Schmolke v. Ho-Chunk Nation

7 Am. Tribal Law 166
CourtHo-Chunk Nation Trial Court
DecidedJune 14, 2007
DocketNo. CV 01-05
StatusPublished

This text of 7 Am. Tribal Law 166 (Schmolke v. Ho-Chunk Nation) is published on Counsel Stack Legal Research, covering Ho-Chunk Nation Trial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Schmolke v. Ho-Chunk Nation, 7 Am. Tribal Law 166 (hochunkct 2007).

Opinion

JUDGMENT

MARK BUTTERFIELD, Chief Judge.

The Trial in this matter took place on June 19, 2001 at the Ho-Chunk Nation Court House in Black River Falls, WI before the Hon. Mark Butterfield, Chief Trial Judge. The plaintiff was represented by Mark Goodman, Esq. of Goodman and Osborne Sparta, WI and the defendants were represented by John Swimmer, Esq. of the Ho-Chunk Nation Dept, of Justice.

INTRODUCTION

This is an employment dispute between an employee who accepted a position with the Ho-Chunk Casino in a management position as “Interim Marketing Director” and the Ho-Chunk Nation Executive Director of Business. Fundamentally this is a case about a misunderstanding as to what type of position the plaintiff, Mr. Schmolke, held. This is critical under Ho-Chunk Nation law because should Mr. Schmolke be classified as a permanent employee he has a right to grieve and to certain job protections including the right to be dismissed only for just cause. However, if Mr. Schmolke was more properly classified as an “LTE” or Limited Term Employee he has no right to grieve and may be dismissed for any reason. That is the crux of this case. What was the proper legal classification of Mr. Schmolke at the time of his dismissal? The plaintiff contends that he was hired under an expectation that his position would ripen into full time permanent employment and the defendant contends that Mr. Schmolke was properly classified as an LTE and had no expectation or right to further employment.

Both positions are not perfectly supported or there would be no dispute. Mr. Schmolke worked 92 days in the last position he held as Interim Marketing Director at Ho-Chunk Casino, which is two days longer than necessary to survive a probationary period of 90 days. It is undisputed that Mr. Schmolke was credited with annual and sick leave, both types of leave LTE’s are not eligible for. However, the defendant points out that there is no special classification as “Interim” anything and so the closest Mr. Schmolke can be is an LTE since he had only a reasonable expectation he was filling a position for a limited amount of time. However, the defendant must explain how Mr. Schmolke could work as an LTE when by law an LTE can only work for 160 hours or 30 days with an one time extension of 160 more hours or another 30 days.

APPLICABLE LAW

Ho-Chunk Nation Policies and Procedures Manual [PPM], Chapter 3, pp. 5-7.

KINDS OF EMPLOYMENT

Unclassified Employees:

The Unclassified service is composed of those top management positions that serve at the will of the Ho-Chunk Nation. Such positions include elected or appointed positions.

[168]*168Initial Probationary Employees:

New or 'rehired employees who serve a prescribed period of close supervision and evaluation in order to assess their ability and adaptation. Nonexempt employees are eligible for overtime. Exempt employees are eligible for compensation for up to 45 hours regular pay per week.

Permanent Full-time Employees:

Employees who regularly work a minimum of 32 hours per week on a continuous basis following satisfactory completion of a probationary period.

Permanent Part-time Employees:

Employees who complete a satisfactory probationary period and regularly work more than 20 hours but less than 32 hours per week on a continuous basis. Part-time employees shall not hold supervisory positions.

Limited Term Employees:

Employees holding jobs of limited or specified duration arising our of special projects, position vacancy pending appointment, the absence of a position incumbent, abnormal work loads, emergencies, “on-call” at the enterprises, or other reasons established by the Nation. Limited Term Employees may work either full- or part-time work schedules, but will not be eligible to use the Administrative Review Procedure to file formal grievances except in matters pertaining to alleged discrimination or unfair treatment. Limitation of LTE status is 1 month or 160 hours per year, unless a one time only 30-day extension is approved by the Division Director and the Personnel Director. Non-exempt Limited Term Employees will be eligible to earn overtime. Exempt LTEs are eligible for compensation for up 45 hours regular pay per week. LTEs are not eligible for health insurance programs.

Employee Orientation and Integration

New employees are to be scheduled for a thorough orientation on or before their report date; they receive information about the Nation’s employment benefits and complete related documents. The employee’s supervisor is to provide each new employee with such information as background about the Nation, its personnel policies, each department's organization and functions, the employee’s job content and performance evaluation standards, job safety, promotional opportunities, employee status, and any other information deemed pertinent to establish employee comfort.
The topics covered by a supervisor in a employee orientation shall be documented on a form prescribed by the Personnel Department, who will receive completed orientation forms, including the employee signature, for placement in the employee’s personnel file.
Following initial orientation, supervisor and managers shall regularly check with the employees concerning questions they may have, their working conditions, any problems or difficulties they may have encountered, and feedback concerning their performance of job progress.

Purpose of Probationary Period

The probationary period is an intricate part and extension of the employee selection process during which the employee will be considered in training and under careful observation and evaluation by supervisory personnel. This period will be utilized to train and evaluate the employee’s effective adjustment to work tasks, conduct, observance of rules, attendance and job responsibilities, and to provide for the release of any probation[169]*169ary employee whose performance does not meet required standards of job progress or adaptation.

Length of Probationary Period

Employees will serve a 90-day probationary period, during which time their job progress will be formally evaluated by the standards established for their areas of job responsibility.

During Probation

Initial probationary employees are not eligible for some benefits paid for or sponsored by the Nation. Upon successful completion of the probationary period, employees are considered permanent employees of the Nation and become eligible for the benefits described herein provided they satisfy the terms and conditions of the various benefits programs.
If, at the conclusion of the employee’s probationary period, the employee’s performance and employment conditions have been satisfactory, a retention recommendation is to be made to the Director, on or before the expiration of the employee’s probationary period.
Such a recommendation wall be accompanied by the complete, final probationary performance evaluation according to standards developed by the Personnel Department and status change.

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Bluebook (online)
7 Am. Tribal Law 166, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schmolke-v-ho-chunk-nation-hochunkct-2007.