Mackay v. Four Rivers Packing Co.
179 P.3d 1064 (2008)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
An oral employment contract for an indefinite term, such as 'until retirement,' is not barred by the Statute of Frauds because the contingency for its completion could possibly occur within one year. Direct evidence that an employer perceived an employee as unable to work due to a medical condition is sufficient to create a genuine issue of material fact for a 'regarded as disabled' discrimination claim.
Facts:
- In the summer of 1999, Randy Smith, general manager of Four Rivers Packing Co., hired Stuart Mackay as a field man.
- In March 2000, Mackay alleges that Four Rivers offered him a long-term oral employment contract to continue working until his retirement, which Mackay accepted.
- In 2000, Mackay was diagnosed with Type II diabetes and notified Four Rivers of his condition.
- In early 2003, Mackay's condition progressed, requiring him to become insulin-dependent, and he again notified Four Rivers.
- On March 7, 2003, Randy Smith terminated Mackay's employment.
- A coworker, Jim Goins, claimed to have heard Smith state on at least two occasions that Mackay was 'too sick with diabetes to work for Four Rivers Packing.'
- Four Rivers denies offering a long-term contract, claiming Mackay was an at-will employee terminated for unsatisfactory performance.
Procedural Posture:
- Stuart Mackay filed a complaint against Four Rivers Packing Co. in an Idaho district court, alleging breach of contract and disability discrimination.
- Four Rivers answered, asserting that Mackay was an at-will employee and raising the Statute of Frauds as an affirmative defense.
- Four Rivers moved for summary judgment on both claims.
- The district court granted summary judgment in favor of Four Rivers, concluding the alleged contract was barred by the Statute of Frauds and that Mackay had failed to show his diabetes was a disability under the IHRA.
- Mackay filed a motion for reconsideration, which the district court denied.
- Mackay, as appellant, appealed the summary judgment order to the Supreme Court of Idaho.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
1. Does Idaho's Statute of Frauds, which invalidates oral agreements not to be performed within one year, bar an alleged oral employment contract that is to last 'until retirement'? 2. Does a coworker's testimony, stating that a manager said an employee was 'too sick with diabetes to work,' create a genuine issue of material fact as to whether the employer 'regarded' the employee as disabled under the Idaho Human Rights Act (IHRA)?
Opinions:
Majority - J. Jones
1. No. An oral employment contract that is to last 'until retirement' is not barred by the Statute of Frauds because the contingency of retirement could possibly occur within one year. The court reasoned that the Statute of Frauds only applies to contracts whose performance cannot possibly be completed within a year. Unlike a contract 'until age 65,' a contract 'until retirement' has an indefinite duration because the employee could choose to retire at any time, including within the first year. Therefore, the alleged oral contract falls outside the Statute of Frauds. 2. Yes. A coworker's testimony about a manager's discriminatory statement constitutes direct evidence that the employer regarded the employee as substantially limited in the major life activity of working, thus creating a genuine issue of material fact that precludes summary judgment. The court found that Goins's statement directly evidences the employer's subjective belief about Mackay's condition. Because this fact is disputed by Four Rivers, it represents a genuine issue of material fact that must be decided by a jury, not by a judge on summary judgment.
Analysis:
This decision clarifies the scope of Idaho's Statute of Frauds regarding employment contracts, distinguishing between contracts with a definite term exceeding one year (e.g., 'until age 65') and those with an indefinite term based on a contingency that could occur within a year (e.g., 'until retirement'). It reinforces the narrow interpretation of the statute's one-year provision. Furthermore, the ruling emphasizes the significance of direct evidence in 'regarded as' disability discrimination claims, establishing that a single, credible statement reflecting an employer's discriminatory perception is sufficient to survive a summary judgment motion and proceed to trial.
