Stark v. ASSISTED LIVING CONCEPTS, INC., 272 P.3d 478

Claimant Brooke Stark was employed as residence director at Sylvan House (a facility of Assisted Living Concepts, Inc.) from 2008 to 2010.
On October 29, 2010, Stark was asked by regional sales leadership about a rumor that Teton House might be closing, and she denied knowing the source.
Later that evening, HR and then the CEO separately asked Stark to disclose the rumor’s source; Stark refused, saying she would not reveal sources and would 'take one for the team.'
Stark was suspended pending investigation and was terminated effective October 29, 2010.
Stark applied for unemployment benefits; the Appeals Examiner found misconduct, the Industrial Commission reversed, and the Idaho Supreme Court ultimately reversed the Commission, concluding misconduct occurred and awarding costs to the appellant on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Stark's refusal to disclose the source misconduct in connection with employment?	Stark contends the conduct was not linked to her job duties.	Employer argues the misconduct was connected to its business and was a valid directive matter.	Yes; conduct was in connection with employment.
Does misconduct encompass a deliberate violation of reasonable employer rules or a disregard of the employer's interest?	Insubordination alone should not preclude eligibility; failure to reveal sources may be excused as a lack of direct harm.	Disobeying a direct order and violating reasonable rules constitutes misconduct.	Yes; it constitutes misconduct under the three-prong standard.
Was the employer's expectation objectively reasonable for Stark to disclose sources?	No evidence the source disclosure would have halted the rumor or harmed the employer if undisclosed.	Reasonable to seek the source to prevent harm to the business and employees.	Yes; the expectation was objectively reasonable.

Avery v. B & B Rental Toilets, 97 Idaho 611 (1976) (insubordination analysis distinguished from absolute docility; legitimate direct orders may be enforced)
Folks v. Moscow School Dist. No. 281, 129 Idaho 833 (1997) (intentional insubordination focus; pattern not required for misconduct)
Adams v. Aspen Water, Inc., 150 Idaho 408 (2011) (single incident can constitute misconduct; form of discipline irrelevant)
Fife v. Home Depot, Inc., 260 P.3d 1180 (2011) (standard of review; substantial evidence and legal application in IC decisions)
Sprague v. Caldwell Trans., Inc., 116 Idaho 720 (1989) (framework for evaluating employment-related misconduct)