Brown v. Unemployment Insurance Commission

CourtSuperior Court of Maine
DecidedSeptember 27, 2005
DocketCUMap-05-038
StatusUnpublished

This text of Brown v. Unemployment Insurance Commission (Brown v. Unemployment Insurance Commission) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Unemployment Insurance Commission, (Me. Super. Ct. 2005).

Opinion

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WALLACE BROWN,

Petitioner * v. * * OR?!iR : "

f' ' UNEMPLOYMENT INSURANCE 5 ::to' COMMISSION, * qc L

Respondents * *

T h s case comes before the Court on Petitioner Wallace Brown's Motion to

Take Additional Evidence pursuant to M.R.c&. P 80C(e).

FACTUAL BACKGROUND

A Deputy of the Bureau of Unemployment Security disqualified Petitioner

from unemployment benefits because he voluntarily left his job with Maine

Overnight Air Express Inc. without good cause attributable to h s employment.

He appealed that decision to the Department of Administrative Hearings

("DAH"). Despite receiving notice of the date and time of the appeal, Petitioner

failed to appear. DAH dismissed the appeal by default. Over nine months later,

Petitioner appealed the DAH's decision to the Maine Unemployment Insurance

Commission (the "Commission"). The Commission dismissed the claim as

untimely pursuant to 26 M.R.S.A. 5 1194(3). Petitioner's request for

reconsideration was denied. Petitioner now seeks final agency review pursuant

to M.R. Civ. P. 80C and has requested that the Court take additional evidence

pursuant to M.R. Civ. P. 80C(e). DISCUSSION

Petitioner has requested that the Court allow additional evidence to be

taken in h s Rule 80C appeal. The Court may grant a motion to take additional

evidence a) in the case of "failure or refusal to act or alleged irregularities in

procedure before the agency whch are not adequately revealed in the record," or

b) if it finds that additional evidence is material, and such evidence "could not

have been presented or was erroneously disallowed in proceedings before the

agency." 5 M.R.S.A. 5 11006(1)and (2); York Hospital v.Department of Human

Services, 2005 ME 41, ¶ 20,869 A.2d 729,735 (a request for additional evidence is

most appropriately asserted when the evidence is relevant to bias or prejudice or

a claim that could not have been addressed to the agency during the

administrative proceedings).

The Commission's rulings may be reversed or modified on appeal only if

the Court determines that they are unsupported by substantial evidence on the

whole record, were affected by error of law or were "arbitrary or capricious as

characterized by abuse of discretion." 5 M.R.S.A 5 11007(4)(C)(4)(5)(6).

Accordingly, when the Superior Court reviews a decision of the Commission, it

must determine whether the law was correctly applied the law and whether the

findings of fact are supported by any competent evidence. Maddocks v.

Unemployment Ins. Comm'n, 2001 ME 60, P7,768 A.2d 1023,1025.

In h s case, Petitioner argues that the Deputy who originally denied h s

petitioner for unemployment benefits failed to use proper procedure by

essentially misjudging the credibility of Petitioner's employer. Petitioner seeks

to 1)take the testimony of the Deputy to determine h s fact-finding procedure; 2)

take the testimony of all employees of Maine Overnigh-tA r Express Inc. who spoke to the Deputy; 3) subpoena the telephone records of the conversations

between the Deputy and the employees; and 4) order the Deputy to produce a

written record of the facts.

First, Petitioner's failed to appear at h s hearing on appeal before the DAH.

He received notice of that hearing and had the opportunity then to present all the

evidence he seeks to introduce in h s motion.

Second, it is not an irregularity in procedure for a Deputy of the Bureau of

Unemployment to determine the credibility of witnesses when malung a benefits

decision. Furthermore, the Court will not second-guess a credibility

determination by a fact-finder unless it is unsupported by competent evidence.

Petitioner's own affidavit states that the Deputy relied on Petitioner's employer's

statement quoting Petitioner as saying "that I was going to quit and go back to

school."l In finding the employer to be credible, it was reasonable to believe that

Petitioner intended to leave the job voluntarily.

Finally, and most importantly, Petitioner had fifteen days to appeal the

DAH's decision to the Commission, yet he delayed over nine months. See 26

M.R.S.A. § 1194(3).' It was not an abuse of discretion or an erroneous

interpretation of the law for the Commission to dismiss Petitioner's appeal.

Furthermore, because the decision of the Commission was based on the

' The record does not contain the Deputy's reasons for denying benefits. 26 M.R.S.A. § 1194(3) provides: Unless such appeal is withdrawn, the Division of Administrative Hearings after affording the parties reasonable opportunity for fair hearing, shall affirm, modify or set aside the findings of fact and decision of the deputy. The parties shall then be duly notified of the division's decision, together with its reasons therefore, whch subject to section 11 shall be deemed to be the final decision of the commission unless, withn 15 calendar days after the notification was mailed to his last known address, the claimant and employer may appeal to the commission by filing an appeal in accordance with such rules as the commission shall prescribe, provided that the appealing party appeared at the hearing and was given notice of the effect of the failure to appear in writing prior to the hearing. untimeliness of the appeal, the additional evidence Petitioner seeks to take is not

material to the decision of the Commission. Essentially, Petitioner was given two

chances to fully present h s case at the

The Motion to Take Additional Evidence is D

DATE: ' COUaTS i d County I 287 X e 041 12-0287

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F COURTS ~ n County d ;ox 287 i e 041 12-0287

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Petitioner * v. * ORDER * UXEMPLOYMENT INSURANCE * COMMISSION, * * Respondent * *

This case comes before the Court on Petitioner Wallace Brown's 80C

Appeal and Petitioner's Motion to Amend his Complaint to allow h m to

transition this action into an ordinary civil action pursuant to M.R. Civ. P. 80C(a).

A Deputy of the Bureau of Unemployment Security disqualified Petitioner

from unemployment benefits because he voluntarily left h s job with Maine

Overnight Air Express Inc. without good cause attributable to h s employment.

He appealed that decision to the Department of Administrative Hearings

("DAH"). Despite receiving notice of the date and time of the appeal, Petitioner

failed to appear. DAH dismissed the appeal by default. Over nine months later,

Petitioner appealed the DAH's decision to the Maine Unemployment Insurance

Commission (the "Commission"). The Commission dismissed the claim as

untimely pursuant to 26 M.R.S.A. 5 1194(3). Petitioner's request for

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Related

York Hospital v. Department of Human Services
2005 ME 41 (Supreme Judicial Court of Maine, 2005)
Maddocks v. Unemployment Insurance Commission
2001 ME 60 (Supreme Judicial Court of Maine, 2001)

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Brown v. Unemployment Insurance Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-unemployment-insurance-commission-mesuperct-2005.