Ford v. ICAO

CourtColorado Court of Appeals
DecidedJanuary 15, 2026
Docket25CA1526
StatusUnpublished

This text of Ford v. ICAO (Ford v. ICAO) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ford v. ICAO, (Colo. Ct. App. 2026).

Opinion

25CA1526 Ford v ICAO 01-15-2026

COLORADO COURT OF APPEALS

Court of Appeals No. 25CA1526 Industrial Claim Appeals Office of the State of Colorado DD No. 12645-2025

Erik Ford,

Petitioner,

v.

Industrial Claim Appeals Office of the State of Colorado,

Respondent.

ORDER AFFIRMED

Division A Opinion by JUSTICE MARTINEZ* Román, C.J., and Hawthorne*, J., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced January 15, 2026

Erik Ford, Pro Se

No Appearance for Respondent

*Sitting by assignment of the Chief Justice under provisions of Colo. Const. art. VI, § 5(3), and § 24-51-1105, C.R.S. 2025. ¶1 In this unemployment benefits case, claimant, Erik Ford,

seeks review of a final order of the Industrial Claim Appeals Office

(Panel). The Panel affirmed the hearing officer’s decision

disqualifying Ford from receiving benefits based on his job

separation from CraneWorks, Inc. We affirm.

I. Background

¶2 Ford worked as a Branch Services Manager for CraneWorks

from January 2022 to September 2024. He originally took this

position with hopes that he would be able to move up the ranks,

but over time it became clear that there was no opportunity for

growth. Ford therefore started looking for another position and was

offered a Branch Service Manager position for a competitor at

higher pay. Ford gave notice to CraneWorks and started his new

position.

¶3 A deputy determined that Ford was disqualified from receiving

benefits because he was responsible for his separation from

employment when he quit CraneWorks to accept other employment.

As far as we can discern from the record, Ford’s new employer

eliminated his position sometime in March 2025 and he

immediately applied for unemployment benefits. But because

1 Ford’s “base period” included only time he worked for CraneWorks,

the deputy determined that Ford’s eligibility for unemployment

benefits was limited to the circumstances under which he separated

from that employer. See § 8-70-103(2), C.R.S. 2025 (defining “base

period” as “the first four of the last five completed calendar quarters

immediately preceding the first day of the individual’s benefit year”).

The record before us does not include specific dates from which the

base period and the eligibility for unemployment benefits can be

determined. And that is not an issue Ford raised.

¶4 Ford appealed and a hearing was held. The hearing officer

concluded that Ford was disqualified from receiving unemployment

benefits under section 8-73-108(5)(e)(V), C.R.S. 2025, because he

quit to accept other employment. Ford appealed the hearing

officer’s decision to the Panel, which affirmed upon review.

II. Standard of Review and Applicable Law

¶5 As relevant in this case, we may set aside the Panel’s decision

only if the findings of fact do not support the decision or if the

decision is erroneous as a matter of law. § 8-74-107(6), C.R.S.

2025. We may not disturb the hearing officer’s factual findings if

they are “supported by substantial evidence or reasonable

2 inferences drawn from that evidence.” Yotes, Inc. v. Indus. Claim

Appeals Off., 2013 COA 124, ¶ 10; see also § 8-74-107(4) (facts

supported by substantial evidence shall be conclusive). Substantial

evidence is “that which is probative, credible, and competent, of a

character which would warrant a reasonable belief in the existence

of facts supporting a particular finding.” Rathburn v. Indus.

Comm’n, 566 P.2d 372, 373 (Colo. App. 1977).

¶6 A claimant’s entitlement to employment benefits depends on

the reason for the separation from employment, which is a question

of fact for the hearing officer. Eckhart v. Indus. Claim Appeals Off.,

775 P.2d 97, 99 (Colo. App. 1989); see also § 8-73-108(1)

(unemployment benefits are aimed at persons unemployed through

no fault of their own). A claimant is disqualified from receiving

benefits when the claimant “quit[s] to accept other employment”

(except for certain employment in the construction industry).

§ 8-73-108(5)(e)(V).

III. Analysis

¶7 It is undisputed that Ford quit working for CraneWorks to

accept a job with a competitor. Ford testified accordingly before the

3 hearing officer. Ford neither argued nor presented evidence that

the construction work exception applies. See § 8-73-108(4)(f)(I).

¶8 In his appeal to the Panel, Ford asserted that the hearing

officer erred when she made a factual finding that he left

CraneWorks for a better paying job. Ford argued he left for

“professional growth” rather than better pay. The Panel addressed

Ford’s argument, explaining that Ford said he left for “professional

development” but also that the new position paid more annually

and had the potential for quarterly bonuses — which his

employment at CraneWorks did not. The Panel found, and we

agree, that the hearing officer’s inferences from this evidence that

Ford sought a job with higher pay was not in error. Accordingly,

the hearing officer’s factual findings as to the reason for Ford’s

separation from CraneWorks, are supported by substantial

evidence. See § 8-74-107.

¶9 More importantly, an employee is disqualified for benefits

under section 8-73-108(5)(e)(V), if they quit their job to accept other

employment — quitting for higher pay is not required. Thus, Ford

was not eligible for benefits whether he left CraneWorks for

“professional growth,” for higher pay, or for both.

4 ¶ 10 On appeal, Ford also asserts that had he waited six more days

to file for unemployment benefits, he would have received it from

his new employer, rather than CraneWorks. He asserts that he

should not be disqualified from receiving benefits because he has

worked for thirty consecutive years, does not know how

unemployment benefits work, and did not know the details about

how the timing of benefits worked. He further asserts that the

unemployment office should have told him to wait a week to file for

benefits to ensure that he received them.

¶ 11 Even assuming that Ford would have been entitled to benefits

had he waited a week to file a claim, under the circumstances, it

appears that the hearing officer had no choice but to find Ford

disqualified from receiving benefits because of his voluntary

separation from CraneWorks. See § 8-73-108(5)(e)(V). Further, on

this record and with the issues Ford raised, we cannot conclude

that the Panel’s order upholding the hearing officer’s decision was

legally erroneous or unsupported by the factual findings. See

Yotes, ¶ 10. Consequently, we cannot set aside the Panel’s order on

review.

5 ¶ 12 As we understand Ford’s argument, he claims that had he

waited to file for unemployment benefits, his “base period” would

have encompassed his employment with the new employer who laid

him off and, as such, he would not have been disqualified from

receiving benefits. As mentioned above, that issue was not before

the hearing officer. See § 8-74-104(2), C.R.S. 2025 (the Panel may

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Related

Paul v. Industrial Commission
632 P.2d 638 (Colorado Court of Appeals, 1981)
Rathburn v. Industrial Commission
566 P.2d 372 (Colorado Court of Appeals, 1977)
Velo v. Employment Solutions Personnel
988 P.2d 1139 (Colorado Court of Appeals, 1998)
Voisinet v. Industrial Claim Appeals Office
757 P.2d 171 (Colorado Court of Appeals, 1988)
Boeheim v. Industrial Claim Appeals Office
23 P.3d 1247 (Colorado Court of Appeals, 2001)
Yotes, Inc. v. Industrial Claim Appeals Office
2013 COA 124 (Colorado Court of Appeals, 2013)

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