Evans v. USF Reddaway, Inc., 1:15-cv-00449

Background

Plaintiff Edward Evans, a long‑time Teamsters‑represented Reddaway driver, filed STAA retaliation and Idaho wrongful‑discharge claims after Reddaway terminated him in March 2014 for alleged theft of company time and falsifying records.
Evans had filed two workplace safety grievances in 2013 concerning poor conditions and security at Reddaway’s Twin Falls and Boise terminal yards; he later raised those issues with OSHA and union representatives.
Reddaway placed Evans on leave February 27, 2014 and fired him March 6, 2014 for billing "wait time" and a DOT safety break while leaving before his scheduled start time.
Evans contends other drivers engaged in similar billing/early‑leave practices without discipline and argues his termination was retaliatory for the safety complaints and union activity.
Reddaway moved to strike portions of Evans’s declaration and exhibits and moved for summary judgment on both claims. The court denied the motion to strike but granted summary judgment in full.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the STAA claim uses AIR‑21 burden shifting	Evans: AIR‑21 "contributing factor"/then employer must show by clear and convincing evidence it would have acted anyway; applies in federal court	Reddaway: AIR‑21 burden applies only to Secretary of Labor proceedings, not federal suits	Held: AIR‑21 framework applies to Evans’s STAA claim (court applies Ninth‑Circuit approach), but Evans failed to prove protected activity, so STAA claim fails on the merits
Whether Evans engaged in STAA‑protected activity (complaint clause)	Evans: his terminal safety complaints were reasonably related to FMCSR violations (citing §§392.3, 392.7, 392.9, 392.14); need only show reasonable belief	Reddaway: complaints concern terminal working conditions, not FMCSR regulated vehicle safety; not protected	Held: Complaints did not reasonably relate to or evidence a reasonable belief in FMCSR violations; therefore not protected activity under §31105(a)(1)(A)
Admissibility of Evans’s declaration/exhibits re: comparators	Evans: materials could be presented in admissible form at trial and are proper for summary judgment consideration	Reddaway: statements contain hearsay, lack foundation, not personal knowledge	Held: Motion to strike denied; court may consider materials for summary judgment but makes no final trial admissibility ruling
Whether Idaho public‑policy wrongful discharge claim applies to non‑at‑will employees	Evans: Idaho law should allow public‑policy claim for non‑at‑will employees (or certify question to Idaho Supreme Court)	Reddaway: Evans is not at‑will; Idaho’s public‑policy exception applies only to at‑will employees; thus claim unavailable	Held: Idaho precedent confines the public‑policy wrongful termination claim to at‑will employees; Evans’s claim fails as a matter of law

Key Cases Cited

Van Asdale v. Int’l Game Tech., 577 F.3d 989 (9th Cir.) (applies AIR‑21 burden shifting framework in retaliation cases)
Formella v. United States Dep’t of Labor, 628 F.3d 381 (7th Cir.) (applies AIR‑21 framework to STAA claims)
Maverick Transp., LLC v. United States Dep’t of Labor, Admin. Rev. Bd., 739 F.3d 1149 (8th Cir.) (applies AIR‑21 framework to STAA claims)
Calhoun v. United States Dep’t of Labor, 576 F.3d 201 (4th Cir.) (complaint protected only if based on reasonable belief of a motor‑vehicle safety violation)
Gaines v. K‑Five Constr. Corp., 742 F.3d 256 (7th Cir.) (employee protected when filing a reasonable, good‑faith safety complaint even if information is inaccurate)
Yellow Freight Sys., Inc. v. Martin, 954 F.2d 353 (6th Cir.) (interpreting "related to" standard for protected complaints under STAA)
Brock v. Roadway Express, Inc., 481 U.S. 252 (U.S.) (Congress intended STAA to encourage reporting of safety noncompliance)
Venable v. Internet Auto Rent & Sales, Inc., 329 P.3d 356 (Idaho) (Idaho limits public‑policy wrongful termination exception to at‑will employees)