Clifford G. Menyweather, Relator v. Fedtech, Inc., Department of Employment and Economic Development
872 N.W.2d 543
| Minn. Ct. App. | 2015Background
- Clifford Menyweather was terminated by Fedtech on December 5, 2014, and signed a separation agreement that granted him $4,080 in lump-sum severance (equivalent to six weeks’ pay).
- Menyweather applied for unemployment benefits before receiving the severance; DEED initially paid him benefits and paid six weeks before learning of the severance agreement.
- DEED later redetermined that Menyweather was ineligible for benefits for the six weeks immediately following his termination and sought repayment of $1,880 overpayment.
- An unemployment-law judge (ULJ) found Menyweather knew on December 5 that he would receive severance, that the severance equaled six weeks’ regular pay, and ruled he was ineligible for benefits for the six-week period and owed repayment.
- Menyweather appealed, arguing he was eligible until he actually received the lump-sum payment on January 19, 2015.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether severance pay makes applicant temporarily ineligible for unemployment benefits and when the ineligibility period runs | Menyweather: ineligibility should begin when severance is actually paid (Jan 19, 2015) | DEED/ULJ: ineligibility begins immediately after the later of separation or date applicant first knew of payment (Dec 5, 2014) | Court held ineligibility runs from Dec 5, 2014 (six weeks immediately after termination); lump-sum receipt date is irrelevant |
| Whether Menyweather must repay benefits paid during the ineligibility period | Menyweather: he was eligible when payments were made, so no repayment required | DEED: payments were overpayments because of statutory ineligibility | Held that the payments made during the six-week ineligibility were overpayments and must be repaid |
Key Cases Cited
- Van de Werken v. Bell & Howell, LLC, 834 N.W.2d 220 (Minn. App. 2013) (held severance ineligibility tied to actual receipt; later effectively abrogated by 2014 statutory amendment)
- Irvine v. St. John’s Lutheran Church, 779 N.W.2d 101 (Minn. App. 2010) (discusses de novo review of statutory interpretation)
- Markel v. City of Circle Pines, 479 N.W.2d 382 (Minn. 1992) (supports standards for appellate review of legal questions)