Chrysler Group, LLC v. Review Board of the Indiana Department of Workforce Development
960 N.E.2d 118
Ind.2012Background
- Chrysler offered an Enhanced Voluntary Termination of Employment Program (EVTEP) during the 2008-09 downturn to Kokomo employees.
- EVTEP provided cash payments (100,000 then 75,000) and six months of health coverage in exchange for voluntary termination, with recall rights eliminated.
- Employees who accepted EVTEP were either on lay-off or actively employed; Chrysler ceased subpay and health coverage for some after six months.
- Indiana's DWD initially denied unemployment benefits to EVTEP participants, then the Review Board awarded benefits under Indiana Code § 22-4-14-1(c) (Supp. 2011).
- Court of Appeals reversed the Board; Indiana Supreme Court granted transfer and affirmed the Board’s interpretation and application of the statute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| How § 22-4-14-1(c) should be interpreted | Chrysler argues no inference of employer intent; requires explicit declaration. | Board interpreted § 22-4-14-1(c) to permit inferred intent from conduct. | Statute allows inferred employer intent; explicit declaration not required. |
| Whether § 22-4-14-1(c) trumps § 22-4-15-1(a) | § 22-4-14-1(c) cannot override general disqualification rules without explicit intent. | § 22-4-14-1(c) prevails over § 22-4-15-1(a). | Section 22-4-14-1(c) prevails over the disqualification provision. |
| Whether EVTEP was intended to avert or lessen the layoff effect | Chrysler maintains lack of evidence of intent to avert a layoff. | Board reasonably inferred intent to avert/lessen layoff from conduct and context. | There is substantial evidence that EVTEP was intended to avert or lessen the layoff effect. |
Key Cases Cited
- LTV Steel Co. v. Griffin, 730 N.E.2d 1251 (Ind.2000) (agency statutory interpretation given deference)
- McClain v. Review Bd. of Ind. Dep't of Workforce Dev., 693 N.E.2d 1314 (Ind.1998) (three-tier factual-conclusion framework; substantial evidence standard)
- Geckler v. Rev. Bd. of Indiana Emp't Sec. Div., 244 Ind. 473, 193 N.E.2d 357 (Ind.1963) (good cause must be objective and employment-related)
- Trelleborg YSH, Inc. v. Bd. of Ind. Dep't of Workforce Dev., 798 N.E.2d 484 (Ind.Ct. App.2003) (inverse seniority clause preempts disqualification; clarity on intent)
- Quakenbush v. Review Bd. of Ind. Dept. of Workforce Dev., 891 N.E.2d 1051 (Ind.Ct. App.2008) (liberal construction to aid unemployed)
- Bailey v. Review Bd. of Ind. Dept. of Workforce Dev., 668 N.E.2d 1293 (Ind.Ct. App.1996) (unemployment act humanitarian purposes )
- Holmes v. Review Bd. of Ind. Emp't Sec. Div., 451 N.E.2d 83 (Ind.Ct. App.1983) (liberal construction of unemployment benefits)