Hurst v. IHC Health Services, Inc., 817 F. Supp. 2d 1202

Hurst, a long-time Hospital employee, resigned from her Clinic position after a dispute with Dr. Harris about clinic practices; Hospital had arranged for Clinic employees to be staffed by Hospital personnel.
In January 2010, Hurst’s primary assignment shifted from the Clinic to a part-time, on-call recovery room role, with significantly reduced income and benefits.
Hurst remained employed by the Hospital on an on-call basis, but her Clinic position was effectively terminated, leaving her with minimal hours and pay.
The Hospital moved for summary judgment; the Court denied in part and granted in part, addressing public policy wrongful discharge, implied covenant, and wage claim issues.
The Court concluded Hurst’s public policy wrongful discharge claim survives; it granted summary judgment on the implied covenant claim and on the Idaho Wage Claim Act claim, dismissing those claims with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hurst’s alleged constructive discharge from the Clinic qualifies as public policy wrongful discharge.	Hurst contends the Clinic/ Hospital actions exceeded routine discipline and amounted to discharge protected by public policy.	Hospital argues no public policy wrongful discharge claim for non-termination; at most, routine disciplinary action.	Public policy wrongful discharge claim survives.
Whether the implied covenant of good faith and fair dealing supports a claim against at-will employment.	Cantwell-based claim that a contractual limitation implied by the Clinic’s questionnaire imposes at least some protection.	Handbook language and lack of an implied contractual term negate the claim.	Court grants summary judgment for Hospital; claim dismissed.
Whether Hurst is entitled to paid time off under Idaho Wage Claim Act after termination from the Clinic.	Wage Claim Act and hospital PTO policy entitle her to accrued but unused PTO upon termination.	No entitlement; PTO policy and wages do not create such a payment upon termination from Clinic.	Wage Claim Act claim granted to be dismissed; PTO claim dismissed.

Edmondson v. Shearer Lumber Prod., 75 P.3d 733 (Idaho 2003) (public policy exception to at-will discharge)
Patterson v. State Dept. of Health & Welfare, 256 P.3d 718 (Idaho 2011) (constructive discharge analyzed under public policy)
Draper v. Coeur Rochester, Inc., 147 F.3d 1104 (9th Cir.1998) (constructive discharge framework cited)
Zimmerman v. Buchheit of Sparta, Inc., 164 Ill.2d 29, 645 N.E.2d 877 (1994) (retaliatory discharge/discipline concerns; limits on wage actions)
White v. State, 131 Wash.2d 1, 929 P.2d 396 (1997) (rejects wrongful transfer/discipline as public policy cause of action)
Touchard v. La-Z-Boy Inc., 148 P.3d 945 (Utah 2006) (no public policy basis for harassment/discrimination short of discharge)
Cantwell v. City of Boise, 191 P.3d 205 (Idaho 2008) (implied-in-fact contract; manuals may supply terms but disclaimer controls)
Jenkins v. Boise Cascade Corp., 108 P.3d 380 (Idaho 2005) (limitations of implied terms from employee manuals)
Hales v. King, 762 P.2d 829 (Idaho Ct. App.1988) (interpretation of wage/compensation upon termination)
Independence Lead Mines v. Hecla Mining Co., 137 P.3d 409 (Idaho 2006) (general contract interpretation; at-will context)