Williams v. Ohio Department of Job & Family Services
129 Ohio St. 3d 332
| Ohio | 2011Background
- Williams was hired as a full-time residential social worker for Bridgeway, Inc.
- Promotion to Residential Services Program Manager required LISW licensure within 15 months.
- Appointment letter stated the LISW requirement and Williams signed acknowledging terms.
- Williams took LISW exam; health issues delayed a June 2008 attempt; she failed and could not retake within the window.
- Bridgeway terminated Williams for failing to obtain LISW within 15 months; she sought unemployment benefits.
- Appellate history culminated in the Supreme Court reversing the lower appellate ruling and upholding denial of unemployment benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is failure to obtain LISW within 15 months just cause for denial of unemployment benefits? | Williams argues the condition is not just cause. | Bridgeway contends failure to comply constitutes just cause. | Yes; failure to meet a license condition is just cause. |
| Was Williams afforded a reasonable opportunity to obtain the LISW license? | Williams asserts insufficient time or opportunity. | Bridgeway contends extension was available and reasonable. | Yes; reasonable opportunity was provided and disposition upheld. |
| Was the policy fairly applied to Williams compared to others? | Appellate court found inconsistent application. | Bridgeway had no requirement misapplied; Williams not similarly situated. | Policy fairly applied; Williams treated similarly to required standard. |
| Should the court review defer to the agency’s factual determinations? | N/A | N/A | Review limited to whether decision was unlawful, unreasonable, or against weight of evidence. |
Key Cases Cited
- Irvine v. Unemp. Comp. Bd. of Review, 19 Ohio St.3d 15 (Ohio 1985) (standard of review for unemployment decisions; factual findings defer to agency)
- Tzangas, Plakas & Mannos v. Ohio Bur. of Emp. Servs., 73 Ohio St.3d 694 (Ohio 1995) (fault essential to just-cause termination; includes unsuitability)
- Salzl v. Gibson Greeting Cards, Inc., 61 Ohio St.2d 35 (Ohio 1980) (act’s purpose to aid unemployed; no fault by employee)
- Leach v. Republic Steel Corp., 176 Ohio St. 221 (Ohio 1964) (humanitarian purpose; employee fault affects eligibility)
- Peyton v. Sun T.V. & Appliances, 44 Ohio App.2d 10 (Ohio App.2d 1975) (definition of just cause; reasonable expectations)