Haugen v. Superior Development, Inc.
819 N.W.2d 715
Minn. Ct. App.2012Background
- Daniel Haugen began managing 16 rental houses for Superior Development, Inc. in August 2008, earning about 28 hours per week at $15/hour plus commission.
- Superior added a second assignment (an 18-unit building), increasing duties and raising Haugen’s hours toward 40 per week.
- In late April 2011, Superior reduced Haugen’s weekly hours from 40 to 24.
- Haugen applied for unemployment benefits based on the reduction and was approved for $365 per week on April 25, 2011.
- Haugen quit his employment on June 29, 2011, and subsequently applied for unemployment benefits again.
- The Department of Employment and Economic Development denied benefits, but a ULJ determined Haugen quit for a good reason caused by Superior; Superior appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May a corporation appear without counsel in the court of appeals? | Superior argued section 481.02 allows self-representation. | Haugen argued only attorneys may represent corporations in appeals. | Corporations must be represented by counsel in the court of appeals. |
| Does Minn. Stat. § 268.105. subd. 7 violate equal protection? | Section 268.105, subd. 7 discriminates by making employers pay costs not borne by unemployed. | Employers and unemployed are not similarly situated; the policy supports unemployment compensation. | Statute does not violate equal protection. |
| Did the ULJ err by finding Haugen quit for good reason caused by Superior? | Haugen quit due to a substantial reduction in hours/compensation caused by Superior. | Haugen’s reasons were not tied to the employer’s conduct or were not substantial. | Haugen had a good reason to quit caused by Superior. |
Key Cases Cited
- Nicollet Restoration, Inc. v. Turnham, 486 N.W.2d 753 (Minn. 1992) (corporations cannot be represented by non-attorneys; practice of law is reserved for the judiciary)
- Turnham, 486 N.W.2d 753 (Minn. 1992) (recognizes judiciary controls who may practice law before courts)
- State v. Ward, 580 N.W.2d 67 (Minn.App. 1998) (court of appeals bound by supreme court precedent)
- Wood v. Menard, Inc., 490 N.W.2d 441 (Minn.App. 1992) (substantial wage/hour reductions can constitute a good reason to quit)
- Ryks v. Nieuwsma Livestock Equip., 410 N.W.2d 380 (Minn.App. 1987) (employer-initiated adverse conditions may justify quitting)
- Danielson Mobil, Inc. v. Johnson, 394 N.W.2d 251 (Minn.App. 1986) (substantial wage reductions support good reason to quit)