Lockyear v. Department of Workforce Services
262 P.3d 451
Utah Ct. App.2011Background
- Lockyear seeks review of the May 4, 2011 Workforce Board of Appeals decision.
- The Department discharged Lockyear for good cause on January 13, 2011 and set a deadline to appeal by January 31, 2011.
- Lockyear received the decision but filed his appeal on February 8, 2011.
- ALJ found the appeal untimely and lacking good cause under Utah Code 35A-4-406(3).
- Lockyear appealed to the Board, which affirmed the ALJ.
- Court reviews Board decisions for reasonableness and substantial evidence, not reweighing evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lockyear showed good cause for untimely filing. | Lockyear contends delays due to computer help and family member illness were beyond control. | Department argues there was no good cause and options to file (mail, hand-delivery, fax) were available. | No good cause; Board affirmed for lack of jurisdiction. |
Key Cases Cited
- Autoliv ASP, Inc. v. Workforce Appeals Bd., 8 P.3d 1033 (Utah Ct.App. 2000) (untimely appeal jurisdiction when no good cause)
- Nelson v. Department of Emp't Sec., 801 P.2d 158 (Utah Ct.App. 1990) (review for reasonableness and substantial evidence)
- Bradley v. Payson City Corp., 70 P.3d 47 (Utah Ct.App. 2003) (standard of review—not reweighing evidence)