Chamberlain v. Unemployment Compensation Board of Review
114 A.3d 385
Pa.2015Background
- Charles H. Chamberlain was receiving unemployment benefits when he pled guilty to summary offenses and was sentenced to 60 days in a county house‑arrest (Keystone House Arrest Program) with permission to work and leave home for errands and shopping; failure to comply would result in 60 days in county prison.
- The Department issued a determination disqualifying Chamberlain under 43 P.S. § 802.6 (disqualification for being “incarcerated after a conviction”); Chamberlain appealed.
- The referee and the Unemployment Compensation Board of Review (UCBR) upheld the disqualification, construing “incarcerated” broadly to include house arrest.
- The Commonwealth Court reversed, holding that house arrest is not “incarceration” under Section 402.6 and that Chamberlain’s house arrest did not prevent him from satisfying the UC Law’s able‑and‑available requirements; the Court distinguished workers’ compensation precedents.
- The Pennsylvania Supreme Court affirmed the Commonwealth Court: it construed the undefined term “incarcerated” using its ordinary meaning, legislative history, remedial UC Law purpose, and precedent distinguishing institutional confinement from home confinement, and concluded Section 402.6 does not automatically bar claimants on house arrest.
Issues
| Issue | Chamberlain's Argument | UCBR's Argument | Held |
|---|---|---|---|
| Whether a claimant on house arrest is "incarcerated" under 43 P.S. § 802.6 | House arrest is not "incarceration"; ordinary meaning and Sentencing Code distinguish home confinement from institutional imprisonment | "Incarcerated after a conviction" should be read broadly (consistent with WC Act cases) to include house arrest and thus disqualify benefits | House arrest does not, as a matter of law, constitute "incarceration" under § 402.6; facts may still bar benefits under other UC Law provisions (e.g., able/available) |
| Whether workers’ compensation precedents interpreting “incarceration” control UC Law interpretation | Distinct statutory purposes; WC Act cases are not binding and are distinguishable on facts | WC Act cases are persuasive because disqualification language is similar and courts have interpreted "incarcerated" broadly | WC Act authorities are persuasive but not controlling; differences in statutory purpose and facts justify a different result here |
| Whether Section 402.6 was enacted to overturn Greer and to bar work‑release or home‑confinement claimants | Section 402.6 targeted prison work‑release situations; no clear evidence it was meant to reach home confinement | Legislative intent was to prevent incarcerated persons (including those on work release) from obtaining benefits | Legislative history shows concern about prison work‑release; absent clear language, Section 402.6 not read to encompass non‑institutional home confinement |
| Whether claimant’s ability to work should be dispositive when construing § 402.6 | Ability to work supports that house arrest is not the kind of "incarceration" intended to be disqualifying | Relying on able/available would nullify § 402.6’s purpose of per se disqualification | Court may consider ability/availability under other UC provisions; but § 402.6’s per se bar does not automatically apply to house arrest |
Key Cases Cited
- Commonwealth v. Kriston, 588 A.2d 898 (Pa. 1991) ("imprisonment" for sentencing credit does not include home electronic monitoring; institutional confinement differs qualitatively from staying at home)
- Henkels & McCoy, Inc. v. Workers’ Comp. Appeal Bd., 776 A.2d 951 (Pa. 2001) (criminal sentence involving involuntary commitment to psychiatric hospital constituted "incarceration" for WC Act disqualification)
- Brinker’s Int’l, Inc. v. Workers’ Comp. Appeal Bd., 721 A.2d 406 (Pa. Cmwlth. 1998) ("incarceration" under WC Act can include confinement with work release in a residential recovery/detention facility)
- Moore v. Workers’ Comp. Appeal Bd., 811 A.2d 631 (Pa. Cmwlth. 2002) (claimant on house arrest with work release was "incarcerated" for WC Act purposes)
- Greer v. Unemployment Comp. Bd. of Review, 392 A.2d 918 (Pa. Cmwlth. 1978) (pre‑§ 402.6: prisoner on work‑release could be eligible for UC benefits if able and available for work)
- Commonwealth v. Wegley, 829 A.2d 1148 (Pa. 2003) (home confinement can constitute "official detention" for escape statute despite differences from institutional imprisonment)