Young v. District of Columbia, Department of Employment Services, 268 A.3d 827

Ashley Young applied for unemployment benefits Nov 5, 2019 and was denied after DOES found she was discharged for misconduct.
Her denied claim was randomly selected for a Benefits Accuracy Measurement (BAM) quality-control audit; a BAM investigator mailed and emailed requests and deadlines to Young to complete a questionnaire.
Young did not receive the mailings (mail problems and missed junk email); she completed the BAM only in July 2020 when she reached the investigator by phone.
Unaware until later, Young had been issued a DOES “failure to report” determination in January 2020 that rendered her ineligible for prior weeks “until such time as contact is made.” She appealed in October 2020.
The ALJ found Young lacked good cause for the initial failure to report and denied back benefits, but treated her as eligible beginning the week she completed the BAM.
The court reversed and remanded with instructions to award Young benefits for the contested weeks, finding the ALJ’s denial arbitrary given ambiguous agency materials, lack of evidence justifying the deadlines, and the remedial purpose of the Unemployment Compensation Act.

Issue	Young's Argument	DOES's Argument	Held
Whether ALJ could deny back benefits for Young's failure to complete BAM	ALJ lacked authority; denial conflicts with humanitarian purpose and due process	Regulations permit conditioning benefits on completion of BAM	Reversed — ALJ’s denial arbitrary; remand to award benefits
Whether BAM completion was a "reasonably necessary" claimant filing requirement under 7 DCMR § 304.4(g)	BAM is a quality-control audit, not necessary to establish eligibility	BAM was reasonably necessary and falls within reporting rules (including § 316)	Court: regulations do not clearly authorize denying benefits here; ALJ failed to justify applying them
Whether DOES provided clear notice about consequences of failing to complete BAM	DOES materials warned BAM may not lead to corrective action and told claimants to pursue appeals—creating ambiguity	DOES points to language saying failure to complete BAM “may result” in delay/denial	Court: agency communications were inconsistent and ALJ did not reconcile them; ambiguity resolves for claimant given remedial statute
Standard of construction and burden on ALJ to explain deprivation of benefits	Unemployment statute is remedial and must be broadly/liberally construed for claimants; ALJ needed to give full, reasoned consideration	DOES emphasizes regulatory authority and claimant obligations	Court: ALJ did not provide adequate reasoning or evidentiary basis; must construe Act liberally for claimant

Rodriguez v. Filene's Basement Inc., 905 A.2d 177 (D.C. 2006) (standard for reviewing OAH factual findings and legal conclusions)
Gardner v. District of Columbia Dep’t of Emp. Servs., 736 A.2d 1012 (D.C. 1999) (definition of "substantial evidence")
Thomas v. District of Columbia Dep’t of Lab., 409 A.2d 164 (D.C. 1979) (courts should not affirm administrative determinations reflecting legal misconceptions)
Cruz v. District of Columbia Dep’t of Emp. Servs., 633 A.2d 66 (D.C. 1993) (Unemployment Compensation Act is remedial and should be liberally construed for benefit of workers)
Hamilton v. Hojeij Branded Food, Inc., 41 A.3d 464 (D.C. 2012) (requirement for full and reasoned consideration when denying benefits)
Ridge v. Police and Firefighters Ret. & Relief Bd., 511 A.2d 418 (D.C. 1986) (where statutory guidance is absent, denial of benefits is unsupported)