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Current v. HADDONS FENCING, INC.
152 Idaho 10
| Idaho | 2011
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Background

  • Current was Haddons Fencing's shop foreman from June 10, 2008 to September 12, 2009.
  • On September 12, 2009, Current sought either a raise or guaranteed hours, which Haddons' owner Jan refused.
  • Current asked to be laid off; Jan refused and told him to quit; he turned in his keys and corporate credit card.
  • Around the same time, Current arranged to harvest for Wada Farms, with a start date of September 15, 2009.
  • On September 14, 2009, Current filed an unemployment claim selecting 'lack of work/laid off'; Haddons reported that he quit.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Was there substantial evidence of a willful false statement? Current argues the misstatement was a mistaken belief, not willful. Current's misstatement was willful and material under I.C. 72-1366(12). Yes; substantial and competent evidence supports willful false statement.
Did the failure to call a witness render the hearing unfair? Robin's testimony was relevant and should have been heard. Robin's testimony was not arranged or relevant to the issues; examiner did not abuse discretion. No; examiner did not abuse discretion; Robin's testimony was not necessary.

Key Cases Cited

  • Meyer v. Skyline Mobile Homes, 99 Idaho 754 (Idaho 1979) (materiality defined; standard for determining material facts)
  • Woods v. Ewins, 138 Idaho 343 (Idaho 2003) (deference to commission on credibility and factual determinations)
  • Buckham v. Idaho Elk's Rehabilitation Hosp., 141 Idaho 338 (Idaho 2005) (substantial evidence standard for commission findings)
  • Ginther v. Boise Cascade Corp., 150 Idaho 143 (Idaho 2010) (standard of review; deference to commission unless clearly erroneous)
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Case Details

Case Name: Current v. HADDONS FENCING, INC.
Court Name: Idaho Supreme Court
Date Published: Dec 8, 2011
Citation: 152 Idaho 10
Docket Number: 37740
Court Abbreviation: Idaho