Crawford v. Division of Employment Security
2012 Mo. LEXIS 158
| Mo. | 2012Background
- Crawford was fired in January 2009 and briefly admitted to a state mental facility; his physician advised applying for SSDI benefits.
- SSDI application was denied, then Crawford appealed; while appeal was pending, he sought employment and received state unemployment benefits beginning July 27, 2009 through March 20, 2010.
- SSA determined on March 2, 2010 that Crawford had been disabled since January 29, 2009, and found no significant number of jobs available for him.
- Crawford notified the Division of Employment Security of the SSA disability finding; on March 31, 2010 a deputy reconsidered eligibility and found Crawford ineligible from December 20, 2009 to March 20, 2010 and overpayment of $3,080.
- Appeals tribunal and the Missouri Labor and Industrial Relations Commission affirmed, though the commission recognized Crawford’s willingness to work, it held he was not able to work under Missouri law.
- The court reversed in part and affirmed in part, holding that the division could not collect certain overpayments under specific collection provisions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Supremacy Clause conflict with SSA benefits | Crawford argues retroactive ineligibility conflicts with SSA SSDI reduction rules. | Division contends SSA rules do not prevent retroactive state ineligibility determinations and do not violate Supremacy. | No Supremacy Clause violation; retroactive ineligibility permissible. |
| Good cause for redetermination | Division lacked good cause to reconsider eligibility after initial determination. | Section 288.070.5 permits reconsideration for good cause; issue was denied for lack of preservation. | Not preserved for appeal; cannot prevail on this argument. |
| Use of SSA disability finding under §288.215.2 | Division improperly relied on SSA finding to deny benefits. | Findings from independent proceedings are not binding but may be considered; no violation. | Permissible to consider SSA findings without violating §288.215.2. |
| Substantial and competent evidence of inability to work | Record lacks substantial evidence Crawford was unable to work. | There was substantial evidence including medical testimony and Crawford's own statements. | Evidence supports the commission's finding Crawford was unable to work; outcome affirmed on this point. |
| Recovery of overpayments – ripeness and methods | Questions about recovery methods are ripe for review and limited to misrepresentation vs. error. | Division may pursue various collection methods under §288.380; subsections 12, 13, and 14 harmonized. | Overpayment recovery limited by subsections 12 and 13; subsections 14 not a repeal; reversal in part on collection methods. |
Key Cases Cited
- Nash v. Florida Industrial Comm’n, 388 U.S. 335 (1967) (Supremacy Clause interpretation; distinguishable from case facts)
- Higgins v. Missouri Division of Employment Security, 167 S.W.3d 275 (Mo. App. 2005) (non-binding findings may be considered by the Commission)
- K & D Auto Body, Inc. v. Division of Employment Sec., 171 S.W.3d 100 (Mo. App. 2005) (non-binding independent proceedings not controlling but may inform)
- Roberts v. Labor and Indus. Relations Commission, 869 S.W.2d 139 (Mo. App. 1993) (commission authorized to reconsider eligibility under statute)
- St. Charles County v. Dir. of Revenue, 961 S.W.2d 44 (Mo. Banc 1998) (statutory interpretation; harmony of related provisions)
- In re Marriage of Lindhorst, 347 S.W.3d 474 (Mo. Banc 2011) (SSA disability rules; substantial gainful activity thresholds)