Fearn v. Steed, 151 Idaho 295

Steeds employed Fearn and she resigned effective April 8, 2009, after agreeing to reduced hours and pay.
On April 3, 2009 Fearn emailed approximately 7,500 sales contacts; a second email with her contact info followed, prompting termination on April 6, 2009.
IDOL found Fearn quit without good cause; appeals examiner affirmed; Industrial Commission conducted de novo review and later granted benefits.
Industrial Commission determined Fearn was not discharged for misconduct, but did find a pattern of Steed’s comments about religion and personal life constituted good cause to quit.
Steeds unsuccessfully sought reconsideration arguing termination grounds should be used instead of resignation grounds.
The Idaho Supreme Court affirmed, holding the Commission’s misconduct determination supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Fearn discharged for misconduct?	Steeds contend misconduct was shown.	Fearn argues no willful disregard of employer interests.	Not discharged for misconduct; affirmed
Should the decision rely on reasons for termination or resignation?	Steeds argue termination reasons should govern.	Fearn argues resignation rationale governs under IDAPA rule.	Court did not reach good-cause-to-resign issue; decision affirmed on misconduct basis

Kivalu v. Life Care Ctrs. of Am., 142 Idaho 262, 127 P.3d 165 (2005) (misconduct standard for unemployment benefits; employer bears burden)
Adams v. Aspen Water, Inc., 150 Idaho 408, 247 P.3d 635 (2011) (burden on claimant to show misconduct; preponderance standard)
Eacret v. Clearwater Forest Indus., 136 Idaho 733, 40 P.3d 91 (2002) (scope of appellate review for Industrial Commission findings)
R Homes Corp. v. Herr, 142 Idaho 87, 123 P.3d 720 (Ct. App. 2005) (duty of loyalty; relevance to misconduct analysis)