Summary
The Idaho Supreme Court reviewed whether owner/operators hauling goods for Western Home Transport were engaged in covered employment under Idaho's Employment Security Law. The Court overruled part of Giltner's bright-line rule concerning the relevance of a motor carrier's federal transportation authority, vacated the Industrial Commission's decision, and remanded for further proceedings.
Court
Supreme Court of the State of Idaho
Jurisdiction
Idaho
Decision date
February 11, 2014
Docket number
40462
Disposition
reversed_and_remanded
Questions Presented
- Whether the owner/operators were presumed to be engaged in covered employment under Idaho's Employment Security Law.
- Whether Western could establish the independent-business prong of the exemption in Idaho Code section 72-1316(4) based on the owner/operators' use of Western's DOT authority.
- Whether the Idaho Industrial Commission applied an erroneous bright-line rule by treating the source of the owner/operators' DOT authority as dispositive of independent-business status.
Holdings
- The source of an owner/operator's DOT or other federal or state authority to haul goods interstate for a motor carrier is not a relevant factor in analyzing whether the owner/operator is engaged in an independently established trade, occupation, profession, or business.
- The Commission must reconsider whether Western satisfied the second prong of Idaho Code section 72-1316(4) without considering the source of the owner/operators' DOT authority as a factor.
Court Document
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