Gladieux Food Services, Inc. v. Unemployment Compensation Board of Review

365 A.2d 889, 27 Pa. Commw. 142, 1976 Pa. Commw. LEXIS 778
CourtCommonwealth Court of Pennsylvania
DecidedNovember 17, 1976
DocketAppeal, No. 1610 C.D. 1975
StatusPublished
Cited by5 cases

This text of 365 A.2d 889 (Gladieux Food Services, Inc. v. Unemployment Compensation Board of Review) 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
Gladieux Food Services, Inc. v. Unemployment Compensation Board of Review, 365 A.2d 889, 27 Pa. Commw. 142, 1976 Pa. Commw. LEXIS 778 (Pa. Ct. App. 1976).

Opinions

Opinion by

Judge Blatt,

Gladieux Food Services, Inc. (Gladieux) has appealed a decision of the Unemployment Compensation Board of Review (Board), dated September 25, 1975, which granted unemployment compensation benefits to David A. Laskey1 (claimant). The claimant is a member of Teamsters Local 249 (union) which represents the employees at Gladieux’s in-flight kitchen facility at the Pittsburgh airport. The collective bargaining agreement between Gladieux and the union expired on April 30, 1974. Prior to the expiration of the contract, the parties had engaged in collective bargaining, but had been unable to agree on new terms and conditions of. employment. At or about 10:00 P.M. on April 30, the union members voted not to strike and consequently the appropriate employees then reported for work on the midnight shift on May 1, 1974. The airlines which utilized Gladieux’s facility to provide food to the passengers on their flights, however, [145]*145had notified Gladieux prior to the expiration of the contract that they would cease utilizing Gladieux’s facility due to the unsettled labor situation until such time as they could be assured of receiving uninterrupted service.2 The employees continued to report to work until May 9, 1974, when Gladieux closed its facility for lack of work. The claimant was granted unemployment compensation benefits effective as of that date by the Bureau of Employment Security, that decision was affirmed by the Board, and this appeal followed.

Our scope of review of a decision of the unemployment compensation authorities is to determine whether or not errors of law have been committed, and, absent fraud, whether or not the findings of fact are supported by substantial evidence, leaving questions of credibility and weight of evidence to the Board. Unemployment Compensation Board of Review v. Tickle, 19 Pa. Commonwealth Ct. 550, 339 A.2d 864 (1975).

The purpose of our unemployment compensation system is to compensate an individual who has become unemployed through no fault of his own. Section 3 of the Unemployment Compensation Law3 (Act), 43 P.S.§752. Section 402(d) of the Act, 43 P.S. §802(d) provides, inter alia, as follows:

An employe shall be ineligible' for compensation for any week—
[146]*146In which his unemployment is due to a stoppage of work, which exists because of a labor dispute (other than a lock-out) at the factory, establishment or other premises at which he is or was last employed. . . .

When a work stoppage has occurred due to a labor dispute, it is necessary to determine the party whose action constituted the final cause thereof, and to assess responsibility against that party. Bokoski Unemployment Compensation Case, 206 Pa. Superior Ct. 96, 211 A.2d 124 (1965). If fault is attributable to both the employer and the employees, compensation must be denied because the purpose of the unemployment compensation law is to benefit faultless employees. Toma v. Unemployment Compensation Board of Review, 4 Pa. Commonwealth Ct. 38, 285 A.2d 201 (1971). In Vrotney Unemployment Compensation Case, 400 Pa. 440, 444-445, 163 A.2d 91, 93 (1960), our Supreme Court established the sole method under Section 402(d) of the Act for determining the responsibility for a work stoppage as follows:

Have the employees offered to continue working for a reasonable time under the pre-existing terms and conditions of employment so as to avert a work stoppage pending the final settlement of the contract negotiations; and has the employer agreed to permit work to continue for a reasonable time under the pre-existing terms and conditions of employment pending further negotiations?

The Board here made the following crucial findings of fact:

6. Prior to the expiration of the current agreement, the union agreed to continue to work under the same terms and conditions of the then current agreement and that any new agreement would be retroactive to May 1,191I¡.
[147]*1477. The company refused to agree to the union’s offer; the company was willing to continue to provide work under the same terms and conditions of the then current agreement, but would not agree to retroactivity. (Emphasis added.)

We believe that the union’s “offer” did not constitute a bona fide offer to continue work under the preexisting terms and conditions of employment because of the demand of retroactive benefits. See Vrotney, supra; Clark Unemployment Compensation Case, 209 Pa. Superior Ct. 239, 223 A.2d 909 (1966); Allman Unemployment Compensation Case, 187 Pa. Superior Ct. 416, 144 A.2d 852 (1958).

The import of this language [of the Vrotney test] is clear. It is the duty of the employe to offer to continue working for a reasonable time under the same terms and conditions.

Clark, supra, 209 Pa. Superior Ct. at 243, 223 A.2d at 911. (Emphasis added.)

The union’s offer did not discharge its duty, and, therefore, the Board’s findings require that the responsibility for the work stoppage here be assessed against the union as the party which first refused to maintain the status quo. Philco Corp. v. Unemployment Compensation Board of Review, 430 Pa. 101, 242 A.2d 454 (1968).

The union, however, argues that its membership made the required offer to continue working and maintain the status quo by appearing for work as scheduled after the expiration of the contract and thereby discharged its duty under Vrotney. It is true that the employees here never called a strike and that they continued to report for work. It is also true, however, that the flow of work from the airlines into G-ladieux’s facility ceased as a result of the labor dispute and the failure of the parties to agree to continue working for a reasonable period of time.

[148]*148In Lerch Unemployment Compensation Case, 400 Pa. 446, 163 A.2d 535 (1960), the employer was Iiershey Estates and onr Supreme Court considered the nature of the employer’s business when it determined that the union’s offer to continue working under the then existing status quo on a day-to-day basis was not sufficient to meet its obligations under the Vrotney test. In Lerch, the employer’s business consisted mainly of service industries which could not be operated on a day-to-day basis.

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Related

Loftus v. Commonwealth
420 A.2d 1351 (Commonwealth Court of Pennsylvania, 1980)
Borello v. Commonwealth
397 A.2d 471 (Commonwealth Court of Pennsylvania, 1979)
Gladieux Food Services, Inc. v. Unemployment Compensation Board of Review
388 A.2d 678 (Supreme Court of Pennsylvania, 1978)
Kells v. Commonwealth
378 A.2d 495 (Commonwealth Court of Pennsylvania, 1977)

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365 A.2d 889, 27 Pa. Commw. 142, 1976 Pa. Commw. LEXIS 778, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gladieux-food-services-inc-v-unemployment-compensation-board-of-review-pacommwct-1976.