B.L. Readinger v. UCBR
B.L. Readinger v. UCBR - 1289 C.D. 2016
| Pa. Commw. Ct. | Jun 5, 2017Background
- Claimant Readinger, a full-time water plant operator, was discharged after leaving his overnight shift on March 4-5, 2016 without being relieved, leaving the plant without a certified operator for ~22 minutes.
- Employer relied on an operator checklist (stating an operator may not leave until relieved) and DEP regulations requiring periodic readings; Employer’s witnesses testified Claimant said he "quit" during a phone call after a confrontation.
- Claimant asserted he left because he was ill (asthmatic), denied quitting, claimed inadequate training on the rule, and alleged a hostile work environment unrelated to the immediate incident.
- A referee found Claimant committed willful misconduct; the Board affirmed, finding a known, reasonable rule was violated and rejecting Claimant’s illness and training claims as not credible.
- The Board also said that even if analyzed under voluntary leaving (Section 402(b)), Claimant failed to show necessitous and compelling cause or reasonable efforts to preserve employment.
- Commonwealth Court reviewed the Board’s credibility findings for substantial-evidence support and affirmed the denial of unemployment benefits under Section 402(e).
Issues
| Issue | Readinger’s Argument | Employer’s Argument | Held |
|---|---|---|---|
| Whether Claimant committed willful misconduct disqualifying him from UC benefits under §402(e) | He left due to illness, lacked training on the rule, did not quit | Claimant knowingly violated a known, reasonable rule by leaving without relief and indicated he quit | Held: Substantial evidence supports Board’s finding of willful misconduct; benefits denied |
| Whether Employer proved existence and reasonableness of a work rule | Claimed no rule forbade leaving for illness | Employer pointed to the operator checklist and DEP requirements prohibiting unattended uncertified operation | Held: Employer proved a known, reasonable rule existed and was violated |
| Whether Claimant established good cause for leaving | Illness and hostile work environment justified leaving | Employer argued anger/quitting—not illness—motivated leaving; no adequate notice or relief obtained | Held: Board rejected illness as primary motive; Claimant failed to show good cause |
| Whether Board’s credibility and factual findings were supported by substantial evidence on appeal | Argued Board erred and witnesses lied | Employer relied on testimony and documentary checklist; Board credited Employer witnesses | Held: Court defers to Board credibility findings; substantial evidence supports conclusions |
Key Cases Cited
- Guthrie v. Unemployment Compensation Board of Review, 738 A.2d 518 (Pa. Cmwlth.) (appellate review scope in UC cases; deference to Board findings)
- Johns v. Unemployment Compensation Board of Review, 87 A.3d 1006 (Pa. Cmwlth.) (definition and framework for willful misconduct; burden shift once employer proves rule and violation)
- Maskerines v. Unemployment Compensation Board of Review, 13 A.3d 553 (Pa. Cmwlth.) (employer’s burden to prove a reasonable work rule and violation)
- Curran v. Unemployment Compensation Board of Review, 752 A.2d 938 (Pa. Cmwlth.) (Board as factfinder; credibility determinations)
- Stockdill v. Unemployment Compensation Board of Review, 368 A.2d 1341 (Pa. Cmwlth.) (Board may reject uncontradicted testimony as not credible)
- Kirkwood v. Unemployment Compensation Board of Review, 525 A.2d 841 (Pa. Cmwlth.) (scope of appellate review limited to legal error, constitutional violations, and substantial-evidence review)