Arizona Department of Economic Security v. Magma Copper Co.

609 P.2d 1089, 125 Ariz. 389, 1980 Ariz. App. LEXIS 423
CourtCourt of Appeals of Arizona
DecidedApril 1, 1980
Docket1 CA-CIV 4059
StatusPublished
Cited by12 cases

This text of 609 P.2d 1089 (Arizona Department of Economic Security v. Magma Copper Co.) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arizona Department of Economic Security v. Magma Copper Co., 609 P.2d 1089, 125 Ariz. 389, 1980 Ariz. App. LEXIS 423 (Ark. Ct. App. 1980).

Opinions

OPINION

DONOFRIO, Acting Presiding Judge.

This is an appeal by the Arizona Department of Economic Security (Department) from a Maricopa County Superior Court judgment in favor of the Magma Copper Company (Magma). The superior court reversed a decision of the Department that held Magma discharged the claimant/worker for a reason not warranting disqualification from unemployment insurance benefits.

The main issue of this appeal is whether the superior court may properly reverse an unemployment insurance benefit decision of the Department by making a finding that a “record of unexcused absences is misconduct” within the meaning of A.R.S. § 23-775(2), when the employer has presented no evidence as to the facts surrounding the absences other than that the employer considered them to be unexcused in accordance with its company rules.

A claimant has the burden of proving that he is eligible for unemployment benefits, Employment Security Commission v. Doughty, 13 Ariz.App. 494, 478 P.2d 109 (1970), however, when the employer is claiming disqualification of the claimant from benefits because of misconduct the Department has adopted a rule which places the burden upon the employer to prove this assertion.1

Mario Martinez, claimant, filed a claim for unemployment insurance benefits with the Department effective March 7, 1976, claiming he was discharged from employment on March 6, 1976. The employer, Magma, protested the payment on the basis that claimant was disqualified from receiving benefits. On April 19,1976, a deputy of the Department determined that the claimant was entitled to benefits because he was discharged for a reason not warranting disqualification. The employer’s account was accordingly charged for the benefits paid to claimant. Magma appealed to the Director and a hearing was held before the Department’s appeals tribunal.

The tribunal rendered its decision affirming the determination of the deputy making the following findings and conclusions:

FINDINGS OF FACT:
The claimant was employed as a chute-blaster for the X Copper Company, San Manuel, Arizona, for approximately seven months until March 6,1976, at which time [391]*391he was discharged. The claimant’s discharge resulted from an unexcused absence after having received prior warnings. The claimant had been experiencing pains in his back. He had previously gone to a medical doctor for this condition, however, had not realized any relief. On March 6, the claimant’s back bothered him so much he was unable to take his boots off. He attempted to contact a chiropractor, however, could not reach anyone on Sunday, March 7. He called his employer on March 7 and informed him of his condition. On March 8, he went to a local chiropractic health clinic where he was attended to by a Doctor of Chiropractics. The employer’s contention is that the claimant presented an invalid medical release for his absence of March 8, 1976, in that he was not attended by a licensed physician as described under their rules. The claimant had not read the personnel instruction booklet and was not aware that chiropractors would not be considered as acceptable licensed doctors. Chiropractors have to be licensed by the State of Arizona in order to operate in this state.
REASONING AND CONCLUSIONS OF LAW:
The employer has contested a determination that the claimant was discharged for a reason not warranting disqualification. The issues raised must be decided under Section 23-775, Paragraph 2, and Section 23-727 of the Employment Security Law of Arizona (Copy Attached).
The Department’s Benefit Policy Rules provide in pertinent part:
Absences due to causes beyond the control of the claimant are generally regarded as falling short of misconduct; however failure to give notice of such absence may constitute misconduct. The absence itself, based on illness, accident, unavoidable delay in transportation, urgent domestic responsibilities and the like, is not considered misconduct. .
When a claimant gives no excuse for his absence or is absent for an obviously capricious reason, and is discharged for such absence, his discharge is held to be for misconduct connected with his work.
The Tribunal finds the claimant credible and believes that what he said occurred did, in fact, happen. We feel that the claimant sincerely believes he was giving his employer proper notice of his absence and supplying the employer with a proper substantiating medical release. The Tribunal does not feel that evidence has been established that the claimant was discharged for work-connected misconduct. We, therefore, find that his discharge does not warrant disqualification.

The decision of the Department was made final and Magma took judicial review to the superior court under A.R.S. § 12-901, et seq. A certified copy of the record of the proceedings before the Department was transmitted to the trial court. The parties submitted the matter to the trial judge on the record.

The superior court’s first ruling held that the decision of the Department was legally unsupportable because claimant was discharged for his fifth unexcused absence within a six-month period, and because the last absence did not have a proper medical release from a licensed physician. The superior court vacated its initial judgment and upon reconsideration held that claimant’s record of the unexcused absences was misconduct although the last absence may not have been.2

We must first determine whether the facts as found by the Department constitute misconduct within the meaning of A.R.S. § 23-775(2). The parties have not taken issue with the findings of fact and therefore our focus is limited to whether [392]*392the superior court was correct in its interpretation of the law. In this situation we are free to draw our own legal conclusions in determining whether the Department or the superior court erred in its interpretation of the law. Eshelman v. Blubaum, 114 Ariz. 376, 560 P.2d 1283 (App.1977). We hold that under the facts as determined by the Department, claimant’s actions did not amount to misconduct as a matter of law.

Magma takes the position that claimant had five unexcused absences within a six-month period and that pursuant to the rules of the company3 he was discharged after the fifth of these. Magma argues that the statute [§ 23-775(2)] speaks of negligent or wilful misconduct, and that because of claimant’s own negligent violation of the company’s rules he was terminated from employment. That while claimant’s last absence may not have been a major infraction, five unexcused absences together were a total disregard of the employer’s interest and constituted misconduct.

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Arizona Department of Economic Security v. Magma Copper Co.
609 P.2d 1089 (Court of Appeals of Arizona, 1980)

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Bluebook (online)
609 P.2d 1089, 125 Ariz. 389, 1980 Ariz. App. LEXIS 423, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arizona-department-of-economic-security-v-magma-copper-co-arizctapp-1980.