348 So.3d 1022
Miss. Ct. App.2022Background:
- Patterson worked as a seamstress for Golden Manufacturing from Jan. 3, 2012, until her employment ended May 15, 2020, after she did not return when the employer re-opened following a two‑week COVID‑19 shutdown.
- Patterson did not return because she feared contracting COVID‑19 given obesity and hypertension and because the employer allegedly did not mandate masks or six‑foot distancing.
- Patterson filed for unemployment; an MDES adjudicator initially awarded benefits, but Golden Manufacturing appealed and an ALJ reversed, finding Patterson voluntarily left without good cause.
- At the ALJ hearing Patterson submitted a physician’s MDES form that indicated the doctor had not advised her to leave work and had released her to return; Patterson nonetheless asserted the workplace was unsafe.
- The MDES Board of Review affirmed the ALJ’s decision (noting possible Pandemic Unemployment Assistance eligibility), the Prentiss County Circuit Court affirmed, and Patterson appealed to this Court.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Patterson had "good cause" under §71‑5‑513(A)(1) for leaving work due to COVID‑19 risk | Patterson: high‑risk medical conditions + employer refused to guarantee masks/distancing = good cause to not return | Employer/MDES: Patterson exceeded allowed absences, abandoned job, and medical form shows doctor did not advise leave | Court: Affirmed — substantial evidence Patterson voluntarily left without good cause; benefits denied |
| Whether the Board’s decision should be set aside as unsupported/arbitrary | Patterson: Board erred and decision is arbitrary given pandemic context | MDES: Board findings are factual and supported by record; agency deference applies | Court: Affirmed — agency findings supported by substantial evidence and not arbitrary or capricious |
Key Cases Cited
- Allen v. Mississippi Employment Security Commission, 639 So. 2d 904 (Miss. 1994) (courts must not reweigh facts or substitute their judgment for the agency)
- Good Samaritan Personal Services v. Mississippi Dep’t of Emp. Sec., 996 So. 2d 809 (Miss. Ct. App. 2008) (standards for disturbing agency conclusions)
- Jackson County Bd. of Supervisors v. Mississippi Employment Security Commission, 129 So. 3d 178 (Miss. 2013) (presumption in favor of agency decisions; burden on claimant to rebut)
- City of Grenada v. Mississippi Dep’t of Emp. Sec., 320 So. 3d 523 (Miss. 2021) (purpose of employment‑security law is to protect workers not at fault for unemployment)
- Hereford v. MDES, 306 So. 3d 863 (Miss. Ct. App. 2020) ("good cause" requires an ordinary prudent employee would feel compelled to quit and that alternatives were explored)