Thrall v. St. Luke's Regional Med Cntr
Annotate this CaseJoan Thrall appealed an Idaho Industrial Commission decision denying her unemployment benefits. The Commission concluded that Thrall was not entitled to benefits because she voluntarily resigned from St. Luke's Regional Medical Center without good cause. Thrall timely appealed, arguing that she was discharged and that St. Luke's failed to show the discharge was for misconduct. The Supreme Court reversed and remanded this case for further proceedings. Because the Commission's factual findings demonstrate that Thrall satisfied her burden to show that she was discharged, Thrall was entitled to benefits unless the discharge was for misconduct in connection with her employment, with St. Luke's carrying the burden to show the discharge was for misconduct. When the Commission mistakenly concluded that Thrall voluntarily resigned, it improperly placed the burden on Thrall to show that she was not discharged for misconduct. "Though the Commission's order includes a variety of statements regarding misconduct and Thrall's errors in the performance of her job duties, it is unclear to what extent those statements were a consequence of its misallocation of the burden of proof."
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