Justia Wyoming Supreme Court Opinion Summaries

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

Robert Scherf suffered a heart attack at work while servicing a front end loader. Scherf died of acute myocardial infraction with cardiogenic shock. Claimant, Scherf’s widow, applied for workers’ compensation death benefits. The Wyoming Safety and Compensation Division denied benefits. The Office of Administrative Hearings (OAH) upheld the denial of benefits, concluding that although Claimant had proved a causal link between Scherf’s work exertion and the myocardial infarction, Claimant failed to prove that exertion itself was unusual or abnormal for the particular employment in which Scherf was engaged. The district court affirmed. The Supreme Court reversed, holding that the OAH conclusion that any unusual or abnormal employment exertion Scherf experienced was not unusual to or abnormal for an employee servicing heavy equipment was contrary to the overwhelming weight of the evidence. Remanded for entry of an order awarding benefits. View "Scherf v. State ex rel. Dep’t of Workforce Servs., Workers' Comp. Div." on Justia Law

Appellant had been employed for seven years by the Fremont County School District Number One when the District’s Board of Trustees terminated his employment. On appeal, Appellant asserted that the Board failed to comply with the Board’s rules of practice by untimely making its decision, and because the Board failed to take action within the time set by the rule, the Board lost subject matter jurisdiction to decide the case. The Supreme Court affirmed, holding that even if the decision was untimely, the Board did not lose jurisdiction because the rules do not specify any consequence for non-compliance and there is nothing in the rules to suggest that missing the deadline strips the Board of subject matter jurisdiction. View "Scott v. Bd. of Trs. of Fremont County Sch. Dist. Number One" on Justia Law

Sheri Eaton requested workers’ compensation benefits claiming that she received a workplace injury resulting from an injury at her workplace. After a contested case hearing, the Office of Administrative Hearings (OAH) determined that Eaton did not prove that her injury was related to the workplace event. The OAH also upheld the final determination by the Division ceasing payments for temporary total disability benefits and mental health treatment six months after reaching maximum medical improvement. The district court affirmed the OAH’s decision. The Supreme Court affirmed the district court’s order, holding that the OAH hearing examiner’s decision was supported by substantial evidence and that the OAH’s determination was not arbitrary or capricious. View "Eaton v. State ex rel. Dep’t of Workforce Servs." on Justia Law

Appellant received a back injury while working as a concrete truck driver. Appellant subsequently received two surgeries to his back and could not return to work. The Wyoming Workers’ Safety and Compensation Division assigned Appellant a nine percent permanent partial impairment (PPI) rating. The Medical Commission sustained the Division’s PPI rating. The Supreme Court affirmed, holding that the Medical Commission’s decision that Appellant did not prove he was entitled to a higher impairment rating under the AMA Guides to the Evaluation of Physical Impairment was supported by substantial evidence and otherwise in accordance with the law. View "In re Worker's Compensation Claim of Michael D. Hurt" on Justia Law