Stassen v. Lone Mountain Truck Leasing, LLC
814 N.W.2d 25
| Minn. Ct. App. | 2012Background
- Stassen, an accounts-payable collector, wrote an email that Lone Mountain treated as resignation after a customer transfer dispute.
- Lone Mountain accepted the email as resignation and later settled with Stassen for severance and nonwage damages.
- DEED mailed the eligibility determination to Lone Mountain’s former address, not its current one.
- Lone Mountain appealed the determination; ULJ initially dismissed as untimely, but later rulings found DEED’s mailing error affected timing.
- A de novo ULJ hearing found Stassen quit and therefore ineligible for unemployment benefits.
- The court affirmed, holding the appeal timely due to DEED’s mismailing and that Stassen quit; no fair-hearing error found.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of Lone Mountain’s appeal | Stassen argues untimely appeal barred ULJ jurisdiction | Lone Mountain contends proper notice to current address; timely if mailing occurred | Appeal timely; mailing to wrong address did not trigger untimely filing |
| Whether Stassen quit, not discharged | Stassen claims email was negotiation or not a quit | Email reasonably shows resignation and transition, not negotiation | Stassen quit; ineligible for benefits |
| Fair hearing respect | ULJ failed to assist and biased hearing | ULJ neutral, comments within proper limits | Hearing fair; no procedural defect warranting reversal |
| ULJ jurisdiction and statutory requirements | Challenge to ULJ authority over merits due to untimely appeal | DEED mismailing affected timing; ULJ had jurisdiction | ULJ had jurisdiction; decision upheld |
Key Cases Cited
- Kennedy v. Am. Paper Recycling Corp., 714 N.W.2d 738 (Minn. App. 2006) (untimely agency appeals require dismissal; review de novo for jurisdictional issues)
- Smith v. Masterson Pers., Inc., 483 N.W.2d 111 (Minn. App. 1992) (mailing date controls appeal period; address issues potential mismailing liability)
- Mgmt. Five, Inc. v. Comm’r of Jobs & Training, 485 N.W.2d 323 (Minn. App. 1992) (timeliness depends on proper mailing; misaddress can toll timing in limited circumstances)
- Johnson v. Metropolitan Medical Ctr., 395 N.W.2d 380 (Minn. App. 1986) (absolute appeal deadline; exceptions evaluated for notice failures)
- Midland Elec., Inc. v. Johnson, 372 N.W.2d 810 (Minn. App. 1985) (discharge vs. quit; factual findings defer to ULJ unless unsupported)
- Sykes v. Nw. Airlines, Inc., 789 N.W.2d 253 (Minn. App. 2010) (standard of review for ineligibility determinations; de novo review)