Sarah E. Cheney v. Unemployment Insurance Commission
144 A.3d 45
| Me. | 2016Background
- Sarah E. Cheney worked as a retail assistant manager at a convenience store, typically 40 hours/week on varied shifts including daytime and overnight; she returned from maternity leave in November 2013.
- After her return, disputes with the employer over schedule changes and a place to pump breast milk arose; Cheney gave two weeks’ notice and left.
- Bureau Deputies denied her unemployment benefits on two grounds: (1) voluntary leaving without good cause; (2) not able and available for full-time work under 26 M.R.S. § 1192(3).
- The Hearing Officer affirmed both denials; the Commission later set aside the voluntary-leave denial (finding lack of place to pump constituted good cause) but affirmed the denial that Cheney was not able and available for full-time work.
- The Commission found Cheney limited to weekday-evening and weekend availability due to childcare constraints and concluded she was not available for the daytime shifts customary in retail work and thus not available for full-time work.
- Cheney sought judicial review in Superior Court; the court affirmed the Commission, and Cheney appealed to the Supreme Judicial Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Cheney was "able and available for full-time work" under 26 M.R.S. § 1192(3) | Cheney contends she was willing/able to work full time and thus eligible for benefits despite childcare-driven shift limitations | Commission argues she was not available for customary daytime shifts in retail and thus not available for full-time work; rules require availability for all shifts customary to the occupation | Court held Commission correctly applied statute and rules; Cheney was not available for customary retail shifts and therefore not eligible |
| Whether statutory "parental obligation" exception covers Cheney's childcare-driven unavailability for daytime shifts | Cheney argues public policy supports eligibility where claimant is willing to work full time but constrained by childcare | Commission/State argues the statutory parental-obligation protection applies only to shifts where the majority of hours fall between midnight–5 a.m.; statute’s limited exception excludes other shift-time constraints | Court held the statute’s explicit midnight–5 a.m. parental-obligation exception implies exclusion of other shift protections; no statutory compulsion to expand protection |
| Whether Cheney’s ongoing childcare situation qualifies as "good cause" (entitling to prorated benefits) | Cheney argues childcare constraints are good cause for inability to accept certain shifts | Commission argues section 1192(13) limits "good cause" to emergencies, not ongoing childcare arrangements | Court held "good cause" includes child care emergencies only; Cheney’s ongoing situation does not trigger prorated-benefit protection |
| Whether the Commission’s interpretation violated public policy or required deference | Cheney claims the result is contrary to the remedial purpose of the Employment Security Law | State asserts statutory text and Commission rules control; policy changes are for the Legislature | Court held courts may not enlarge the statute; public-policy arguments should be addressed to the Legislature; deference to agency on matters within expertise upheld |
Key Cases Cited
- Ramelli v. Unemployment Ins. Comm’n, 130 A.3d 963 (Me. 2016) (standards for judicial review of Commission decisions)
- Sinclair Builders, Inc. v. Unemployment Ins. Comm’n, 73 A.3d 1061 (Me. 2013) (deference to agency within its expertise and substantial-evidence standard)
- Bischoff v. Bd. of Trustees, 661 A.2d 167 (Me. 1995) (party seeking to overturn agency decision bears burden to show contrary result compelled)
- Schwartz v. Unemployment Ins. Comm’n, 895 A.2d 965 (Me. 2006) (administrative-review principles)
- Musk v. Nelson, 647 A.2d 1198 (Me. 1994) (expressio unius inference in statutory interpretation)
- Blue Yonder, LLC v. State Tax Assessor, 17 A.3d 667 (Me. 2011) (avoid treating statutory language as superfluous)
- State v. Brown, 95 A.3d 82 (Me. 2014) (policy arguments are for the Legislature)