J.M. Lyle v. UCBR, J.M. Lyle v. UCBR

Background

Claimant James Lyle, a Family Dollar store manager from Feb 1 to Apr 20, 2016, applied for unemployment benefits after he voluntarily quit on April 20, 2016.
Initial UC determination denied benefits under 43 P.S. §802(b) (voluntary quit). Claimant missed the first referee hearing and later testified at a Board remand that he did not receive notice due to mail problems.
Claimant complained his supervisor repeatedly threatened to fire him and submitted text-message evidence; he contacted a third‑party ethics hotline on April 15 and was told an investigator would contact him within 14 days.
A regional investigator contacted Claimant on April 20, 2016, and asked for supporting materials; Claimant quit that same day and did not wait for the investigation to conclude, citing fear of being fired.
The Board found Claimant established good cause for missing the initial hearing but concluded he voluntarily quit for a personality conflict and failed to make reasonable efforts to preserve employment; therefore he was ineligible for benefits under Section 402(b).
Claimant sought reconsideration based on after‑discovered evidence that Employer did not complete the investigation; the Board denied reconsideration, and the Commonwealth Court affirmed.

Issues

Issue	Lyle's Argument	Board/Employer's Argument	Held
Whether Claimant quit for a "necessitous and compelling" reason	Lyle: supervisor’s threats and Employer inaction created pressure justifying quitting	Board: threats existed but an investigation had begun and Lyle quit before it concluded; he failed to preserve employment	Held: No; quitting while an investigation was pending and without exhausting remedies is not necessitous and compelling
Whether the Board capriciously disregarded material evidence	Lyle: Board ignored threatening texts and evidence of unanswered corporate contacts	Board: Board credited the evidence of threats and considered all testimony; findings supported by substantial evidence	Held: No capricious disregard; findings affirmed
Whether denial of reconsideration to admit after‑discovered evidence (investigation later discontinued) was error	Lyle: after‑discovered evidence shows the investigation would have been futile	Board: evidence irrelevant to futility at the time he quit; reconsideration requires good cause/new evidence affecting original decision	Held: Denial proper; even if considered, irrelevant because it does not show futility before quitting
Whether Employer’s nonappearance prejudiced Lyle	Lyle: Employer’s absence prevented him from proving the investigation was futile	Board: in voluntary‑quit cases, claimant bears the burden; employer has no burden and Lyle could have subpoenaed witnesses	Held: No prejudice; Employer’s absence not fatal to the Board’s decision

Key Cases Cited

Wintermyer v. Workers’ Comp. Appeal Bd. (Marlowe), 812 A.2d 478 (Pa. 2002) (appellate review for capricious disregard of material evidence)
Solar Innovations, Inc. v. Unemployment Comp. Bd. of Rev., 38 A.3d 1051 (Pa. Cmwlth. 2012) (elements for necessitous and compelling reason)
Brunswick Hotel & Conference Ctr., LLC v. Unemployment Comp. Bd. of Rev., 906 A.2d 657 (Pa. Cmwlth. 2006) (reasonable effort to preserve employment requirement)
Earnest v. Unemployment Comp. Bd. of Rev., 30 A.3d 1249 (Pa. Cmwlth. 2011) (employer bears no burden in voluntary‑quit cases)
St. Barnabas, Inc. v. Unemployment Comp. Bd. of Rev., 525 A.2d 885 (Pa. Cmwlth. 1987) (resignation without giving employer opportunity to solve problem precludes benefits)
Martin v. Unemployment Comp. Bd. of Rev., 749 A.2d 541 (Pa. Cmwlth. 2000) (futility exception for reporting harassment)