Ansley Nickell v. Department of Labor and Economic Opportunity, 369779

Ansley Nickell applied for Pandemic Unemployment Assistance (PUA) benefits in May 2020, relying on a self-certification of eligibility under the federal CARES Act.
Initially, no documentation of prepandemic employment was required, but the law changed under the CAA to require such proof.
Nickell never provided documentation of employment or planned employment before the pandemic, asserting she was a full-time student and had only lined up possible future employment dependent on graduating and obtaining her license.
The Agency eventually determined she was not eligible for benefits and sought restitution for overpaid amounts.
Administrative and commission rulings ultimately found Nickell eligible; circuit court affirmed, and the Agency appealed to the Court of Appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether claimant qualified for PUA benefits without evidence of prepandemic employment or planned employment	Nickell argued she met the requirements because she intended to begin working and was prevented by the pandemic	Agency argued that documentation of employment or planned employment is required under federal law	Court held Nickell was ineligible, reversing lower decisions
Whether the Agency provided adequate notice of the requirement to submit documentation	Nickell claimed she did not receive adequate notice	Agency maintained notice was properly given via online account	Court did not reach this question, relying on the substantive eligibility issue
Application of the legal standard in review of agency and lower court decisions	Nickell supported deference to agency/circuit determinations	Agency asserted legal interpretation is reviewed with minimal deference	Court agreed with the Agency's legal standard
Whether Nickell's circumstances (inability to finish school/get license due to pandemic) satisfied statutory categories for eligibility	Nickell argued her interrupted education/caretaking for children qualified her	Agency countered these did not meet statutory requirements absent employment documentation	Court found these circumstances insufficient for eligibility

Lawrence v Mich Unemployment Ins Agency, 320 Mich App 422 (Mich. Ct. App. 2017) (describes standard for reviewing agency and lower court decisions in administrative law)
Dep't of Licensing & Regulatory Affairs/Unemployment Ins Agency v Lucente, 508 Mich 209 (Mich. 2021) (addresses standards of statutory interpretation in administrative appeals)