Dept. of L&I v. UCBR

CourtCommonwealth Court of Pennsylvania
DecidedMay 8, 2026
Docket390 C.D. 2025
StatusUnpublished
AuthorFizzano Cannon

This text of Dept. of L&I v. UCBR (Dept. of L&I v. UCBR) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dept. of L&I v. UCBR, (Pa. Ct. App. 2026).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Department of Labor and Industry, : Petitioner : : v. : : Unemployment Compensation : Board of Review, : No. 390 C.D. 2025 Respondent : Submitted: April 13, 2026

BEFORE: HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE STACY WALLACE, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE FIZZANO CANNON FILED: May 8, 2026

The Department of Labor and Industry (Department) petitions for review of the February 28, 2025, order of the Unemployment Compensation (UC) Board of Review (Board). The Board reversed a May 10, 2024, referee’s order that had deemed Kimberly Bauer (Claimant), a former Department employee, ineligible for UC benefits. Upon review, we reverse the Board’s order.

I. Factual and Procedural Background On December 5, 2023, Claimant applied online for UC benefits. Certified Record (C.R.) at 3.1 She asserted that she resigned from her employment with the Department on December 4, 2023, for personal reasons. Id. at 10 & 12. In an application questionnaire, Claimant wrote that she attempted to maintain the

1 Certified Record (C.R.) references are to electronic pagination. employment relationship but ultimately decided she “needed to leave and find a less mentally taxing job.” Id. at 29. The record includes Claimant’s December 5, 2023, email to the Department notifying her supervisors of her decision to resign. Id. at 41-42. Claimant stated in the email that she hoped to retain her “chances for rehire in the future” but needed “to take time to reset and better her mental health.” Id. In a December 17, 2023, follow-up UC application questionnaire, Claimant explained that she resigned because she could “no longer deal with the mental anguish” of the job after being denied a promotion and “punished” for things that her supervisors would not explain when she asked about them. Id. at 48-49. On January 17, 2024, the UC Service Center issued an initial determination denying benefits because Claimant’s application indicated that she left for personal rather than work-related reasons. C.R. at 53. Claimant timely appealed, asserting that she did everything she could to maintain the employment relationship, including asking for assistance and clarification of her “alleged issues” so that she could address them and speaking with management to understand the reason she was not promoted. Id. at 68. She added that she was “called out” multiple times in team meetings for “things that could not be validated and told I was being punished,” and then it became a “hostile work environment with my supervisor who did nothing to help me when I asked for it.” Id. at 69. A referee conducted an in-person hearing on May 8, 2024. C.R. at 109. Claimant, who appeared pro se, stated that she began working full time for the Department as an intake interviewer in September 2022, although the date was later corrected to August 2022. Id. at 117 & 126. She worked three weeks of each month from home and one week of each month in the office. Id. at 117. The work involved taking calls from UC claimants, helping them open and reopen claims, and

2 answering their questions. Id. She began as a temporary employee but became permanent in October 2022. Id. at 118. In addition to calls, she handled chat emails and “special projects” like monetary investigations regarding claimants’ wage figures; she described the job as tough and difficult. Id. at 118 & 120. In October or November of 2023, she unsuccessfully applied for a promotion to an available “examiner” position that paid more and involved examining already-filed claims and helping make determinations on those claims. Id. at 119. One of her supervisors, Nora Anderson, told her it was based on seniority and she was just below the people who got the job; she planned to apply again when promotions opened up again, usually every few months, and acknowledged that she would probably be “near the top of the list” when that happened. Id. at 119 & 125. She understood why she was not promoted but characterized it as “a little bit of a setback for me.” Id. Claimant testified that shortly after the unsuccessful promotion application, she began feeling that one of her supervisors, Tom Arner, was singling her out for criticism at her group’s weekly online team meetings, where roughly 5 to 10 interviewers participated. C.R. at 120. Arner pointed out at least twice during meetings in late November 2023 that Claimant was exceeding her after-call time, which is for wrap-up tasks and duties after each call, and that she would be punished for it. Id. at 120 & 122. The usual rule was that after-call work should take about 10% of the length of the call. Id. at 121. Claimant said that she was the only person that Arner called out for this issue. Id. at 121. Claimant acknowledged that she once forgot to change her status in the system when she went into a meeting right after she finished a call, so it looked as though she had exceeded the recommended after-call timespan. Id. at 120-21. Other than that, she normally messaged a supervisor if her after-call time was going to take

3 longer than normal, so she did not understand why she was being reprimanded and threatened with punishment at the meetings. She asked Arner for specifics and he told her he was going to ask another supervisor about it, but she never heard back from either of them. Id. at 121-22. Soon, her time on special projects was reduced and she was given more time on the phones, but this was not presented to her as formal discipline or a demotion. Id. at 123 & 126. She felt wrongly singled out at the meetings about the after-call time issue and wished Arner had spoken to her separately and privately. Id. at 123. She did not believe she needed more training on time management because she was only trying to find out what incidents Arner was referring to in the meetings. Id. at 126. Claimant had not been with the Department for long and believed that a challenge to Arner’s conduct would not go well for her if it was her word against his, so she did not talk to a higher-level supervisor, human resources, or her union representatives. C.R. at 122-24. At that point, she began to feel like the job was too mentally taxing for her. Id. at 124. She did not have any personal leave days or health insurance at the time and believed that without a medical or mental health diagnosis, asking for a leave of absence would be futile. Id. at 124-25. She stated that she loved her job and had hoped to be there for a long time until these setbacks occurred in late 2023. Id. at 125. As of the May 2024 hearing, she had not found another job. Id. The Department, represented at the hearing by counsel, presented Nora Anderson as a witness. Anderson testified that Claimant had been “excellent” at her job and received a commendation in February 2023 for helping an applicant. C.R. at 127 & 129-30. Claimant never came to Anderson with any issues and was not under disciplinary or performance improvement conditions before resigning. Id. at

4 128 & 130-31. Claimant never told Anderson of any problems with her schedule or that she felt singled out by superiors for criticism and punishment. Id. at 129-30. Anderson confirmed that Claimant asked her about the promotion and that she told Claimant it was based on seniority. Id. at 128-29. Anderson stated that Claimant could have been a promotion candidate next time if her seniority fit the requirements. Id. at 129. Anderson testified that scheduling for interviewers was based on operational needs and that if the phone queue got high, interviewers across the state would be taken off of special projects and added to the phone team. C.R. at 131 & 136. After-call time was based on the needs of each call, but if an interviewer needed more than about five minutes after a call, management would want to know if the interviewer needed help. Id.

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Bluebook (online)
Dept. of L&I v. UCBR, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dept-of-li-v-ucbr-pacommwct-2026.