257 P.3d 755
Idaho2011Background
- Four Rivers Packing Co. operates an onion packing plant in Idaho since 1999 and engaged Mackay as field man.
- Mackay alleges a March 2000 oral offer of a long-term employment contract, to last until retirement, which he accepted after discussing with his wife.
- Four Rivers disputes that any long-term contract existed and maintains at-will employment absent mutual agreement on duration.
- In 2000-2001 season, Mackay helped procure onions; injunction in June 2000 interrupted business, causing layoffs.
- In October 2001, Four Rivers drafted a written contract with an at-will provision; neither party signed it.
- Mackay sued in 2004 for breach of contract; on remand the district court allowed a jury verdict that there was a long-term contract up to ten years or retirement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether jury instructions correctly framed contract formation under Idaho law. | Mackay argues instruction allowed implied terms and should reflect meeting of the minds. | Four Rivers contends instruction improperly suggested agreement on some terms. | Instructions were proper and did not mislead the jury. |
| Whether the statute of frauds should have been applied and instructed to the jury. | Mackay contends contract duration could fall within statute of frauds if ten years. | Four Rivers argued statute of frauds applies to a ten-year term. | No statute of frauds instruction required; contract duration viewed as until retirement. |
| Whether substantial, competent evidence supports the verdict. | There is ample evidence of a long-term offer and breach. | Evidence shows no enforceable long-term contract. | Yes; substantial evidence supports the verdict. |
| Whether the district court properly denied a statute of frauds instruction based on Mackay’s testimony. | Mackay's testimony could support ten-year term. | There was no objective evidentiary support for ten-year term. | District court correctly denied the instruction. |
| Who is entitled to attorney fees on appeal. | Mackay prevailed on appeal. | Four Rivers did not prevail. | Mackay awarded attorney fees under I.C. § 12-120(3). |
Key Cases Cited
- Burton v. Atomic Workers Fed. Credit Union, 119 Idaho 17 (Idaho 1990) (statute of frauds and contract duration concerns in employment relations)
- Mackay v. Four Rivers Packing Co., 145 Idaho 408 (Idaho 2008) (Mackay I; contract duration issue; summary judgment reversal for genuine issue of fact)
- Stoddard v. Nelson, 99 Idaho 293 (Idaho 1978) (standard of review for appellate evidence sufficiency)
- Vanderford Co. v. Knudson, 144 Idaho 547 (Idaho 2007) (entitlement to jury instruction when theory supported by evidence)
- Silver Creek Computers, Inc. v. Petra, Inc., 136 Idaho 879 (Idaho 2002) (jury instructions reviewed as whole; no reversible error if not misleading)
- Clark v. Klein, 137 Idaho 154 (Idaho 2002) (instruction quality and law accuracy in jury questions)
- Willie v. Bd. of Trustees, 138 Idaho 131 (Idaho 2002) (attorney fees as commercial transaction under I.C. § 12-120(3))
- McKim v. Horner, 143 Idaho 568 (Idaho 2006) (credibility and weight of evidence are jury functions)