Engel Manufacturing Company, Inc. v. Review Board of the Indiana Department of Workforce Development and D.R. (mem. dec.), 93A02-1607-EX-1596

Background

D.R. worked as a lathe operator for Engel Manufacturing from 2008 until February 2016; his duties included preparing aerospace parts for shipment.
Employer Stephen Engel frequently yelled at and verbally abused D.R. and other employees; incidents included public ridicule over work performance and a November 2014 episode after which D.R. briefly stopped coming to work but returned after an apology.
In February 2016, after repeated public beratings (including yelling about an unfinished job and ridiculing D.R. over a blueprint), D.R. told Mr. Engel he could not work in the same building; Engel treated this as a resignation but then asked D.R. to stay on part-time; continued abuse led D.R. to stop coming to work and apply for unemployment.
A claims deputy found D.R. voluntarily left for good cause and was eligible for benefits; an ALJ and then the Review Board affirmed that decision, adopting the ALJ’s findings.
Engel appealed to the Court of Appeals arguing insufficient evidence supported the Review Board’s finding that D.R. quit for good cause related to the work.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether D.R. voluntarily left without good cause under Ind. Code § 22-4-15-1(a)	D.R.: repeated, public verbal abuse by employer made work environment intolerable and would compel a reasonably prudent person to quit	Engel: reprimands were not so unreasonable; cites cases where single or nonsevere incidents were not good cause; points to lack of medical proof of harm	Held: Review Board’s finding affirmed — substantial evidence showed repeated harassment that would compel a reasonably prudent person to quit, so D.R. left for good cause

Key Cases Cited

P.K.E. v. Review Bd. of Ind. Dep’t of Workforce Dev., 942 N.E.2d 125 (Ind. Ct. App. 2011) (standard for Review Board factual review and agency discretion)
Ind. State Univ. v. LaFief, 888 N.E.2d 184 (Ind. 2008) (voluntary leaving without good cause disqualifies claimant)
P&P Home Servs., LLC v. Review Bd. of Ind. Dep’t of Workforce Dev., 53 N.E.3d 1232 (Ind. Ct. App. 2016) (claimant entitlement determined on available information without proof burden)
Chrysler Group, LLC v. Review Bd. of the Indiana Dep’t of Workforce Dev., 960 N.E.2d 118 (Ind. 2012) (framework for appellate review of Review Board findings: basic facts, ultimate facts, conclusions of law)
K.S. v. Review Bd. of Ind. Dep’t of Workforce Dev., 33 N.E.3d 1195 (Ind. Ct. App. 2015) (Review Board factual findings are binding absent limited exceptions)
Y.G. v. Review Bd. of Ind. Dep’t of Workforce Dev., 936 N.E.2d 312 (Ind. Ct. App. 2010) (medical substantiation required when claim rests on physical disability grounds)
Kentucky Truck Sales, Inc. v. Review Bd. of Ind. Dep’t of Workforce Dev., 725 N.E.2d 523 (Ind. Ct. App. 2000) (reprimand may be insufficient as good cause depending on context and employee history)
Marozsan v. Review Bd. of Ind. Employment Sec. Div., 429 N.E.2d 986 (Ind. Ct. App. 1982) (employee must show provocation so strong a reasonably prudent person would leave)
Brown v. Ind. Dep’t of Workforce Dev., 919 N.E.2d 1147 (Ind. Ct. App. 2009) (two-step test: would a reasonably prudent person be compelled to quit and are reasons objectively job-related)
Richey v. Review Bd., 480 N.E.2d 968 (Ind. Ct. App. 1985) (single remote incident producing subjective discomfort not good cause)
Geckler v. Review Bd., 193 N.E.2d 357 (Ind. 1963) (single indelicate reprimand insufficient where employees characterized as hypersensitive)