Venable v. Internet Auto Rent & Sales, Inc.
156 Idaho 574
Idaho2014Background
- Venable was hired March 15, 2011 as an at-will Internet Manager at Internet Auto Rent & Sales, Inc.
- Venable alleged the dealership violated the Idaho Consumer Protection Act (ICPA) and Truth in Lending Act through deceptive practices.
- She reported misconduct to management and was terminated about a month later.
- Internet Auto was granted summary judgment on all claims except slander and negligent infliction of emotional distress; Venable amended to include those claims.
- At trial the jury ruled for Internet Auto on the remaining claims; Venable’s motions for reconsideration were denied; the district court ultimately denied her appeal; Internet Auto sought fees under I.C. §12-121, which were awarded on appeal.
- The Idaho Supreme Court affirmed the district court’s grant of summary judgment and awarded Internet Auto its attorney fees on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Venable’s wrongful-discharge claim survived summary judgment. | Venable argues public-policy protection for reporting deceptive practices. | Internet Auto contends no protected activity was shown and no causal link to termination. | Summary judgment affirmed; no genuine issue of protected activity. |
| Whether the district court properly denied Venable’s second motion for reconsideration. | Venable asserts new facts show genuine issues of material fact. | Internet Auto argues evidence remains insufficient to defeat summary judgment. | Reconsideration denial upheld; no new facts creating genuine issues. |
| Whether Internet Auto is entitled to attorney fees on appeal. | Internet Auto sought fees under I.C. §12-121 for frivolous appeal. | Fees awarded to Internet Auto on appeal. |
Key Cases Cited
- Bollinger v. Fall River Rural Elec. Co-op, Inc., 152 Idaho 632 (Idaho 2012) (public policy exception is narrow; must identify specific policy and conduct)
- Thomas v. Medical Center P.A., 138 Idaho 200 (Idaho 2002) (summary-judgment standard; disputed issues of law and fact)
- Edmondson v. Shearer Lumber Products, 139 Idaho 172 (Idaho 2003) (at-will employment; public-policy exception requires protected activity)
- Sorensen, 118 Idaho 666 (Idaho 1992) (public policy exceptions to at-will employment)
- Van v. Portneuf Medical Center, 147 Idaho 552 (Idaho 2009) (public policy analysis; what constitutes protected activity)
- Oats v. Nissan Motor Corp. in U.S.A., 126 Idaho 162 (Idaho 1994) (summary judgment standards; evidence must show genuine issue)
- Brown v. Matthews Mortuary, Inc., 118 Idaho 830 (Idaho 1990) (nonmoving party must present admissible evidence; conclusory statements insufficient)