Derrick E. Pavelka v. Texas Workforce Commission and City of Austin, Texas Aviation Department

CourtCourt of Appeals of Texas
DecidedOctober 3, 2006
Docket03-05-00293-CV
StatusPublished

This text of Derrick E. Pavelka v. Texas Workforce Commission and City of Austin, Texas Aviation Department (Derrick E. Pavelka v. Texas Workforce Commission and City of Austin, Texas Aviation Department) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Derrick E. Pavelka v. Texas Workforce Commission and City of Austin, Texas Aviation Department, (Tex. Ct. App. 2006).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-05-00293-CV

Derrick E. Pavelka, Appellant



v.



Texas Workforce Commission and City of Austin, Texas Aviation Department, Appellees



FROM THE DISTRICT COURT OF WILLIAMSON COUNTY, 26TH JUDICIAL DISTRICT

NO. 04-543-C368, HONORABLE BURT CARNES, JUDGE PRESIDING

M E M O R A N D U M O P I N I O N

Derrick Pavelka asserts that the district court erred in concluding that substantial evidence supports the Texas Workforce Commission's (the Commission) decision denying his claim for unemployment benefits because he was terminated for misconduct.  Tex. Lab. Code Ann.§ 207.44(a) (West 2006). In December 1994, Pavelka was arrested for the unlawful carrying of a weapon in Dallas County. See Tex. Penal Code Ann. § 46.02(a) (West 2003). In April 1995, Pavelka's attorney entered a plea of nolo contendere on Pavelka's behalf, and the trial court placed Pavelka on deferred adjudication community supervision for twelve months. Pavelka was discharged from community supervision in April 1996. In February 2001, Pavelka was hired by the City of Austin Aviation Department and assigned to work at the local airport. The City's employment application included the following question: "Have you been convicted of a crime or have you pled nolo contendere or been granted deferred adjudication within the last ten years?" Despite his 1995 plea, on Pavelka's application the "No" box is checked in response to the question.

When it was discovered that Pavelka had received deferred adjudication, he was terminated because he was no longer allowed to have unescorted access to the Security Identification Display Area at the airport, a requirement for his job duties, and because he falsified his employment application. Pavelka applied for unemployment benefits. The Commission denied his application based on its determination that Pavelka was discharged from his position for falsifying his employment application, which constitutes misconduct under the Act. See Tex. Lab. Code Ann. § 201.012 (West 2006). Pavelka, appearing pro se, sought review of the Commission's decision in district court. Pavelka argued that he did not check the "No" box and, alternatively, if he did, he did not understand the response to be false at the time because he was unaware of the fact that he had been placed on deferred adjudication. The district court affirmed the Commission's decision, and Pavelka appeals from that judgment. Because Pavelka failed to establish that the Commission's decision was not supported by substantial evidence, we affirm the district court's judgment.



BACKGROUND

After the September 11, 2001 terrorist attacks, the Transportation Security Administration (TSA) issued regulations requiring criminal history record checks on all employees having unescorted access to secured areas of any airport in the United States. The regulations prohibit the employment of "individuals who have unescorted access to aircraft or a secured area of an airport when an individual has a criminal conviction (or finding of not guilty by reason of insanity) for a disqualifying offense in the previous ten-year period." In an effort to assist airport personnel and "to ensure uniformity in the adjudication of background checks for airport and air carrier workers," TSA prepared a document entitled "Legal Guidance on Criminal History Records Checks." In the document, TSA took the position that "a conviction means any finding of guilt, plea of guilty, plea of nolo contendere, or finding of not guilty by reason of insanity." On December 19, 2001, the City of Austin sent a memorandum to all Aviation Department employees informing them of TSA's new regulations and requesting that the employees self-report whether they had been "convicted or found not guilty by reason of insanity of a 'disqualifying criminal offense.'" The unlawful possession of a weapon was listed as a disqualifying offense, but the City did not circulate the legal guidance document to its employees or explain that a plea of nolo contendere was considered a conviction. Pavelka did not make a report.

Lieutenant Tim Schroeder checked Pavelka's criminal history. In December 2002, Pavelka's first criminal history background check came back negative. However, in September 2003, a second criminal background check revealed that Pavelka had been placed on deferred adjudication community supervision for the unlawful carrying of a weapon in 1995. Relying on TSA's legal guidance document, Lieutenant Schroeder concluded that Pavelka had been convicted of a disqualifying offense within the previous ten-year period and notified Pavelka's supervisor, Patti Edwards, that Pavelka was no longer eligible for unescorted access privileges at the airport. Edwards met with Pavelka in an effort to find a different position for him, but there was no available position that did not require unescorted access privileges. At that time, Edwards also pulled Pavelka's job application and discovered that he had checked the "No" box in response to the question asking whether he had been granted deferred adjudication within the last ten years. Ultimately, Pavelka was terminated from his position at the Aviation Department because he falsified his employment application and because he was unable to perform his duties without unescorted access privileges.

Pavelka appealed his termination to the City's grievance committee and a hearing was held in November 2003. The hearing officer, Frederick Ahrens, made the following finding:



[Pavelka] gave credible testimony at the hearing that he believed the Court Order Dismissing the [unlawful carrying of a weapon] charge wiped his record clean. Therefore when he filled out his employment application he did not have a deferred adjudication or a plea of nolo contendere.



After reviewing Ahrens's report, the City's grievance committee recommended that "the decision to terminate Derrick Pavelka be reversed." The grievance committee recommended further that Pavelka be reinstated to a similar position in another department. Despite the grievance committee's recommendation, the City determined that the decision to terminate Pavelka's employment was appropriate.

After his termination, Pavelka applied for unemployment benefits, but the Commission denied his application, saying that he was terminated for falsifying his employment application. Pavelka appealed this decision to the Commission's appeal tribunal and hearings were held in November and December 2003. The hearing officer issued findings of fact and conclusions of law. She found that Pavelka was not aware that he had been placed on deferred adjudication in 1995. She found further that Pavelka "never received any official court documents and thought all charges had been dismissed prior to the time he applied for work" at the City.

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