Jackson County Board of Supervisors v. Mississippi Employment Security Commission
129 So. 3d 178
Miss.2013Background
- Seaman worked for Jackson County Community Center and as carnival coordinator for the Jackson County Fair Association and submitted time sheets showing 30–40 hours weekly for fair work.
- Jackson County terminated Seaman, contending she falsified time sheets, constituting misconduct under Miss. Code Ann. § 71-5-513(A)(1)(b).
- A private investigation was inconclusive; human resources director Krebs testified Seaman was fired for falsifying time sheets; Russell denied signing, while Seaman claimed Russell directed her to sign.
- An administrative-law judge found no misconduct by clear and convincing substantial evidence; the Board of Review affirmed.
- The Court of Appeals reversed, holding the employer proved misconduct; this Court granted certiorari and held the Court of Appeals erred by reweighing evidence; the Circuit Court’s judgment was reinstated and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the MESC decision supported by substantial evidence? | Seaman argues substantial evidence shows she did not falsify time sheets. | Jackson County contends the time sheets and statements establish misconduct. | No; the Supreme Court reversed the Court of Appeals and affirmed the MESC’s substantial-evidence finding. |
| Did the Court of Appeals improperly reevaluate the evidence? | Seaman asserts the appellate court reweighed credibility and substituted its judgment. | Jackson County argues the Court of Appeals correctly reviewed the record. | Yes; reweighing was improper; court reinstated the agency’s decision. |
| What is the proper standard of review for MESC findings on misconduct? | Seaman contends the Court should defer to the MESC where supported by substantial evidence. | Jackson County contends the Board’s findings must be reviewed for substantial evidence. | Substantial-evidence standard applies; if there is such evidence, the agency’s credibility determinations stand. |
Key Cases Cited
- Wheeler v. Arriola, 408 So.2d 1381 (Miss. 1982) (defines misconduct; distinguishes mere inefficiency from disqualifying conduct)
- Percy v. Miss. Employment Sec. Comm’n, 641 So.2d 1172 (Miss. 1994) (falsification of time cards constitutes misconduct)
- Foster v. Miss. Employment Sec. Comm’n, 632 So.2d 926 (Miss. 1994) (establishes burden of proof for misconduct)
- Shannon Engineering & Const., Inc. v. Miss. Employment Sec. Comm’n, 549 So.2d 446 (Miss. 1989) (substantial evidence standard and review framework)
- Mississippi v. Harris, 672 So.2d 739 (Miss. 1996) (rebuttable presumption in favor of agency findings; review on law)
- Hinds County v. Miss. Comm’n on Envtl. Quality, 61 So.3d 877 (Miss. 2011) (definition of substantial evidence; defer to agency credibility determinations)
- Merchants Truck Line, Inc., 598 So.2d 778 (Miss. 1992) (agency credibility and weight of evidence; deference to agency fact-finding)
- Hooks v. George County, 748 So.2d 678 (Miss. 1999) (substantial evidence standard; reviewing court limits on reweighing)
- Knight v. Public Employees’ Ret. Sys., 108 So.3d 912 (Miss. 2012) (limits on appellate reweighing of witness credibility)
- Miss. Employment Sec. Comm’n v. Harris, 672 So.2d 739 (Miss. 1996) (reaffirmation of agency-first approach and substantial-evidence review)