Tasha Jeffcoat v. Idaho Dept of Correction, 389 P.3d 139

Jeffcoat worked for Idaho Department of Corrections until June 14, 2013, and filed for unemployment on June 26, 2013.
Beginning July 4, 2013, she worked part-time for AEIdaho, LLC and continued to claim unemployment benefits through January 11, 2014.
Idaho Department of Labor (IDOL) cross-checked reported earnings, found discrepancies between employer records and Jeffcoat’s reported earnings, and sent a letter requesting explanation which Jeffcoat did not respond to.
IDOL concluded Jeffcoat provided false information to obtain benefits; an Appeals Examiner found the misstatements willful and denied waiver of repayment.
The Industrial Commission conducted a de novo review, adopted the Appeals Examiner’s findings with minor modifications, imposed a 25% civil penalty, and required repayment of benefits.
Jeffcoat appealed to the Idaho Supreme Court pro se but raised only general arguments about intent; the Supreme Court affirmed the Commission’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jeffcoat willfully misstated or concealed material facts to obtain unemployment benefits	Jeffcoat contends she reported what she believed she earned and would have corrected errors if she had known	IDOL argues discrepancies and failure to respond to audit letter show willful misstatement/concealment	Court held Jeffcoat willfully misstated a material fact and was ineligible for benefits or waiting-week credit
Whether a waiver of repayment under Idaho Code § 72-1369(1)(d) was appropriate	Jeffcoat implicitly sought relief from repayment	IDOL argued waiver inappropriate given willfulness	Court held waiver was not available and repayment required
Whether a 25% civil penalty under Idaho Code § 72-1369(2) applies	Jeffcoat did not meaningfully contest penalty on legal grounds	IDOL sought penalty consistent with statute given willfulness	Court upheld the 25% civil penalty
Whether appellant preserved specific legal errors for review	Jeffcoat raised general claims about intent and evidence but no specific legal arguments or authorities	IDOL maintained appellant failed to preserve particularized legal challenges	Court held general assertions were insufficient; issues not preserved and affirmed the Commission

Bell v. Idaho Dep’t of Labor, 157 Idaho 744, 339 P.3d 1148 (2014) (standards for review of Industrial Commission decisions)
Uhl v. Ballard Med. Prods., Inc., 138 Idaho 653, 67 P.3d 1265 (2003) (appellate review standards on Commission factual findings)
Hughen v. Highland Estates, 137 Idaho 349, 48 P.3d 1238 (2002) (deference to Commission credibility determinations)
Neihart v. Universal Joint Auto Parts, Inc., 141 Idaho 801, 118 P.3d 133 (2005) (viewing facts in light most favorable to prevailing party before Commission)
Bach v. Bagley, 148 Idaho 784, 229 P.3d 1146 (2010) (requirement to assert assignments of error with particularity)
Twin Falls Cnty. v. Coates, 139 Idaho 442, 80 P.3d 1043 (2003) (pro se litigants held to same standards as represented parties)