Tina Robinson v. Department of Labor and Economic Opportunity
369248
| Mich. Ct. App. | May 12, 2025Background
- Tina Robinson operated a home-based childcare service and applied for Pandemic Unemployment Assistance (PUA) in May 2020 following loss of work due to COVID-19.
- The Michigan Unemployment Insurance Agency approved her initial PUA claim, but later requested documentation of self-employment per updated federal law in 2021.
- Robinson submitted a payment log and two client letters as proof, but the Agency rejected these as insufficient and found her ineligible for continued benefits.
- Robinson appealed the denial; an Administrative Law Judge (ALJ) held a hearing and found Robinson's evidence and testimony credible, reversing the Agency's decision.
- The Agency was denied a rehearing, with both the Unemployment Insurance Appeals Commission (UIAC) and circuit court affirming Robinson's eligibility. The Agency appealed to the Court of Appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was documentation sufficient to prove Robinson's self-employment for PUA? | Robinson submitted sufficient evidence (payment log, letters). | Agency argued these documents were inadequate. | The court held the documentation and testimony were sufficient. |
| Did the ALJ correctly apply the law in deeming Robinson eligible? | ALJ properly relied on credible testimony and accepted documentation. | Agency contended the ALJ misapplied legal standards. | Court affirmed ALJ correctly applied the law. |
| Was the Agency solely empowered to determine sufficiency of documentation? | Discretion does not allow Agency to disregard credible evidence. | Agency asserted unilateral discretion to define adequacy. | Court found Agency's view of unilateral authority was erroneous. |
| Did the circuit court err in affirming the UIAC and ALJ decisions? | Circuit court followed law and standard of review. | Agency argued circuit court misapplied substantial evidence test. | The court held the circuit court’s review and affirmance were proper. |
Key Cases Cited
- Motycka v. General Motors Corp, 257 Mich App 578 (standard for substantial evidence in agency review)
- Lawrence v. Mich Unemployment Ins Agency, 320 Mich App 422 (standards for appellate review of agency decisions)
- Hodge v. US Sec Assoc Inc, 497 Mich 189 (court must affirm agency action if supported by the record)
- In re Sangster, 340 Mich App 60 (ALJ may rely on inferences from testimony and evidence)