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Doggett v. Wyoming Department of Workforce Services
334 P.3d 1231
Wyo.
2014
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Background

  • 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)
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Case Details

Case Name: Doggett v. Wyoming Department of Workforce Services
Court Name: Wyoming Supreme Court
Date Published: Sep 24, 2014
Citation: 334 P.3d 1231
Docket Number: S-14-0012
Court Abbreviation: Wyo.