K. Horvath v. UCBR

CourtCommonwealth Court of Pennsylvania
DecidedJanuary 30, 2020
Docket837 C.D. 2019
StatusUnpublished

This text of K. Horvath v. UCBR (K. Horvath v. UCBR) 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
K. Horvath v. UCBR, (Pa. Ct. App. 2020).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Keith Horvath, : Petitioner : : v. : : Unemployment Compensation Board : of Review, : No. 837 C.D. 2019 Respondent : Submitted: November 22, 2019

BEFORE: HONORABLE MARY HANNAH LEAVITT, President Judge HONORABLE ANNE E. COVEY, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE COVEY FILED: January 30, 2020

Keith Horvath (Claimant), pro se, petitions this Court for review of the Unemployment Compensation (UC) Board of Review’s (UCBR) May 8, 2019 order affirming the Referee’s decision denying UC benefits under Section 402(e) of the UC Law (Law).1 Claimant essentially presents one issue for this Court’s review: whether the UCBR erred by concluding that Claimant committed willful misconduct.2 After review, we affirm. Claimant was employed by World Energy LLC (Employer) as a full- time laboratory technician from February 28, 2018 until January 29, 2019, when

1 Act of December 5, 1936, Second Ex. Sess., P.L. (1937) 2897, as amended, 43 P.S. § 802(e) (referring to willful misconduct). 2 Claimant states three issues in his Statement of the Questions Involved: (1) whether the income Claimant helped World Energy LLC (Employer) accrue outweighs any detriment caused by Claimant’s tardiness; (2) whether Claimant’s financial need and distance from work outweigh Employer’s detriment arising from Claimant’s tardiness; and (3) whether Employer’s tardiness policy was uniformly applied to all employees. See Claimant Br. at 5. Because these issues are subsumed in whether the UCBR erred by concluding that Claimant committed willful misconduct, they will be addressed therein. Employer discharged him for excessive tardiness. Employer had an Attendance and Punctuality Policy (Policy) that specified: “An employee is deemed to be tardy when he/she: [f]ails to report for work at the assigned/scheduled work time[,] . . . [and/or] [a]rrives to work past his/her scheduled start time.” Certified Record (C.R.) Item 8, Notes of Testimony, March 29, 2019 (N.T.) at 6, Ex. 1. Employees were subject to progressive discipline for violating the Policy, up to and including discharge. On March 5, 2018, Claimant signed an acknowledgement that he understood the Policy. See N.T. Ex. 1 at 1. Employer terminated Claimant’s employment on January 29, 2019, after he was late for work 14 times between June 2018 and January 2019. Claimant applied for UC benefits. On March 4, 2019, the Harrisburg Overflow Center (UC Service Center) determined that Claimant was not eligible for UC benefits due to his willful misconduct, pursuant to Section 402(e) of the Law. Claimant appealed and a Referee hearing was held on March 29, 2019. On April 2, 2019, the Referee affirmed the UC Service Center’s determination. Claimant appealed to the UCBR which, on May 8, 2019, adopted the Referee’s findings and conclusions and affirmed the Referee’s decision. Claimant appealed to this Court.3 Initially,

Section 402(e) of the Law provides that an employee is ineligible for [UC] benefits when his unemployment is due to discharge from work for willful misconduct connected to his work. The employer bears the burden of proving willful misconduct in a[] [UC] case. Willful misconduct has been defined as (1) an act of wanton or willful disregard of the employer’s interest; (2) a deliberate violation of the employer’s rules; (3) a disregard of standards of behavior

3 “Our scope of review is limited to determining whether constitutional rights were violated, whether an error of law was committed, or whether the findings of fact were unsupported by substantial evidence. Section 704 of the Administrative Agency Law, 2 Pa.C.S. § 704.” Turgeon v. Unemployment Comp. Bd. of Review, 64 A.3d 729, 731 n.3 (Pa. Cmwlth. 2013).

2 which the employer has a right to expect of an employee; or (4) negligence indicating an intentional disregard of the employer’s interest or a disregard of the employee’s duties and obligations to the employer.

Sipps v. Unemployment Comp. Bd. of Review, 181 A.3d 479, 481 (Pa. Cmwlth. 2018) (quoting Dep’t of Transp. v. Unemployment Comp. Bd. of Review, 755 A.2d 744, 747 n.4 (Pa. Cmwlth. 2000) (citation and emphasis omitted)).

Where willful misconduct is based upon the violation of a work rule, the employer must establish the existence of the rule, its reasonableness, and [] the employee was aware of the rule. Once employer meets this burden, the burden shifts to the claimant to prove that the rule was unreasonable or that he had good cause for violating the rule.

Sipps, 181 A.3d at 482 (quoting Weingard v. Unemployment Comp. Bd. of Review, 26 A.3d 571, 574-75 (Pa. Cmwlth. 2011) (citation omitted)). “[T]he law is clear that habitual tardiness, particularly after warnings, is sufficient evidence to sustain a finding of willful misconduct.” Markley v. Unemployment Comp. Bd. of Review, 407 A.2d 144, 146 (Pa. Cmwlth. 1979). Claimant argues that the UCBR erred by concluding that Claimant committed willful misconduct. Claimant admits in his brief to this Court that he “violate[d] [Employer’s] tardiness [P]olicy which he knew would lead to his [employment] termination.” Claimant Br. at 6; see also Claimant Br. at 8. Claimant nevertheless argues that the UCBR erred by concluding that he committed willful misconduct, when his efforts on Employer’s behalf and his need for steady financial income outweighed any detriment Employer may have experienced due to his tardiness, and because Employer did not uniformly apply its Policy. At the Referee hearing, Employer’s Assistant Plant Manager Joshua Fleet (Fleet) testified that the Policy describes progressive discipline for tardiness,

3 with five occurrences in a 12-month period leading to suspension or termination.4 Fleet explained that the consequence after two occurrences was a verbal warning, three occurrences resulted in a written warning, the fourth occurrence brought a suspension, and a fifth occurrence was either another suspension or discharge. See N.T. at 6-7. Fleet recalled that Claimant was late for work on June 3, August 8, 11, 17, 18, 19, 20 and 21, October 27, December 9, 22 and 27, 2018, and January 5, 20 and 29, 2019. See N.T. at 7-12. Fleet declared that Employer suspended Claimant after the October 27, 2018 incident. See N.T. at 11. Fleet further recounted that Employer issued Claimant a written warning on December 22, 2018, stating that his next tardy incident within 90 days would result in his discharge. See id. Claimant thereafter violated the warning on December 27, 2018, January 5 and 20, 2019.5 See id. Claimant was also late on January 29, 2019, the day Fleet had already planned to terminate Claimant’s employment for tardiness. See N.T. at 8, 12. Fleet related that Claimant’s tardiness does not affect Employer’s productivity but, rather, required the employee who worked the previous shift to continue to work until Claimant reported to work and for Employer to pay overtime. See N.T. at 15-16. Claimant testified that he worked 12-hour shifts for Employer, from 6:00 a.m. to 6:00 p.m., rotating two or three days on and two days off.6 Claimant admitted that he was tardy on the specified days and, except for January 20, 2019, when he was delayed due to a flat tire, he was late for work because of traffic or because he overslept. See N.T. at 13-14.

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Related

Weingard v. Unemployment Compensation Board of Review
26 A.3d 571 (Commonwealth Court of Pennsylvania, 2011)
Sipps v. Unemployment Comp. Bd. of Review
181 A.3d 479 (Commonwealth Court of Pennsylvania, 2018)
Sanders v. Unemployment Compensation Board of Review
739 A.2d 616 (Commonwealth Court of Pennsylvania, 1999)
Ductmate Industries, Inc. v. Unemployment Compensation Board of Review
949 A.2d 338 (Commonwealth Court of Pennsylvania, 2008)
Turgeon v. Unemployment Compensation Board of Review
64 A.3d 729 (Commonwealth Court of Pennsylvania, 2013)
Markley v. Commonwealth
407 A.2d 144 (Commonwealth Court of Pennsylvania, 1979)

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Bluebook (online)
K. Horvath v. UCBR, Counsel Stack Legal Research, https://law.counselstack.com/opinion/k-horvath-v-ucbr-pacommwct-2020.