Dahl v. State
2013 ND 25
| N.D. | 2013Background
- Claimants are bargaining unit employees at American Crystal Sugar’s North Dakota facilities represented by unions.
- ACS locked out the bargaining unit on August 1, 2011 and used replacement workers.
- Claimants applied for unemployment benefits; Job Service denied, citing N.D.C.C. § 52-06-02(4) as unemployment due to a labor dispute.
- Appeals were consolidated; the district court affirmed the denial.
- The sole legal question is the interpretation of § 52-06-02(4) and whether it applies to a lockout as opposed to an employee-initiated work stoppage.
- The Supreme Court reversed, holding that the plain language does not disqualify locked-out claimants and remanded for proceedings consistent with that interpretation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 52-06-02(4) disqualifies locked-out workers from benefits | Olson argues lockouts are not ‘a claimant’s work stoppage dispute’ | Job Service/ACS assert broad read including lockouts under the statute | § 52-06-02(4) does not disqualify lockouts |
| What is the proper statutory interpretation of ‘a claimant’s work stoppage dispute of any kind’ | Phrase applies only to employee-initiated stoppages | Phrase broadens to include any work stoppage caused by labor dispute | Phrase refers to employee-initiated stoppages; lockouts are not included |
| Is the statute ambiguous and requires legislative history | Plain language is clear; no ambiguity | Language ambiguous; legislative history should guide interpretation | Statutory language ultimately found unambiguous in light of context; legislative history reviewed but not controlling for the final interpretation |
| Does the history of the 1981 amendment support excluding lockouts | Amendment intended to distinguish claimant-initiated stoppages | Amendment intended to clarify scope but could be read to include lockouts | Legislative history supports excluding employer-initiated lockouts from disqualification |
| What is the proper remedy on appeal | District court’s denial should be reversed | Maintain denial | District court reversed; remanded for benefits proceedings consistent with interpretation |
Key Cases Cited
- Amoco Oil Co. v. Job Serv. North Dakota, 311 N.W.2d 558 (N.D. 1981) (lockouts context and stoppage of work issues longstanding)
- Resolution Trust Corp. v. Dickinson Econo-Storage, 474 N.W.2d 50 (N.D. 1991) (ejusdem generis application and interpretation of general terms with specific classes)
- Amoco Oil Co. v. Job Serv. North Dakota, 311 N.W.2d 558 (N.D. 1981) (interpretation of ‘stoppage of work’ and legislative amendment context)
- Holbach v. City of Minot, 2012 ND 117, 817 N.W.2d 340 (ND 2012) (statutory interpretation in context; plain language emphasis)