Parker v. Underwriters Laboratories, Inc., 140 Idaho 517

Summary

The Idaho Supreme Court considered whether payments made under an employment separation agreement were reportable severance pay for purposes of unemployment benefits. The court held that, after the first two weeks, the payments were made in exchange for the claimant's release of employment-related claims rather than for past services, and therefore were not reportable severance pay under the applicable administrative rule. The court reversed the Industrial Commission's decision and awarded costs to the claimant.

Holdings

1. After the first two weeks, the payments Parker received under the release and enhanced-severance agreement were not reportable "severance pay" within the meaning of IDAPA 09.01.30.525.11 because they were consideration for her release of claims rather than payment for services previously rendered or a salary substitute.
2. The Commission's decision and order was reversed because the payments Parker received after the first two weeks did not constitute reportable severance pay.

Questions Presented

1. Whether periodic payments made pursuant to an agreement requiring Parker to release employment-related claims constituted reportable severance pay under IDAPA 09.01.30.525.11.
2. Whether Parker was entitled to a waiver of repayment of unemployment benefits under Idaho Code section 72-1369(1)(d).

Disposition

reversed