Facts
- Four Rivers Packing Co. hired Stuart Mackay in 1999 as an onion “field man” to secure grower contracts, then laid off employees during financial and ownership disputes.
- Mackay was rehired; he alleged that in March 2000 the general manager orally promised long-term employment “until retirement,” which Mackay estimated could be about ten years.
- Four Rivers denied making a long-term promise and asserted Mackay was an at-will employee.
- Mackay was diagnosed with Type II diabetes in 2000 and became insulin-dependent in early 2003; he informed Four Rivers about his insulin use and potential side effects.
- On March 7, 2003, Four Rivers terminated Mackay without notice; Mackay claimed the discharge was due to diabetes.
- A co-worker testified the general manager said Mackay was “too heavy” and had “too many health problems.”
- Mackay sued for (1) breach of the alleged oral employment contract and (2) disability discrimination under the Idaho Human Rights Act (IHRA) on a “regarded as” disabled theory.
- The district court granted summary judgment to Four Rivers, ruling the oral contract was barred by Idaho’s one-year Statute of Frauds provision and that Mackay failed to show disability (or being regarded as disabled) under the IHRA.
Issues
- Whether an alleged oral agreement to employ Mackay “until retirement” was unenforceable under Idaho Code § 9-505(1) because it was not to be performed within one year.
- Whether summary judgment was proper on Mackay’s IHRA claim where evidence suggested Four Rivers may have regarded him as disabled due to diabetes.
Decision
- The Idaho Supreme Court vacated summary judgment and remanded.
- The court held the alleged “until retirement” oral employment agreement was not barred by the Statute of Frauds because it was capable of being fully performed within one year.
- The court held genuine disputes of material fact existed on whether Four Rivers regarded Mackay as disabled under the IHRA, making summary judgment improper.
Legal Principles
- Under Idaho Code § 9-505(1), the one-year Statute of Frauds applies only to agreements that, by their terms, are incapable of full performance within one year; improbability or the parties’ expectations of longer duration does not trigger the statute.
- An oral employment promise framed as lasting “until retirement” can fall outside the one-year provision because retirement could occur within one year.
- On summary judgment, courts must draw reasonable inferences in favor of the nonmoving party and may not resolve credibility disputes or weigh competing evidence.
- Under the IHRA, evidence that an employer perceived an employee’s medical condition as substantially limiting can support a “regarded as” disability theory and may create a triable fact issue.
Conclusion
The Idaho Supreme Court ruled that an oral “until retirement” employment promise was not categorically unenforceable under the one-year Statute of Frauds and that conflicting evidence about perceived disability and motive required trial on both the contract and IHRA claims.