S.A. v. Review Board of the Indiana Department of Workforce Development
936 N.E.2d 336
Ind. Ct. App.2010Background
- S.A. was laid off from Daimler Chrysler in February 2008 but continued to receive some pay and unemployment benefits.
- Daimler Chrysler offered an early retirement package, which S.A. accepted on May 30, 2009, ending her employment.
- On June 10, 2009, S.A.’s unemployment benefits were suspended after a deputy determined she left without good cause in connection with the work.
- S.A. testified she accepted retirement due to dwindling benefits and anticipated inability to return to work, and to obtain insurance.
- The Board concluded S.A.’s acceptance of retirement fell within Indiana Code § 22-4-14-1(c), excluding her from benefits, and the ALJ’s finding was proper; the court affirmed.
- The court relied on York v. Review Bd. of the Indiana Employment Security Division to uphold the Board’s interpretation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether retirement after a layoff without other job options is good cause. | S.A. argues she remained unemployed and retirement was not a voluntary quit with no good cause. | The Board/State argues the retirement in connection with a layoff falls under § 22-4-14-1(c) and thus eligibility remains unchanged. | Yes; retirement in connection with a layoff falls under § 22-4-14-1(c), affirming ineligibility. |
| Whether the Board properly applied § 22-4-14-1(c) to exclude S.A. from benefits. | S.A. contends she was already unemployed and benefits should continue. | Board applied § 22-4-14-1(c) exclusion for those who elect to retire in connection with a layoff. | Correct; the exclusion applies and benefits were properly denied. |
Key Cases Cited
- York v. Review Bd. of Indiana Employment Security Division, 425 N.E.2d 707 (Ind.Ct.App.1981) (retirement inducement not proper factor; quitting reasons deemed personal)
- Kentucky Truck Sales, Inc. v. Review Bd. of the Ind. Dep't of Workforce Dev., 725 N.E.2d 523 (Ind.Ct.App.2000) (quit for personal, not job-related reasons; undue influence considered in good cause)
- McHugh v. Review Bd. of Ind. Dep't of Workforce Dev., 842 N.E.2d 436 (Ind.Ct.App.2006) (standard of review for Board findings; substantial evidence)
- McClain v. Review Bd. of Ind. Dep't. of Workforce Dev., 693 N.E.2d 1314 (Ind.1998) (inference as ultimate fact; reasonableness of Board inference)
- Indianapolis Osteopathic Hosp., Inc. v. Jones, 669 N.E.2d 431 (Ind.Ct.App.1996) (burden on claimant to prove good cause; job-related standard)