280 P.3d 442
Utah Ct. App.2012Background
- Peter A. Davis sought review of a Workforce Appeals Board decision denying unemployment benefits under Utah Code § 35A-4-405(1)(b).
- The Board concluded Davis voluntarily quit without good cause and denied benefits under the equity and good conscience standard.
- The Board based its voluntariness finding largely on employer witnesses, finding Davis did not contact his employer for several days while injured and then quit upon returning.
- Davis argued that his wife called the employer during his absence and that he attempted to seek a leave of absence on November 13, 2010, when he went to work with a ladder and left the premises.
- The Board rendered credibility determinations in favor of the employer, and the appellate court deferred to those credibility determinations.
- The court affirmed the Board’s rulings, declining to disturb the denial of benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Board's voluntariness finding is supported by substantial evidence | Davis contends the finding is not supported by the record | Board credited employer witnesses over Davis's account | Substantial evidence supports voluntariness |
| Whether denial under equity and good conscience was appropriate | Davis argues it would be contrary to equity and good conscience to deny benefits | Board reasonably concluded Davis's quit was not logical or practical | Board's equity/good conscience denial affirmed |
Key Cases Cited
- Salt Lake Donated Dental Servs., Inc. v. Department of Workforce Servs., 2011 UT App 7 (Utah Court of Appeals, 2011) (defers to Board credibility determinations when evidence is disputed)
- Wright v. Workforce Appeals Bd., 2011 UT App 137, 254 P.3d 767 (Utah Court of Appeals, 2011) (appellate deference to Board's resolution of conflicting evidence)
- Record v. Workforce Appeals Bd., 2011 UT App 340, 263 P.3d 1210 (Utah Court of Appeals, 2011) (definition of substantial evidence standard in agency review)