Childress v. Department of Employment Security

CourtAppellate Court of Illinois
DecidedDecember 1, 2010
Docket1-09-2733 Rel
StatusPublished

This text of Childress v. Department of Employment Security (Childress v. Department of Employment Security) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Childress v. Department of Employment Security, (Ill. Ct. App. 2010).

Opinion

THIRD DIVISION December 1, 2010

1-09-2733

JUANITA CHILDRESS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) ) THE DEPARTMENT OF EMPLOYMENT SECURITY; ) DIRECTOR, THE DEPARTMENT OF EMPLOYMENT ) SECURITY; THE BOARD OF REVIEW ) No. 09 L 50694 ) Defendants-Appellants ) ) (Chicago Park District, c/o Cambridge ) Integrated Services, ) Honorable ) Sanjay T. Tailor, Defendant). ) Judge Presiding.

JUSTICE STEELE delivered the opinion of the court:

Defendants, the Illinois Department of Employment Security

(Department), its Director, and the Board of Review, appeal from

the circuit court’s order reversing the Board’s decision denying

plaintiff, Juanita Childress, unemployment benefits under section

601(A) of the Illinois Unemployment Insurance Act (Act) (820 ILCS

405/601(A) (West 2008)). Defendants contend that under the Act,

plaintiff was ineligible to receive benefits because she

voluntarily left work without good cause attributable to her

employer when she accepted her employer’s severance package.

Defendants contend that, as a result, the circuit court erred in

reversing the Board’s decision. We agree and therefore reverse. 1-09-2733

BACKGROUND

The record shows that plaintiff was employed as an advanced

buyer by the Chicago Park District (hereafter Park District) from

September 1999 until October 15, 2008, when she accepted the Park

District’s voluntary severance package. She then applied for

unemployment benefits and the Park District protested her claim.

The Park District alleged that plaintiff was ineligible for

benefits because she voluntarily accepted the severance package,

along with monetary compensation. The Park District further

alleged that plaintiff was not threatened with a layoff, nor did

her resignation impact another employee.

On February 19, 2009, a claims adjudicator for the

Department determined that plaintiff was ineligible for

unemployment benefits because she left work voluntarily without

good cause attributable to her employer when she accepted the

Park District’s voluntary severance package.

Plaintiff requested reconsideration of this decision. She

stated that she had requested information from upper management

regarding whether an alleged layoff would affect her, but "they

could not guarantee [her] that [she] would remain an employee."

She stated that was sufficient reason for her to accept the

severance package offered and search for employment elsewhere.

On March 31, 2009, a Department referee conducted a

telephonic hearing in the matter. Plaintiff testified that she

- 2 - 1-09-2733

accepted the severance package, along with $15,000 in monetary

compensation, because the Park District was "talking about doing

major layoffs." She testified, however, that she was never

notified that she would be laid off from her position, in which

she held the most seniority. She testified that the job cuts

were not directed at any one person or department or based on

seniority but, rather, were "across the board." She further

stated the number of people the Park District intended to lay off

was reported in the newspaper, but she could not recall that

number. Plaintiff testified that she questioned the Director

about the targeted employees, but he could not confirm who would

be affected by the cuts. Moreover, plaintiff testified that

although the severance package permitted employees to work until

the end of October, she left before then because she was seeking

alternative employment. She acknowledged that three other

employees held the same position but did not accept the buyout

package.

Plaintiff further testified that another reason she left her

employer was because her work was "being taken and misconstrued

or done a different way or given to someone else" even after she

had completed it. She stated that it was her responsibility to

ensure the work was performed properly; however, she had no

knowledge it had been changed. She testified that, prior to

leaving, she notified her director that work on the computer had

- 3 - 1-09-2733

been deleted by other staff. Plaintiff believed she also

reported the deletion of her work to human resources, but was

unsure. She testified that based on the deletion, she believed

she "wasn’t needed."

Park District human resources manager Michele Gage next

testified that the Park District offered the voluntary severance

package to all full-time Park District employees, notifying them

via a letter. She testified that she was unaware of any meetings

where layoffs were threatened and there were no layoffs of full-

time staff at the Park District. Gage testified that when

plaintiff submitted her resignation, she stated that, for a

number of reasons, it was time for her resignation and that she

was not happy with the departmental management. Gage further

testified that plaintiff had resigned from her position prior to

the end of the incentive period, citing personal issues unrelated

to work and good timing.

On April 1, 2009, the referee affirmed the claims

adjudicator’s determination, finding that plaintiff was

ineligible to receive unemployment benefits under section 601(A)

of the Act (820 ILCS 405/601(A) (West 2008)), because she

employer. The referee held the evidence did not reflect that

plaintiff was in imminent danger of losing her job and that she

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could have worked an additional two weeks under the terms of the

offer, but declined to do so because of personal issues.

Plaintiff appealed to the Board. On June 3, 2009, the Board

affirmed the referee’s decision, citing the Illinois

Administrative Code (56 Ill. Adm. Code §2840.125, added at 17

Ill. Reg. 17929, eff. October 4, 1993), which governs when a

person is eligible for unemployment benefits after accepting an

employment buyout package. The Board found the Park District’s

severance offer was voluntary and not coerced by the threat of

layoff. That is, the Board observed that the Park District did

not announce any specific layoffs in conjunction with its offer

and did not set any fixed goals regarding the number of employees

expected to retire. The Board also found plaintiff was not

informed that she would face a layoff if she did not accept the

buyout. It further found there was no evidence that plaintiff

sought assurances from the employer that her employment would

not, in the proximate future, be terminated under terms

substantially less favorable to the terms of the buyout or that

the terms of her employment would not, in the proximate future,

become substantially less favorable. Rather, it found a

substantial reason for her decision to leave was her

dissatisfaction with the allocation of work, and this, the Board

held, did not constitute good cause attributable to her employer.

- 5 - 1-09-2733

Plaintiff subsequently filed a complaint for administrative

review in the circuit court of Cook County. The circuit court

reversed the Board’s decision on September 9, 2009. Defendants

appealed.

Although plaintiff has not filed a brief on appeal, we will

consider the merits of the appeal under the standard set forth in

First Capitol Mortgage Corp.

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