Aiden J. Stratton a/k/a Aiden J. Carr v. Employment Appeal Board

CourtCourt of Appeals of Iowa
DecidedMarch 29, 2023
Docket22-0045
StatusPublished

This text of Aiden J. Stratton a/k/a Aiden J. Carr v. Employment Appeal Board (Aiden J. Stratton a/k/a Aiden J. Carr v. Employment Appeal Board) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Aiden J. Stratton a/k/a Aiden J. Carr v. Employment Appeal Board, (iowactapp 2023).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 22-0045 Filed March 29, 2023

AIDEN J. STRATTON a/k/a AIDEN J. CARR, Petitioner-Appellant,

vs.

EMPLOYMENT APPEAL BOARD, Respondent-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Polk County, Samantha Gronewald,

Judge.

An individual appeals the denial of his application for Pandemic

Unemployment Assistance benefits. AFFIRMED.

Christopher Stewart of Gribble, Boles, Stewart & Witosky Law, Des Moines,

for appellant.

Rick Autry of the Employment Appeal Board, Des Moines, for appellee.

Considered by Ahlers, P.J., and Badding and Chicchelly, JJ. 2

AHLERS, Presiding Judge.

Aiden Stratton1 applied for Pandemic Unemployment Assistance (PUA)

benefits in May 2020. Iowa Workforce Development (IWD) denied his application

on August 20 and mailed notice of the decision to Stratton’s home address in Ames

on that date.2 The notice informed Stratton of his appeal rights and stated that any

appeal must be postmarked by August 31. Stratton’s mother emailed notice of

appeal on September 9.

Following an appeal hearing, an administrative law judge (ALJ) affirmed the

denial of Stratton’s PUA benefits because he failed to file a timely appeal. Stratton

appealed the ALJ’s decision to the Employment Appeal Board (EAB), which

affirmed the ALJ’s decision. Stratton then petitioned for judicial review. The district

court affirmed the EAB’s decision. Stratton appeals.

I. Overview of Appellate Review of Agency Action

This case involves judicial review of agency action, which is governed by

Iowa Code section 17A.19 (2021). When reviewing agency action pursuant to

section 17A.19, the district court acts in an appellate capacity. Lowe’s Home Ctrs.,

L.L.C. v. Iowa Dep’t of Revenue, 921 N.W.2d 38, 45 (Iowa 2018). On appeal, as

we are reviewing the district court acting in an appellate capacity, we apply the

same standards of section 17A.19(10) to determine if we reach the same result as

the district court. Id. If we reach the same decision, we affirm. Carreras v. Iowa

1 The appellant is referred to both as Aiden Stratton and Aiden Carr in the record. As Aiden Stratton is used more consistently throughout the record, we will use that name. 2 The address Stratton provided in his application was to his mother’s home in

Ames. Stratton was attending college in Fort Dodge at the time, but he still used the Ames address to receive his mail. 3

Dep’t of Transp., 977 N.W.2d 438, 444 (Iowa 2022). If not, we may grant relief

from agency action if we determine that substantial rights of the party seeking

judicial review have been prejudiced because the agency’s action falls within any

of the criteria listed in section 17A.19(10)(a) through (n). Id. The standard of

review we apply depends on the type of error asserted. Banilla Games, Inc. v.

Iowa Dep’t of Inspections and Appeals, 919 N.W.2d 6, 12 (Iowa 2018). We will

discuss the specific standard of review under each issue raised.

II. Issues Presented

Stratton raises three issues. He contends: (1) substantial evidence does

not support the finding that Stratton was notified of the decision to deny benefits;

(2) the decision to deny his appeal as untimely is inconsistent with the agency’s

rule and precedent; and (3) the decision to deny his appeal as untimely was

arbitrary and capricious. We address each issue in turn.

A. Substantial Evidence

1. Standard of Review

Stratton’s challenge to the sufficiency of the evidence supporting the agency

action implicates section 17A.19(10)(f). With review under paragraph (f), we defer

to the EAB’s fact findings if supported by substantial evidence. Sladek v. Emp.

Appeal Bd., 939 N.W.2d 632, 637 (Iowa 2020); Titan Tire Corp. v. Emp. Appeal

Bd., 641 N.W.2d 752, 755 (Iowa 2002) (“[I]f the agency’s findings of fact are

supported by substantial evidence, those findings are binding on judicial review.”

(alteration in original) (quoting PanDa Eng’g v. Eng’g & Land Surveying Examining

Bd., 621 N.W.2d 196, 198 (Iowa 2001))). Substantial evidence means evidence 4

that a reasonable person would accept as adequate to reach a conclusion, even if

a reviewing court might reach a different conclusion. Titan, 641 N.W.2d at 755.

2. Analysis

There is no dispute that Stratton did not submit his notice of appeal of the

IWD decision in the ten-day period required by Iowa Code section 96.6(2) (2020).3

Instead, Stratton challenges the adequacy of the decision notice. The crux of his

claim is that the written notice he received did not adequately inform him that a

denial decision had been made, so, in effect, he received no notice of the decision

and had no way of knowing that he needed to appeal. See Smith v. Iowa Emp.

Sec. Comm’n, 212 N.W.2d 471, 473 (Iowa 1973) (“[T]he notice provided for must

at least be one which is reasonably calculated to accomplish its purpose.”).

The EAB rejected Stratton’s contention and found the written notice

adequately informed Stratton of the denial of his claim. While the decision notice

could undoubtedly be improved and made clearer, there is still substantial

evidence supporting the EAB’s finding that the notice adequately advised Stratton

that a denial decision had been made and he needed to appeal if he was

dissatisfied with the decision. The evidence includes the document itself. The

document Stratton received included the statement “THIS IS AN OFFICIAL

DETERMINATION OF YOUR PANDEMIC UNEMPLOYMENT ASSISTANCE

ENTITLEMENT.” The document repeatedly described itself as “this decision” and

included a “decision date.” It also informed Stratton that “benefits are not payable

3 In pertinent part, section 96.6(2) reads: “Unless the claimant or other interested party, after notification or within ten calendar days after notification was mailed to the claimant’s last known address, files an appeal from the decision, the decision is final and benefits shall be paid or denied in accordance with the decision.” 5

to individuals whose employment is not covered under eligibility requirements.”

The document also spelled out appeal rights and deadlines. It explained “[t]his

decision becomes final unless an appeal is postmarked by August 31, 2020.” The

information in the decision notice reasonably conveyed the fact that a denial

decision had been made.

In addition to the information contained in the document, Stratton’s

testimony provides additional evidence supporting the EAB’s finding. Stratton

testified that he continued to receive mail at his mother’s residence in Ames rather

than where he was living in Fort Dodge. He also acknowledged he only checked

his mail “once every two weeks.” When asked why he didn’t file an appeal by

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