Stagg v. Vintage Place Inc.
796 N.W.2d 312
| Minn. | 2011Background
- Stagg was discharged January 29, 2009 from Vintage Place for absenteeism and tardiness.
- Vintage Place had a five-step progressive discipline policy for attendance, culminating in discharge for the fifth unexcused absence.
- Stagg incurred multiple attendance/tardiness incidents beginning November 2008, including two late arrivals and unexplained absences.
- Stagg received oral and written warnings and suspensions prior to termination.
- ULJ found employment misconduct; court of appeals reversed, prompting review by the supreme court.
- Court held that misconduct requires a serious violation of the employer’s reasonable standards, independent of whether the employer followed its disciplinary procedures.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is failure to follow progressive discipline fatal to misconduct findings? | Stagg | Vintage Place | No; focus is on conduct, not employer’s process. |
| Did Stagg’s absenteeism/tardiness constitute employment misconduct under Minn. Stat. 268.095.6(a)? | Stagg’s conduct did not reach misconduct level due to skipped step | Stagg clearly violated standards | Yes; Stagg’s conduct satisfied the statute’s serious-violation standard. |
Key Cases Cited
- Hoemberg v. Watco Publishers, Inc., 343 N.W.2d 676 (Minn.App.1984) (reversed benefits denial when handbook discipline mismatched with policy)
- Jenkins v. Am. Express Fin. Corp., 721 N.W.2d 286 (Minn.2006) (mixed question; review of ULJ findings; standards for review)
- Schmidgall v. FilmTec Corp., 644 N.W.2d 801 (Minn.2002) (misconduct is a legal question; narrow statutory interpretation)
- Valenty v. Med. Concepts Dev., Inc., 503 N.W.2d 131 (Minn.1993) (remedial unemployment policy; unemployment paid to those unemployed through no fault)
- Feges v. Perkins Rests., Inc., 483 N.W.2d 701 (Minn.1992) (contract/ handbook interpretation separate from benefit eligibility)