Bringman v. New Albertsons, Inc.
157 Idaho 71
| Idaho | 2014Background
- Bringman was employed by Albertsons from 2004 until separation in 2010.
- An October 2010 incident led to a written warning; Bringman refused to sign the warning due to following policy.
- Albertsons offered Bringman a severance package for resignation or a demotion with a large pay cut; Bringman chose resignation with severance.
- Bringman filed a first unemployment claim on December 8, 2010 describing the separation as a layoff due to lack of work; benefits were paid.
- A second unemployment claim was filed December 12, 2011; Albertsons challenged eligibility after learning Bringman had previously claimed a layoff.
- The Department determined Bringman willfully made a false statement or failed to report a material fact regarding his separation, leading to overpayments, a civil penalty, and repayment obligations; the Commission affirmed on de novo review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Materiality of the separation reason | Bringman’s ‘layoff due to lack of work’ was a material description. | The separation reason was mischaracterized; ‘quit’ was the true status and material. | Yes; the selection was material to eligibility. |
| Willfulness of the false statement | Bringman did not knowingly misrepresent; options did not fit factual reality. | Bringman knowingly selected a false or misleading option. | Yes; with substantial evidence of willfulness. |
| Waiver of repayment overpayments | Overpayments resulted from erroneous Department actions beyond Bringman’s control. | Waiver barred where overpayments arose from a false statement or failure to report. | No; waiver denied. |
| Attorney’s fees on appeal | Bringman should be entitled to fees as prevailing party. | Bringman not prevailing party. | Denied; no attorney’s fees awarded. |
Key Cases Cited
- Meyer v. Skyline Mobile Homes, 99 Idaho 754 (Idaho 1979) (materiality defined broadly as information relevant to eligibility)
- Current v. Haddons Fencing, Inc., 152 Idaho 10 (Idaho 2011) (willfulness requires intentional falsehoods, not mere confusion)
- McNulty v. Sinclair Oil Corp., 152 Idaho 582 (Idaho 2012) (employment status and reporting of earnings; Meyer applied)
- Wulff v. Sun Valley Co., 127 Idaho 71 (Idaho 1995) (credibility determinations reviewed for clear error)
- Rigoli v. Wal-Mart Assocs., Inc., 151 Idaho 707 (Idaho 2011) (administrative credibility determinations upheld unless clearly erroneous)
- Hopkins v. Pneumotech, Inc., 152 Idaho 611 (Idaho 2012) (clarifies weight given to Commission findings on credibility)
- Uhl v. Ballard Med. Prods., Inc., 138 Idaho 653 (Idaho 2003) (free review on questions of law; substantial evidence for facts)