Flowers v. SHENANGO SCREENPRINTING, INC.
150 Idaho 295
| Idaho | 2010Background
- Flowers was employed by Shenango as lead screen printer from June 2007 until he was fired on September 5, 2008.
- Flowers applied for unemployment benefits; the Department initially found him eligible, prompting Shenango to appeal and request a hearing.
- An informational hearing notice warned that additional evidence would be excluded except in rare circumstances, and emphasized non-hearsay evidence.
- At the hearing, Fraley testified Flowers had an affair with Fraley’s wife and lied about it; he stated there were workplace disruptions and Flowers was terminated for the lies.
- The appeals examiner found Flowers’ misconduct was not proven to be work-related; Shenango appealed to the Commission, which conducted a de novo review without new hearings.
- The Commission found no competent evidence that the affair occurred, and Shenango’s evidence relied on conjecture; Shenango sought reconsideration, which was denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Commission abused discretion in not ordering a new hearing/remand | Shenango argues Rule 7(C) requires a new hearing or remand when the record is inadequate. | Commission held discretion to admit new evidence; no mandatory sua sponte remand unless justified. | No abuse of discretion; no mandatory remand or new hearing required. |
| Whether Shenango met its burden to show work-related misconduct | Shenango asserts misconduct was proven by the affair and disruption at work. | Record lacked non-conclusory evidence of the affair; no direct link shown to work-related misconduct. | Record insufficient to prove work-related misconduct. |
| Whether the reconsideration denial was proper | Shenango argues reconsideration should have allowed added evidence (e.g., Mrs. Fraley's letter). | Reconsideration denied because added evidence did not meet Rule 7(B)(5) requirements and was not timely explained. | No abuse; reconsideration denial affirmed. |
Key Cases Cited
- Higgins v. Larry Miller Subaru-Mitsubishi, 145 Idaho 1 (Idaho 2007) (evidentiary discretion and admissibility of evidence)
- Stolle v. Bennett, 156 P.3d 545 (Idaho 2007) (limits on evidence and hearsay)
- Teevan v. Office of Att'y Gen., Nat. Res. Div., State of Idaho, 130 Idaho 79 (Idaho 1997) (abuse-of-discretion standard for supplemental hearings)
- Parker v. St. Maries Plywood, 614 P.2d 955 (Idaho 1980) (employer's burden to prove discharge was for work-related misconduct)
- Rogers v. Trim House, 588 P.2d 945 (Idaho 1979) (availability and timing of new evidence)