Background

• Ringrose, a deputy, was terminated by the Laramie County Sheriff's Department for an off-duty incident at the Outlaw Saloon, where he provided security while being paid by the saloon.
• Initial unemployment benefits were denied; a contested case hearing awarded benefits, holding the discharge was not for misconduct connected with work.
• The Unemployment Insurance Commission affirmed the hearing officer; Laramie County petitioned for judicial review and the district court reversed.
• The Wyoming Supreme Court reviews under substantial evidence standard, deferring to agency findings of fact but reviewing legal conclusions de novo.
• Evidence showed Ringrose did not file a report until prompted, did not photograph the scene, and did not follow up at the hospital, with contested implications for policy violations.
• The court ultimately held there was substantial evidence supporting the Commission’s decision that Ringrose was not terminated for misconduct.

Issues

Key Cases Cited

• Safety Medical Services, Inc. v. Employment Security Comm'n, 724 P.2d 468 (Wy. 1986) (misconduct requires willful disregard of duties; ordinary negligence not misconduct)
• Aspen Ridge Law Offices, P.C. v. Wyo. Dep't of Employment, 143 P.3d 911 (Wy. 2006) (policy violations may constitute misconduct if willful and contrary to duties)
• Wyo. Dep't of Employment, Unemployment Ins. Comm'n v. SF Phosphates, Ltd., 976 P.2d 199 (Wy. 1999) (employer interests and employee duties; misconduct requires more than isolated negligence)
• Koch v. Dep't of Employment, Unemployment Ins. Comm'n, 294 P.3d 888 (Wy. 2013) (longitude of 'misconduct' analysis; willful or intentional violations matter)
• Laramie County Sheriff's Dep't v. Cook, 272 P.3d 966 (Wy. 2012) (discusses policy-based grounds and course of employment considerations)
• Weidner v. Life Care Centers of America, 893 P.2d 706 (Wy. 1995) (deference to agency findings of fact given agency expertise)