Knudsen v. J.R. Simplot Co.
| Decision Date | 18 March 2021 |
| Docket Number | Docket No. 47020 |
| Citation | 483 P.3d 313,168 Idaho 256 |
| Court | Idaho Supreme Court |
| Parties | Erik KNUDSEN, Plaintiff-Appellant-Cross Respondent, v. J.R. SIMPLOT COMPANY, a Nevada corporation, Defendant-Respondent-Cross Appellant. |
Strindberg & Scholnick, LLC, Boise, for Appellant. Thomas G. Hallam argued.
Anderson, Julian & Hull, LLP, Boise, for Respondent. Brian K. Julian argued.
This employment case arises from Ada County district court and concerns whether an at-will employee can maintain a fraud action against his former employer for misrepresenting the nature of the job he was hired to perform.
J.R. Simplot Company ("Simplot") hired Erik Knudsen for a position as a packaging engineer. Early on in his employment, Knudsen was told that he would be the startup manager on a Simplot project in Grand Forks, North Dakota. Knudsen was unfamiliar with the startup manager position and questioned whether those job duties were fairly within the scope of his employment as a packaging engineer. Simplot and Knudsen disagreed as to the nature of his job, leading to the eventual termination of Knudsen's employment. After his dismissal, Knudsen filed this action, alleging fraud, promissory estoppel, breach of the covenant of good faith and fair dealing, and negligent infliction of emotional distress. The district court granted Simplot's motion for summary judgment as to all of Knudsen's claims and denied Simplot's subsequent motion for attorney's fees.
As this matter comes to this Court on appeal from a motion for summary judgment, the facts are presented in the light most favorable to the non-moving party, Knudsen.
In June 2015, a recruiter from Simplot sent Knudsen a message via LinkedIn—an employment-oriented social networking service—regarding a position as a "Senior Packaging Engineer" for the company. At the time, Knudsen had been employed at Hewlett-Packard ("HP"), a technology company with a large campus in Boise, for roughly thirteen years. Knudsen spent five years of his employment at HP as a packaging engineer and was working in that position when Simplot recruited him for the senior packaging engineer position. While satisfied with his position at HP, Knudsen chose to apply for the position at Simplot because of his respect for the company, interest in the food industry, and the possibility of career advancement.
As part of the hiring process, Knudsen received a copy of the position description for the senior packaging engineer job at Simplot, which summarized the position as follows:
This position is responsible for [t]he J.R. Simplot Food Group packaging development efforts to include packaging design and specification, testing packaging materials, establishing written packaging specifications, and project management related to packaging equipment operation and capabilities. Supports foodservice customers and retail customers in packaging design, with particular emphasis on retail packaging design that delivers the presentation and consumer appeal attributes as designated by the client.
In addition to the summary, the position description listed responsibilities of the job such as "[s]upport Engineering in the selection of new packaging equipment" and "identifying and managing projects related to cost reduction opportunities." Finally, the position description listed the requirements of the job, including:
Knudsen submitted his application for the packaging engineer position in the fall of 2015 and was one of two candidates selected for a series of panel interviews. The first panel interview focused on Knudsen's technical expertise and was attended by members of the packaging engineering division at Simplot including: Timothy Lalley, Senior Packaging Engineer; Jason Schwark, Senior Packaging Engineer; and Craig Lamberton, Director of Packaging Engineering. The second panel primarily concerned Knudsen's leadership attributes and was attended by upper-level leadership at Simplot including: Lamberton; Kent Anderson, Director of Technical Engineering; and Lyle Schook, Senior Director of Engineering. Schook sat atop the engineering hierarchy at Simplot and the directors of the various engineering areas, e.g., technical engineering and packaging engineering, reported to him. At the time of Knudsen's hiring there was not a specific engineering area focused on startup management, instead engineers from various divisions were tapped to act as startup managers on projects.
During the interview process, Knudsen was not informed that the position of senior packaging engineer would be expected to perform as a startup manager. However, Knudsen's interview with the second panel focused heavily on his leadership abilities, including project management work he had performed at HP. In particular, Knudsen emphasized his experience leading a project in China to manufacture and release a new printer.
Following the interviews, Simplot informed Knudsen that if he should receive an offer for the packaging engineer position, it would be at a lower introductory rank because he did not have experience in the food industry. Knudsen acknowledged this difference and stated he understood the change. As Knudsen understood it, the difference between the position he was offered as an Engineer 4 and the position he applied for was merely one of salary and scope. Simplot eventually offered Knudsen the position of Engineer 4, as opposed to the original designation of Engineer 5, reporting to Lamberton, the Director of Packaging Engineering. Knudsen accepted Simplot's employment offer.
Knudsen started work at Simplot on November 23, 2015, and contends that he was immediately told his position as a packaging engineer would only be part-time because he would be the startup manager for a Simplot project in Grand Forks, North Dakota (the "Grand Forks project"). The Grand Forks project involved the installation of two new packaging lines for frozen food and had an estimated cost of $22 million. As startup manager for that project, Knudsen would be expected to coordinate the installation of new factory equipment and test it for functionality. This coordination could include, for example, providing for the training of employees on the new equipment, making sure spare parts were on site, ensuring the availability of materials, and communicating with the rest of the project management team to discuss the project's progress. Although startup management is a transient role, existing only so long as needed to accomplish the tasks necessary to transition from the installation of new equipment to its full operation, a startup manager could be a permanent position, working on different projects in succession.
Although Simplot disputes that Knudsen was immediately assigned to be a startup manager, on November 30—one week from his start date—Knudsen received a communications plan for the anticipated Grand Forks project that listed him as the startup manager. Soon thereafter, Knudsen was flown on the Simplot corporate jet to the site of the Grand Forks project and introduced to other members of the team as the startup manager.
In addition to his assignment as a startup manager, Knudsen points to several other instances early in his employment that underscored the unusual nature of his position compared to the other packaging engineers. For example, Simplot circulated an interoffice communication shortly after Knudsen's start date that introduced Knudsen as a new packaging engineer but indicated that Knudsen would report to a different supervisor than the other packaging engineers and focus on a different aspect of the business. This organizational change was precipitated by the departure of Lamberton, the Director of Packaging Engineering, who had played a hybrid role for Simplot and worked with both packaging materials and packaging equipment. Further, Knudsen recalls conversations with the other packing engineers, Lalley and Schwark, in which they stated that being a startup manager was outside the scope of his position. Lalley noted that he had never been asked to act as a startup manager for a project during his years at Simplot. Schwark indicated that he felt frustrated that Knudsen was spending an inordinate amount of time working as a startup manager instead of assisting with packaging engineering.
Knudsen was discouraged by his startup manager assignment and began to protest it with Simplot leadership, stating that he did not believe he had the experience or background to perform the role in a way that added value to the company. Over time, tensions escalated between Knudsen and his superiors—Schook, Director of Engineering, and Anderson, Director of Technical Engineering—regarding his performance as a startup manager. Knudsen's frustrations with his employment came to a head in a meeting with Schook, who told Knudsen that he never intended to have him work as a full-time packaging engineer.
Following his conversation with Schook, Knudsen began to fear that his employment would be terminated due to his inability to successfully perform as a startup manager. He emailed Kayce McEwan, Simplot's Vice President of Human Resources, about his predicament. In his...
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