Mark Larsson, Relator v. Department of Employment and Economic Development
A16-33
| Minn. Ct. App. | Aug 15, 2016Background
- Mark Larsson, employed by Eaton Hydraulics, took an unpaid leave the week of June 21–27, 2015 and applied for unemployment benefits on June 22, 2015.
- DEED materials (pamphlet and handbook) explained applicants must request a weekly benefit payment and that each claimant has a single nonpayable week before payments begin.
- Larsson did not timely request payment for June 21–27. He later requested payment for a September week, which DEED treated as his nonpayable week, then denied his late June request as untimely.
- Larsson appealed; an unemployment-law judge (ULJ) found he lacked good cause for failing to timely file the continued-request form and denied benefits for the June week; reconsideration was denied.
- Larsson raised additional arguments: DEED materials were inconsistent, DEED should have reminded him within the three-week window, and ULJs have a conflict of interest. The ULJ and the court rejected these contentions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Larsson showed "good cause" for untimely filing a continued request for the week of June 21–27, 2015 | DEED materials were inconsistent and he did not timely request the week; failure excused | DEED materials and handbook warned claimants to request weekly payments; applicant must show objective "good cause" | Larsson failed to show good cause; untimely request is ineligible |
| Whether DEED had a duty to remind Larsson within the three-week acceptance window | DEED should have sent a reminder during the three-week period | No statutory duty to remind; claimant must act with due diligence | No error: DEED had no obligation to remind; claimant’s inaction not excused |
| Whether the objective "reasonable person" standard applies to good-cause inquiry | Larsson argued only his personal diligence matters | Statute uses an objective reasonable-person standard for good cause | Court applied objective standard and found no good cause |
| Whether ULJs have a disqualifying conflict of interest | Larsson asserted ULJs (DEED employees) are conflicted and biased | Presumption of impartiality; no evidence of actual bias; ULJs’ pay is not funded from unemployment trust | No merit: presumption of impartiality stands; no evidence of bias |
Key Cases Cited
- Stagg v. Vintage Place Inc., 796 N.W.2d 312 (Minn. 2011) (appellate review of ULJ factual findings viewed in light most favorable to decision)
- Hayes v. K-Mart Corp., 665 N.W.2d 550 (Minn. App. 2003) (whether claimant is disqualified from benefits is a question of law reviewed de novo)
- Werner v. Med. Prof’ls LLC, 782 N.W.2d 840 (Minn. App. 2010) (objective standard applies to certain good-reason inquiries)
- Irvine v. St. John’s Lutheran Church of Mound, 779 N.W.2d 101 (Minn. App. 2010) (no equitable or common-law entitlement to unemployment benefits)
- Schweiker v. McClure, 456 U.S. 188 (1982) (hearing officers are presumptively unbiased; burden on party alleging bias)