Doggett v. Wyoming Department of Workforce Services
334 P.3d 1231
Wyo.2014Background
- Doggett was fired from Strokers USA, Inc. for misconduct related to work performance.
- He applied for unemployment benefits; a hearing officer awarded benefits, but the Commission reversed.
- District court affirmed the Commission; Doggett appeals seeking reversal.
- The Commission held Doggett’s actions—chipping a fin and installing a dented cylinder—constituted misconduct.
- Doggett admitted chipping the motor fin and failing to inform the owner; he admitted installing a damaged cylinder without prompt reporting.
- Appellate standard requires substantial evidence review to determine whether the agency could reasonably conclude misconduct occurred
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the Commission's finding of misconduct supported by substantial evidence? | Doggett contends there was no knowledge of misconduct at discharge. | Strokers argues proven misconduct based on chipped fin and dented cylinder. | Reversed; lack of substantial evidence for misconduct. |
Key Cases Cited
- Safety Medical Services, Inc. v. Employment Sec. Com’n of Wyoming, 724 P.2d 468 (Wy. 1986) (misconduct requires evident disregard of employer's interests)
- Rissler & McMurry Co., 837 P.2d 686 (Wy. 1992) (liberal construction in favor of claimants; review for substantial evidence)
- Aspen Ridge Law Offices, P.C. v. Wyoming Dep’t of Employment, 143 P.3d 911 (Wy. 2006) (good faith errors or ordinary negligence not misconduct)
- In re Ringrose, 302 P.3d 900 (Wy. 2013) (support requires reasonable basis from evidence; not solely outcome-based)
- Weidner v. Life Care Centers of America, 893 P.2d 706 (Wy. 1995) (deference to agency findings; substantial evidence standard)
- Bush v. State ex rel. Wyo. Workers’ Safety & Health, 120 P.3d 176 (Wy. 2005) (substantial evidence standard applied to agency findings)
