McNulty v. Sinclair Oil Corp.
152 Idaho 582
| Idaho | 2012Background
- McNulty worked as a ski patroller for Sinclair/Sun Valley from 2005–2010 and filed for unemployment benefits for 2009-04-19 to 2009-11-28.
- During off-season weeks, he worked part-time at the Sawtooth Club and failed to report those earnings to IDOL.
- IDOL determined him ineligible for benefits due to willful false statements or failure to report material facts.
- A hearings examiner and the Idaho Industrial Commission upheld in part the eligibility denial, finding willful nondisclosure for multiple weeks.
- McNulty contested the determination, seeking reversal and a waiver of overpayments; the Supreme Court reviewed de novo.
- The Court ultimately affirmed that his reporting omissions were willful, disqualifying him from benefits and waivers, and awarded costs to the Department.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether McNulty willfully failed to report material facts | McNulty: omissions not willful; facts not material. | IDOL/Commission: omissions were willful and material to eligibility. | Yes; willful reporting failure exists and is material. |
| Whether McNulty qualifies for a waiver of overpayments | Waiver due to Department or employer error; misreporting not his fault. | Waiver unavailable where overpayment results from claimant’s failure to report. | No; not eligible for waiver for state or federal overpayments. |
| Whether attorney’s fees on appeal may be awarded | Requested fees under I.C. 12-117. | Statutory provision does not authorize fees for admin-appeal review; not prevailing party. | Not entitled to attorney’s fees. |
Key Cases Cited
- Meyer v. Skyline Mobile Homes, 99 Idaho 754 (Idaho Supreme Court 1979) (materiality includes information relevant to eligibility even if not changing outcome)
- Artis v. Morrison-Knudsen Co., 107 Idaho 1109 (Idaho Supreme Court 1985) (misrepresentation not material when statute precludes denial of benefits)
- Archbold v. Huntington, 201 P. 1041 (Idaho 1921) (willful conduct described as intentional omission)
- Ewins v. Allied Sec., 138 Idaho 343 (Idaho Supreme Court 2003) (standard of review for Commission findings)
- Steffen v. Davison, Copple, Copple, & Copple, 120 Idaho 129 (Idaho Supreme Court 1991) (burden on claimant to prove statutory eligibility)