In re Lennane

CourtSupreme Court of North Carolina
DecidedMarch 11, 2022
Docket3A21
StatusPublished

This text of In re Lennane (In re Lennane) is published on Counsel Stack Legal Research, covering Supreme Court of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Lennane, (N.C. 2022).

Opinion

IN THE SUPREME COURT OF NORTH CAROLINA

2022-NCSC-21

No. 3A21

Filed 11 March 2022

IN THE MATTER OF FRANK LENNANE, Petitioner

ADT, LLC, Employer

and

NORTH CAROLINA DEPARTMENT OF COMMERCE, DIVISION OF EMPLOYMENT SECURITY, Respondent

Appeal pursuant to N.C.G.S. § 7A-30(2) from the decision of a divided panel of

the Court of Appeals, 274 N.C. App. 367 (2020), affirming an order entered on

17 February 2020 by Judge W. Robert Bell in Superior Court, Haywood County.

Heard in the Supreme Court on 6 January 2022.

Legal Aid of North Carolina, Inc., by Joseph Franklin Chilton, Cindy M. Patton, John R. Keller, and Celia Pistolis, for petitioner-appellant.

North Carolina Department of Commerce, Division of Employment Security, by Elias W. Admassu, R. Glen Peterson, and Sharon A. Johnston, for respondent- appellee.

BARRINGER, Justice.

¶1 In this case, we consider whether to uphold the determination that petitioner

Frank Lennane is disqualified from receiving unemployment benefits. To guide the

interpretation and application of unemployment benefits under Chapter 96 of the

General Statutes of North Carolina, the legislature has declared the public policy of IN RE LENNANE

Opinion of the Court

this State for nearly ninety years as the following:

Economic insecurity due to unemployment is a serious menace to the health, morals, and welfare of the people of this State. Involuntary unemployment is therefore a subject of general interest and concern which requires appropriate action by the Legislature to prevent its spread and to lighten its burden which now so often falls with crushing force upon the unemployed worker and his family. The achievement of social security requires protection against this greatest hazard of our economic life. This can be provided by encouraging employers to provide more stable employment and by the systematic accumulation of funds during periods of employment to provide benefits for periods of unemployment, thus maintaining purchasing power and limiting the serious social consequences of poor relief assistance. The Legislature, therefore, declares that in its considered judgment the public good and the general welfare of the citizens of this State require the enactment of this measure, under the police powers of the State, for the compulsory setting aside of unemployment reserves to be used for the benefit of persons unemployed through no fault of their own.

Unemployment Compensation Law, ch. 1, sec. 2, 1936 N.C. Pub. [Sess.] Laws (Extra

Sess. 1936) 1, 1 (codified at N.C.G.S. § 96-2 (2021)).

¶2 This declaration guides our analysis of the issue before us: whether Lennane’s

leaving work was attributable to his employer as required by N.C.G.S. § 96-14.5(a) to

avoid disqualification for unemployment benefits. See N.C.G.S. § 96-2. Having

considered the legislature’s declared public policy, the plain language of the

applicable statute, and the binding findings of fact, we conclude that Lennane failed

to show that his leaving work was attributable to his employer as required by IN RE LENNANE

N.C.G.S. § 96-14.5(a).

I. Background

¶3 Lennane left work on 16 November 2018. Lennane filed an initial claim for

unemployment benefits on 11 November 2018. An adjudicator held Lennane

disqualified for benefits, and Lennane appealed. Thereafter, an appeals referee

conducted a hearing on the matter. The appeals referee affirmed the prior decision

and ruled that Lennane was disqualified for unemployment benefits because he failed

to show good cause attributable to the employer for leaving as required by N.C.G.S.

§ 96-14.5(a). Lennane then appealed to the Board of Review for the North Carolina

Department of Commerce. The Board of Review adopted the appeals referee’s

findings of fact as its own and concluded that the appeals referee’s decision was in

accord with the law and the facts. Accordingly, the Board of Review affirmed the

appeals referee’s decision. Lennane next appealed to the superior court, which

affirmed the Board of Review’s decision. Lennane then appealed to the Court of

Appeals.

¶4 A divided panel of the Court of Appeals affirmed the superior court’s order. In

re Lennane, 274 N.C. App. 367, 372 (2020). When considering whether the superior

court erred by affirming the Board of Review’s determination, the Court of Appeals

compared this case with the Court of Appeals decision in Ray v. Broyhill Furniture

Industries, 81 N.C. App. 586 (1986). In re Lennane, 274 N.C. App. at 370. In Ray, the IN RE LENNANE

Court of Appeals “held that the claimant proved her reason for leaving was

attributable both to the employer’s action (the threat to fire her if she went over her

supervisor’s head) and inaction (her supervisor’s failure to put in her transfer

request).” Id. (cleaned up). Unlike Ray, the Court of Appeals explained that, in this

case, the employer acted to help Lennane. Id.

¶5 The Court of Appeals then considered whether competent evidence supported

the challenged findings of fact and whether those findings of fact supported the

conclusion of law. Id. at 370–72. The Court of Appeals concluded that competent

evidence supported the challenged findings of fact and that the findings of fact

supported the conclusion that Lennane “failed to establish that his good cause for

leaving work was attributable to the employer.” Id. at 372 (cleaned up).

¶6 To the contrary, the dissent contended that:

It is not [Lennane]’s fault that his knee suffers from osteoarthritis, nor is it his fault that his employer’s “business needs” precluded accommodations that would not require him to sacrifice his health. He was thus rendered “unemployed through no fault of [his] own[,]” N.C. Gen. Stat. § 96-2.

Id. at 373 (Inman, J., dissenting) (second and third alterations in original).

¶7 According to the dissent, like in Ray, Lennane’s employer’s inaction “placed

[him] in the untenable position of having to choose between leaving [his] job and

becoming unemployed or remaining in a job which . . . exacerbated [his medical]

conditions.” Id. (alterations in original) (quoting Ray, 81 N.C. App. at 592–93). Thus, IN RE LENNANE

the dissent, relying on N.C.G.S. § 96-2 and Ray, would have held that Lennane left

work for good cause attributable to the employer. Id. The dissent disagreed with the

majority’s conclusion of law but did not identify any findings of fact as being

unsupported by competent evidence. Id. at 372–73.

¶8 Lennane appealed based on the dissenting opinion. Accordingly, we now

consider the issue Lennane identified as distinguishing the majority and dissenting

opinions: “whether his leaving was attributable to the employer.”

II. Standard of Review

¶9 “The standard of review in appeals from the [Department of Commerce,

Division of Employment Security], both to the superior court and to the appellate

division, is established by statute.” Binney v. Banner Therapy Prods., Inc., 362 N.C.

310, 315 (2008). In these judicial proceedings, “the findings of fact by the Division, if

there is any competent evidence to support them and in the absence of fraud, shall be

conclusive, and the jurisdiction of the court shall be confined to questions of law.”

N.C.G.S. § 96-15(i) (2021); see also N.C.G.S. § 96-15(h) (establishing procedure for

judicial review of a decision of the Board of Review); Binney, 362 N.C. at 315. When

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Watson v. Employment Security Commission
432 S.E.2d 399 (Court of Appeals of North Carolina, 1993)
Intercraft Industries Corp. v. Morrison
289 S.E.2d 357 (Supreme Court of North Carolina, 1982)
Barnes v. Singer Co.
376 S.E.2d 756 (Supreme Court of North Carolina, 1989)
Milliken & Co. v. Griffin
309 S.E.2d 733 (Court of Appeals of North Carolina, 1983)
Ray v. Broyhill Furniture Industries
344 S.E.2d 798 (Court of Appeals of North Carolina, 1986)
In Re Watson
161 S.E.2d 1 (Supreme Court of North Carolina, 1968)
State Ex Rel. Employment Security Commission v. Jarrell
57 S.E.2d 403 (Supreme Court of North Carolina, 1950)
In Re Steelman
13 S.E.2d 544 (Supreme Court of North Carolina, 1941)
Couch v. North Carolina Employment Security Commission
373 S.E.2d 440 (Supreme Court of North Carolina, 1988)
Binney v. Banner Therapy Products, Inc.
661 S.E.2d 717 (Supreme Court of North Carolina, 2008)
North Carolina Department of Correction v. North Carolina Medical Board
675 S.E.2d 641 (Supreme Court of North Carolina, 2009)
Carolina Power & Light Co. v. Employment Security Commission
681 S.E.2d 776 (Supreme Court of North Carolina, 2009)
Marlow v. North Carolina Employment Security Commission
493 S.E.2d 302 (Court of Appeals of North Carolina, 1997)
Lancaster v. Black Mountain Center
323 S.E.2d 760 (Court of Appeals of North Carolina, 1984)
Couch v. North Carolina Employment Security Commission
366 S.E.2d 574 (Court of Appeals of North Carolina, 1988)

Cite This Page — Counsel Stack

Bluebook (online)
In re Lennane, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-lennane-nc-2022.