Tex. Workforce Comm'n v. Wichita Cnty.
548 S.W.3d 489
| Tex. | 2018Background
- Julia White, a Wichita County employee, took FMLA leave for anxiety/depression beginning August 16, 2011; her paid leave exhausted August 19 and she continued on unpaid leave.
- While on unpaid FMLA leave, White filed for unemployment benefits on October 2; the Texas Workforce Commission found she was "unemployed" and could be paid benefits if she met other requirements.
- Wichita County appealed, arguing White remained an employee (no separation) and thus was ineligible; administrative tribunals upheld the Commission's decision and said the County would be billed if benefits were paid.
- The trial court granted summary judgment for the County, reversing the Commission; the court of appeals affirmed, calling it "absurd" to allow concurrent FMLA protection and unemployment.
- The Texas Supreme Court granted review to decide whether the Unemployment Act defines someone on unpaid FMLA leave as "unemployed," and whether that status alone entitles them to benefits.
Issues
| Issue | Plaintiff's Argument (Commission/White) | Defendant's Argument (County) | Held |
|---|---|---|---|
| Whether the Unemployment Act defines an individual on unpaid FMLA leave as "unemployed" | Statute's definition of "unemployed" (no services for wages over threshold) includes those on unpaid leave | "Unemployed" in ordinary meaning requires severance of employment relationship | Held: Statute unambiguously defines "unemployed" by wages/hours; FMLA unpaid leave can satisfy that definition |
| Whether the court may override clear statutory text as "absurd" to avoid concurrent FMLA protection and unemployment eligibility | Commission: Court should apply text and leave eligibility screening to benefit-eligibility rules | County: Allowing both protections is absurd because statutory schemes serve different populations | Held: Not absurd for Legislature to define "unemployed" broadly; eligibility (ability/availability/actively seeking) remains to be evaluated later |
| Whether section 207.045 (medical-leave exception to disqualification) is rendered meaningless if unpaid FMLA leave qualifies as "unemployed" | Commission: Section 207.045 complements, does not conflict; medical leave avoids disqualification | County: Authorizes circumventing section 207.045 by claiming FMLA leave instead of quitting | Held: No conflict; section 207.045 still prevents disqualification when work was left for medically verified illness |
| Whether a reimbursing employer (County) may be billed for benefits paid to an employee on medical leave | Commission: Reimbursing employers are generally liable per statute | County: Trial-court argument that certain charges shouldn't apply to reimbursements | Held: Statute displaces the County's challenge; reimbursing-employer rules apply and County did not preserve alternative arguments on appeal |
Key Cases Cited
- TGS-NOPEC Geophysical Co. v. Combs, 340 S.W.3d 432 (Tex. 2011) (statutory terms receive ordinary meaning unless statute provides otherwise)
- Combs v. Health Care Servs. Corp., 401 S.W.3d 623 (Tex. 2013) (absurdity doctrine is narrow and reserved for patently nonsensical results)
- Collingsworth Gen. Hosp. v. Hunnicutt, 988 S.W.2d 706 (Tex. 1998) (Unemployment Act purpose: compensate workers unemployed through no fault of their own)
- Mercer v. Ross, 701 S.W.2d 830 (Tex. 1986) (judicial review of Commission decisions governed by substantial-evidence rule)
- Texas Employment Comm'n v. Southside Indep. Sch. Dist., 775 S.W.2d 733 (Tex. App.—San Antonio 1989) (prior case addressing whether Act defined "unemployed" before 1995 amendment)