Peterson Hunting v. Labor Commission
2012 UT App 14
Utah Ct. App.2012Background
- Peterson Hunting sought review of the Labor Commission's ruling that it is not an agricultural employer under the Workers’ Compensation Act.
- Frohardt, employed as a hunting guide, performed guiding, meal prep, camp setup, animal care, water pumping, and general hunting-support duties.
- Peterson operates hunting expeditions on 3,000 acres of land owned by Tim Anderson and R.J. Rickenbaugh, with joint profit sharing and no farming operations on the land.
- UDWR provides deer and elk tags to Peterson at no cost in exchange for hunting access; Peterson’s operation is framed as guiding rather than farming.
- ALJ and then the Commission found that Peterson did not qualify as an agricultural employer and did not determine whether payroll exceeded $8,000 to nonimmediate family members; key issue remained whether farming/wildlife management occurred.
- Utah Court of Appeals affirmed: Peterson is not exempt as an agricultural employer and Frohardt must receive workers’ compensation benefits
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Peterson qualifies as an agricultural employer | Peterson asserts he engages in feeding, harvesting, and managing wildlife; payroll under threshold | Commission found no feeding/management of wildlife; operation not agricultural | Not exempt; Peterson is not an agricultural employer |
Key Cases Cited
- Esquivel v. Labor Comm’n, 2000 UT 66 (2000) (review of legal conclusions under correct standard; substantial evidence standard applied to findings of fact)
- Strate v. Labor Comm’n, 2006 UT App 179 (2006) (interpretations of law reviewed for reasonableness; mixed questions of law and fact)
- Acosta v. Labor Comm’n, 2002 UT App 67 (2002) (substantial evidence standard for agency findings; discretionary agency authority)
- Martinez v. Media Paymaster Plus/Church of Jesus Christ of Latter-day Saints, 2007 UT 42 (2007) (marshalling evidence requirement; full record review)
- United Park City Mines Co. v. Stichting Mayflower Mountain Fonds, 2006 UT 35 (2006) (mixed questions of law and fact; deferential review of agency findings)
- Smith v. Workforce Appeals Bd., 2011 UT App 68 (2011) (substantial evidence standard; reasonableness review)
- Chen v. Stewart, 2004 UT 82 (2004) (marshalling of evidence; adversarial posture in appellate review)