Goodwill Industries v. Unemployment Compensation Board of Review

634 A.2d 738, 160 Pa. Commw. 147, 1993 Pa. Commw. LEXIS 715
CourtCommonwealth Court of Pennsylvania
DecidedNovember 23, 1993
DocketNo. 2301 C.D. 1992
StatusPublished
Cited by4 cases

This text of 634 A.2d 738 (Goodwill Industries 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
Goodwill Industries v. Unemployment Compensation Board of Review, 634 A.2d 738, 160 Pa. Commw. 147, 1993 Pa. Commw. LEXIS 715 (Pa. Ct. App. 1993).

Opinions

McGINLEY, Judge.

Goodwill Industries (Employer) appeals from the September 29,1992, order of the Unemployment Compensation Board of Review (Board) reversing a referee’s decision that Ervin L. McIntyre (Claimant) was ineligible for benefits because he was discharged from employment for willful misconduct under Section 402(e) of the Unemployment Compensation Law (Law).1 We reverse.

The issue before us is whether the Board erred in holding that Claimant’s off-duty distribution of approximately 500 leaflets containing negative statements about Employer did not constitute willful misconduct. Our scope of review is limited to determining whether constitutional rights were violated, whether an error of law was committed or whether all necessary findings of fact are supported by substantial evidence. Moonlight Mushrooms, Inc. v. Unemployment Compensation Board of Review, 142 Pa.Commonwealth Ct. 153, 158, 596 A.2d 1264, 1266 (1991).

A willful misconduct determination is a question of law subject to our review. Simmons v. Unemployment Compensation Board of Review, 129 Pa.Commonwealth Ct. 315, 565 A.2d 829 (1989), aff'd 528 Pa. 590, 599 A.2d 646 (1991). [150]*150Evidence of one of the following is necessary for a finding of willful misconduct:

(1) wanton and willful disregard of an employer’s interest,
(2) a deliberate violation of the employer’s rules, (3) a disregard of expected standards of behavior which an employer may rightfully expect from an employee, or (4) negligence which manifests culpability, wrongful intent, evil design, or intentional and substantial disregard for an employer’s interest or an employee’s duties or obligations.

Alexander v. Unemployment Compensation Board of Review, 138 Pa.Commonwealth Ct. 647, 650, 588 A.2d 1341, 1342 (1991).

In its September 29, 1992, Decision and Order, the Board made the following findings of fact:

1. Claimant was last employed as a truck helper and occasional driver by Goodwill Industries for approximately three years at a final rate of $5.72 per hour and his last day of work was January 27, 1992.

2. Claimant was dissatisfied with certain procedures the employer utilized in the conduct of its business.

3. Claimant attempted to address his concerns with the employer at various times.

4. On Saturday, January 25, 1992, while off duty, claimant composed approximately 500 flyers stating his opinion in the form of questions.

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Bluebook (online)
634 A.2d 738, 160 Pa. Commw. 147, 1993 Pa. Commw. LEXIS 715, Counsel Stack Legal Research, https://law.counselstack.com/opinion/goodwill-industries-v-unemployment-compensation-board-of-review-pacommwct-1993.