workers’ Compensation Division. The Division denied benefits, finding that Appellant had failed to show that he was authorized to work in the United States. Following an evidentiary hearing, the Office of Administrative Hearings (OAH) awarded benefits, concluding that although Appellant had submitted fake work authorization documents, Employer had a reasonable belief that Appellant was authorized to work in the United States when it hired him and, therefore, Appellant was an employee entitled to worker’s compensation benefits. The district court affirmed the OAH ruling. The Supreme Court affirmed, holding that the OAH conclusion that Appellant was an employee as defined by the Worker’s Compensation Act was in accordance with law and supported by substantial evidence. View "Gonzalez v. Reiman Corp." on Justia Law