Law School Case Brief
Mackay v. Four Rivers Packing Co. - 145 Idaho 408, 179 P.3d 1064 (2008)
The burden at all times is upon the party moving for summary judgment to prove the absence of a genuine issue of material fact. The plaintiff's case must be anchored in something more than speculation, and a mere scintilla of evidence is not enough to create a genuine issue. However, all doubts are to be resolved against the moving party, and the motion must be denied if the evidence is such that one may draw conflicting inferences therefrom, and if reasonable people might reach different conclusions.
Four Rivers Packing Co. hired Stuart Mackay as a field man, but let him go when Four Rivers began experiencing financial difficulties and faced a lawsuit. When the lawsuit was resolved, Smith rehired Mackay. Four Rivers offered him a long-term employment contract to continue working as a field man up to the time of his retirement. Mackay claimed he accepted the long-term offer of employment. Four Rivers denied extending such offer. In 2000, Mackay was diagnosed with Type II diabetes and became dependent on insulin. In 2003, Smith terminated Mackay's employment relationship without notice. Plaintiff Mackay sued Four Rivers alleging the breach of an oral contract for long-term employment and claiming that Four Rivers terminated him because it regarded him as disabled due to his insulin dependent diabetes and discriminated against him in violation of the Idaho Human Rights Act (IHRA). Defendant Four Rivers argued that the contract claimed by Mackay was null, void, and unenforceable as violating Idaho Code § 9-505 because the agreement could not be performed within one year of its making. Four Rivers moved for summary judgment in district court. The district court granted the move for summary judgment. Plaintiff appealed to vacate the summary judgment order entered in favor of defendant Four Rivers.
1. Was the employment contract of Mackay fell under the scope of Statute of Frauds?
2. Was the district court in error in granting the move for summary judgment despite factual contention as to the cause of termination?
1. The Court held that the contract was outside Idaho's Statute of Frauds. Since the alleged contract here contained a term that it will last until Mackay retires, and Mackay could have retired within the first year, the oral contract did not violate the Statute. The Court also resolved that Burton v. Atomic Workers Fed, where the Court decided that trial court should have instructed the jury on the employer's Statute of Frauds defense, was not applicable in the case. Mackay alleges the term of the contract was until retirement. Unlike the contract in Burton, which specified "until age 65," the alleged contract term in this case was indefinite.
2. The Court held that the district court erred in granting the summary judgment. There were disputed issues of fact as to whether the alleged contract contained a provision for its duration, its existence, and its terms. Summary judgment was improper on the disability discrimination claim as a coworker's affidavit was direct evidence that a supervisor regarded the Mackay as being substantially limited in the major life activity of working, thereby raising an issue of fact as to whether Four Rivers terminated the employee because of that perceived disability.
The Court vacated the order granting summary judgment and remanded the case for further proceedings.
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