Ruffner v. Unemployment Compensation Board of Review
172 A.3d 91
| Pa. Commw. Ct. | 2017Background
- Ruffner worked as an auto mechanic for Seybert’s (Oct 2013–Aug 28, 2014) and reported his separation as a layoff when he filed for unemployment in October 2014 after a prior claim expired.
- He received maximum benefits (26 weeks) totaling $8,840; benefits ended April 11, 2015.
- In May 2016 the UC Service Center sent information requests, then issued three determinations finding Ruffner ineligible because he voluntarily quit, assessing an $8,840 fault overpayment, a $1,326 penalty, and a 28-week disqualification.
- At the Referee hearing the employer-owner (Seybert) testified Ruffner asked to be laid off and took other employment; Ruffner denied asking to be laid off or working for the alleged subsequent employer.
- The Referee credited employer testimony, found Ruffner not truthful on his application, and affirmed the determinations; the Board adopted the Referee’s decision without discussion.
- The Commonwealth Court reversed and remanded, holding the record was insufficient because of an unexplained 19‑month delay, employer’s delayed paperwork, and the Referee’s inadequate development of the record for this pro se claimant.
Issues
| Issue | Ruffner's Argument | Board/Employer's Argument | Held |
|---|---|---|---|
| Timeliness / delay in revoking benefits | The 19‑month delay prejudiced him; he had no timely notice to prepare witnesses | The Law imposes no time limit; employer filed for relief from charges and the UC Center may investigate later | Court: Delay unexplained; claimant raised delay below; issue not waived and requires remand to determine prejudice and jurisdictional effects |
| Credibility / voluntariness of separation | He was laid off for lack of work; he did not request layoff or take other employment | Employer: Ruffner asked to be laid off and worked elsewhere; thus benefits were improperly paid | Court: Referee resolved credibility for employer but failed to develop record on material facts (e.g., prior claim timing, replacement hire); remand required |
| Adequacy of hearing assistance to pro se claimant | Referee improperly curtailed Ruffner and failed to assist in developing facts, causing prejudice | Board: Referee’s credibility findings are binding if supported by substantial evidence | Court: Referee has duty to aid pro se claimant in developing facts; here the hearing transcript lacks needed factual development; remand required |
| Employer’s request for relief from charges / notice to claimant | Ruffner lacked notice that investigation was prompted by employer’s relief request and thus could not prepare | Board: Employer timely sought relief; separate procedures allow investigation affecting employer reserve account | Court: Board didn’t explain employer’s delayed questionnaire and didn’t notify Ruffner of the factual basis; remand for fact‑finding on timing and notice |
Key Cases Cited
- Bennett v. Unemployment Compensation Board of Review, 445 A.2d 258 (Pa. 1982) (referee must assist pro se claimant to develop necessary facts)
- Robinson v. Unemployment Compensation Board of Review, 431 A.2d 378 (Pa. 1981) (same principle regarding referee assistance)
- Department of Labor & Industry v. Unemployment Compensation Board of Review, 501 A.2d 297 (Pa. Cmwlth. 1985) (employer seeking relief from charges is seeking a tax exemption)
- First Nat’l Bank of Bath v. Unemployment Compensation Board of Review, 619 A.2d 801 (Pa. Cmwlth. 1992) (distinguishes eligibility determinations from employer requests for relief from charges)
- Roberts v. Unemployment Compensation Board of Review, 977 A.2d 12 (Pa. Cmwlth. 2009) (standards of appellate review for Board decisions)