Desiree Bailey v. Kentucky Unemployent Insurance Commission

CourtCourt of Appeals of Kentucky
DecidedJune 22, 2023
Docket2022 CA 000606
StatusUnknown

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

Bluebook
Desiree Bailey v. Kentucky Unemployent Insurance Commission, (Ky. Ct. App. 2023).

Opinion

RENDERED: JUNE 23, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-0606-MR

DESIREE BAILEY APPELLANT

APPEAL FROM FAYETTE CIRCUIT COURT v. HONORABLE JULIE M. GOODMAN, JUDGE ACTION NO. 19-CI-01734

KENTUCKY UNEMPLOYMENT INSURANCE COMMISSION AND THE HONEY BAKED HAM COMPANY LLC APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, DIXON, AND ECKERLE, JUDGES.

DIXON, JUDGE: Desiree Bailey appeals the order of the Fayette Circuit Court,

entered on May 4, 2022, affirming the Kentucky Unemployment Insurance

Commission’s (the Commission) determination that she knowingly made false

statements in order to obtain benefits. After careful review of the record, briefs,

and law, we affirm. BACKGROUND FACTS AND PROCEDURAL HISTORY

Bailey worked full-time at General Electric (GE) for nearly 40 years

before it closed in 2017, and she worked part-time at The Honey Baked Ham

Company LLC (HBH) from 1993 through the relevant proceedings. After GE

closed, Bailey applied for unemployment insurance (UI) benefits, pursuant to

KRS1 341 and was approved. To receive her benefits, Bailey was required on a bi-

weekly basis from July to December 2017 to answer the following question:

“[d]uring this week, did you perform any work for which you were paid or will be

paid, or receive any income including wages and tips, odd jobs, self-employment,

commission pay, national guard duty pay, holiday pay, or vacation pay?” At issue

is Bailey’s repeated response: “No.”

In January 2019, the Division of Unemployment Insurance (the

Division) questioned Bailey regarding whether she had received undisclosed wages

from HBH while claiming benefits. Bailey admitted she had but explained she was

unaware of her obligation to report this income since her unemployment was from

GE. By a February 4, 2019, Notice of Determination, the Division ruled that

having committed an act of misrepresentation, Bailey was disqualified from

receiving benefits from July to December 2017 and for 52 additional weeks, and

that she owed $10,977 in wrongfully paid benefits and penalties.

1 Kentucky Revised Statutes.

-2- Bailey timely appealed to the Division Referee, and a hearing was

held on March 1, 2019, wherein Bailey was the only party in attendance and the

only witness to testify. During her testimony, Bailey asserted her belief that the

question pertained only to wages from GE and that had she understood the

Division’s intent, she would have duly reported her HBH income. Bailey then

asked for leave to correct her answers and to repay the $4,207.17 she received in

excess benefits as a result of her misreported income. Bailey absolutely denied

seeking any unmerited compensation and cited as proof her request that the

maximum for both state and federal taxes be withheld from her benefit checks. At

the conclusion of the evidence, the referee marked as an exhibit the February 4,

2019, determination, over Bailey’s objection, and affirmed.

In the ensuing appeal, the Commission rejected Bailey’s claims that

the referee improperly admitted evidence and that her failure to disclose her

earnings was an innocent mistake. Bailey then sought review pursuant to KRS

341.450 in the Fayette Circuit Court. After she was again denied relief, this appeal

followed.

-3- LEGAL ANALYSIS

Bailey argues that (1) the Commission’s finding that she knowingly

provided false information was not supported by substantial evidence, and (2) she

was denied an impartial referee and a fair hearing. We shall begin our review with

the latter claim.

Bailey contends that the referee abdicated its role as an impartial

arbiter2 and violated her confrontational rights when it sua sponte and without

foundational testimony introduced the Division’s determination. The Commission

and the circuit court reasoned any error in the admission of the exhibit was

harmless given Bailey’s admissions. We affirm on different grounds.

Pursuant to 787 KAR3 1:110 Section 5(2)(a), “[a]ll reports, forms,

letters, transcripts, communications, statements, determinations, decisions, orders,

and other matters, written or oral, from the worker, employer, or personnel or

representative of the office that have been written, sent, or made in connection with

an appeal shall constitute the record with respect to the appeal.” Plainly satisfying

this definition, the underlying determination was included as a matter of course in

the appellate record available for the referee’s consideration. Accordingly, we fail

2 KRS 341.420(1) provides that “[t]he secretary shall appoint one (1) or more impartial referees . . . to hear and decide appealed claims.” 3 Kentucky Administrative Regulations.

-4- to appreciate how the redundant entry of evidence already of record demonstrates

bias or prejudice by the referee. Additionally, Bailey’s claim that she was denied

an opportunity to confront the evidence is unavailing. Approximately 21 days in

advance of the March 1, 2019, hearing, Bailey was notified that “[a]ny Division

records applicable to the issue on appeal w[ould] be included” for the referee’s

consideration. Thus, she was afforded ample opportunity to secure necessary

witnesses and proof to rebut or explain the evidence of record, including the

determination at issue. Consequently, this claim fails.

We now consider whether substantial evidence supports the finding

that Bailey knowingly provided false information and was thereby disqualified

from receiving benefits.

As an initial matter, to the extent Bailey argues a finding in her favor

is mandated because her benefits were not contested by her employers and an agent

of the Division did not attend the hearing and present allegations against her, we

disagree. As explained in Kentucky Unemployment Insurance Commission v.

Watts:

[n]o Kentucky authority stands for the proposition that if an employer fails to contest a worker’s claim for unemployment benefits, the worker must be awarded unemployment benefits. Such a proposition would be inconsistent with the general rule that no [one] has any prior claim or rights to the amounts paid by the employer into the unemployment trust fund. See KRS 341.530(1).

-5- 407 S.W.3d 569, 574-75 (Ky. App. 2013) (emphasis in original). Moreover, as the

claimant, Bailey bore the burden of proving her entitlement to benefits. Alford v.

Kentucky Unemployment Ins. Comm’n, 568 S.W.3d 367, 370 (Ky. App. 2018)

(citing Brown Hotel Co. v. Edwards, 365 S.W.2d 299, 301 (Ky. 1962)).

Next, before we reach the specifics of Bailey’s claim, we must

address the applicable standard of review. It is well-established that when

substantial evidence supports the Commission’s findings of fact, a reviewing court

must defer, even if the record contains evidence to the contrary. Downey v.

Kentucky Unemployment Ins.

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Related

Thompson v. Kentucky Unemployment Insurance Commission
85 S.W.3d 621 (Court of Appeals of Kentucky, 2002)
Love v. Commonwealth
55 S.W.3d 816 (Kentucky Supreme Court, 2001)
Brown Hotel Company v. Edwards
365 S.W.2d 299 (Court of Appeals of Kentucky (pre-1976), 1962)
Kentucky Unemployment Insurance Commission v. Watts
407 S.W.3d 569 (Court of Appeals of Kentucky, 2013)
Downey v. Kentucky Unemployment Insurance Commission
479 S.W.3d 85 (Court of Appeals of Kentucky, 2015)
Alford v. Ky. Unemployment Ins. Comm'n
568 S.W.3d 367 (Court of Appeals of Kentucky, 2018)

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Desiree Bailey v. Kentucky Unemployent Insurance Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/desiree-bailey-v-kentucky-unemployent-insurance-commission-kyctapp-2023.