Wright v. Ohio Dept. of Job & Family Servs.
2013 Ohio 2260
Ohio Ct. App.2013Background
- Wright quit Schneider National Carriers on August 20, 2010 while mid-delivery and demanded a local route.
- ODJFS initially granted unemployment benefits, then reversed, finding he quit without just cause.
- Wright appealed; case transferred to UCRC with two dockets (C2010-012991 and C2010-014088); hearing held February 10, 2011.
- UCRC affirmed the redetermination that Wright quit without just cause.
- Wright sought judicial review; trial court affirmed the UCRC decision; this court also affirms; issues consolidated.
- Wright argues lack of just cause due to supposed local route availability and failure to call a subpoenaed witness; Schneider argues no local route promises were made and medical issues did not prevent regional work.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether UCRC decision was against the manifest weight of the evidence. | Wright contends he was hired for a local route and the employer knew he needed home time for medical needs. | Schneider contends no local route promises were made and Wright elected to quit without pursuing available opportunities. | No; UCRC's finding that Wright was hired for a regional route was supported by evidence and not against the manifest weight. |
| Whether UCRC decision was unlawful or unreasonable. | Wright argues medical conditions required local work and due process was impaired by a subpoena issue. | UCRC properly weighed medical evidence and Wright failed to establish pre-termination notice or availability of suitable work. | No; the decision was lawful and reasonable; Wright failed to show pre-termination notice of suitable local work or proper due process errors. |
Key Cases Cited
- Lang v. Dir., Ohio Dept. of Job & Family Servs., 134 Ohio St.3d 296 (2012-Ohio-5366) (standard of review for UCRC decisions; deferential review to record)
- Irvine v. Unemp. Comp. Bd. of Review, 19 Ohio St.3d 15 (1985) (burden on employee to prove entitlement; medical conditions must be considered in evaluating just cause)
- Eastley v. Volkman, 132 Ohio St.3d 328 (2012-Ohio-2179) (manifest-weight standard; credibility and weighing of evidence limited on appeal)