Idaho at-will employees have standing to sue employer for fraudulent hiring

The Idaho Supreme Court recently rendered a decision highlighting an important distinction between wrongful discharge and “fraudulent hiring,” the latter of which allows at-will employees to sue their former employer.

Background

Employment in Idaho is presumed to be “at-will” unless contractually stated otherwise. In other words, with very few exceptions, an employment relationship has no set length, and either party may end it at any time, with or without notice or cause.

At first glance, the recent supreme court opinion may look like another narrow exception to the at-will employment presumption. On closer inspection, however, we find the ruling instead creates an “important distinction between a fraud-in-hiring claim and a wrongful discharge claim that makes the former permissible and the latter limited in an at-will relationship.”

Facts

The J.R. Simplot Company hired Erik Knudsen to work as a packaging engineer. The position quickly morphed into a startup manager job for a project in Grand Forks, North Dakota. Simplot and Knudsen disagreed about the nature of the employment, which eventually led to his discharge.