Arnold v. Workforce Services, 491 P.3d 957

David Arnold was temporarily laid off to care for his blind wife and indicated on his unemployment application that he was not able/available to accept full-time work for the moment.
Because Arnold was expected to return to his former employer, the Department of Workforce Services granted a work-search deferral (waiving the active job-search requirement) but denied benefits because he was not "able and available" for full-time work under Utah Code § 35A-4-403.
An ALJ and the Workforce Appeals Board affirmed the denial after Arnold testified he was unavailable for roughly two more weeks; the Utah Court of Appeals reversed on summary disposition, invoking the absurdity doctrine.
The Utah Supreme Court granted certiorari to decide whether a work-search deferral also waives the statutory able-and-available requirement.
The Supreme Court reversed the court of appeals, holding the statute plainly requires claimants to remain able and available even when a work-search deferral is granted, and therefore Arnold was properly denied benefits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a work-search deferral waives the statutory requirement that a claimant be "able and available" to accept full-time work under Utah Code § 35A-4-403	Arnold: a deferral from actively searching for work should excuse the availability requirement during the deferral	Department: statute permits waiver of the job-search duty but not the able-and-available duty; availability ensures immediate return if work arises	Court held: deferral does not waive the able-and-available requirement; denial of benefits affirmed
Whether applying the absurdity doctrine to read the statute as waiving availability was appropriate	Arnold/Ct. of Appeals: literal reading leads to absurd result because claimants not searching will not be offered jobs	Department: there is a rational interpretation—availability preserves employers' ability to recall workers earlier than expected; literal reading aligns with statutory purpose	Court held: no absurdity here; plain text and purpose support requiring availability despite a work-search deferral

Bagley v. Bagley, 387 P.3d 1000 (Utah 2016) (explains narrow application of the absurdity doctrine and when literal language may be reformed)
State ex rel. Z.C., 165 P.3d 1206 (Utah 2007) (applies absurdity doctrine where literal reading produced an implausible legislative intent)
Dorsey v. Dep’t of Workforce Servs., 330 P.3d 91 (Utah 2014) (availability measured by ability to respond quickly enough to accept work; international-travel rule conflicted with availability requirement)
Savage v. Utah Youth Vill., 104 P.3d 1242 (Utah 2004) (courts look first to plain statutory language in interpretation)
Murray v. Utah Labor Comm’n, 308 P.3d 461 (Utah 2013) (addresses standard of review for administrative decisions)
Nichols v. Jacobsen Constr. Co., 374 P.3d 3 (Utah 2016) (de novo review of statutory interpretation)