L.C. v. Board of Review, Department of Labor and Lakeland Bank

110 A.3d 949, 439 N.J. Super. 581, 2015 N.J. Super. LEXIS 39
CourtNew Jersey Superior Court Appellate Division
DecidedMarch 16, 2015
DocketA-5997-12
StatusPublished
Cited by2 cases

This text of 110 A.3d 949 (L.C. v. Board of Review, Department of Labor and Lakeland Bank) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
L.C. v. Board of Review, Department of Labor and Lakeland Bank, 110 A.3d 949, 439 N.J. Super. 581, 2015 N.J. Super. LEXIS 39 (N.J. Ct. App. 2015).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-5997-12T2

L.C.,1

Appellant, APPROVED FOR PUBLICATION

v. March 16, 2015

APPELLATE DIVISION BOARD OF REVIEW, DEPARTMENT OF LABOR and LAKELAND BANK,

Respondent. ______________________________

Submitted January 21, 2015 – Decided March 16, 2015

Before Judges Messano, Ostrer and Hayden.

On appeal from the Board of Review, Department of Labor, Docket No. 423,182.

L.C., appellant pro se.

John J. Hoffman, Acting Attorney General, attorney for respondent Board of Review (Lewis A. Scheindlin, Assistant Attorney General, of counsel; Adam Verone, Deputy Attorney General, on the brief).

Respondent Lakeland Bank has not filed a brief.

1 As this appeal addresses plaintiff's claim she was a victim of domestic violence, we refer to her and other parties by their initials, consistent with our practice in cases involving domestic violence complaints. The opinion of the court was delivered by

OSTRER, J.A.D.

In this unemployment insurance appeal, we construe N.J.S.A.

43:21-5(j), which allows a person to receive unemployment

insurance benefits when he or she has quit work for reasons

related to domestic violence. L.C. claimed she quit her job at

Lakeland Bank and moved to Utah to flee an abusive ex-spouse.

Since 1961, our unemployment insurance laws have generally

disqualified claimants from receiving benefits if they "left

work voluntarily without good cause attributable to such work."

L. 1961, c. 43, §3, codified at N.J.S.A. 43:21-5(a). Personal

reasons for quitting unrelated to work, regardless of how

compelling, have not warranted benefits. Self v. Bd. of Review,

91 N.J. 453, 456-57 (1982). However, in 2000, the Legislature

created an exception for workers who leave work because they are

victims of domestic violence. L. 1999, c. 391, § 1 (1999 Law),

codified at N.J.S.A. 43:21-5(j).

L.C. argues that the Board of Review (Board) misapplied the

1999 Law in denying her claim for benefits. The Board affirmed

the determination of the Appeal Tribunal (Tribunal) that L.C.

had presented insufficient evidence that she was a victim of

domestic violence. The Board did not consider a letter from

L.C.'s divorce lawyer, identifying various acts of domestic

2 A-5997-12T2 violence by her estranged husband. As we conclude the Board

should consider a certification from L.C.'s attorney under the

1999 Law, we reverse and remand for a new hearing.

I.

In February 2013, after almost six years on the job, L.C.

gave Lakeland Bank two weeks' notice that she was resigning as a

loan processor. On March 17, 2013, she filed her unemployment

claim. The deputy denied her claim as a voluntary quit without

good cause attributable to work. L.C. appealed, claiming

protection under the 1999 Law.

The statute includes two essential elements. First, a

claimant must establish that he or she is a victim of domestic

violence as defined in the Prevention of Domestic Violence Act

(PDVA), N.J.S.A. 2C:25-19. Second, the claimant must establish

that the loss of employment, by quitting or discharge, was

causally related to being a victim. The key statutory provision

states: "Notwithstanding any other provisions of this chapter

. . . no otherwise eligible individual shall be denied benefits

because the individual left work or was discharged due to

circumstances resulting from the individual being a victim of

domestic violence as defined in section 3 of P.L.1991, c.261

(C.2C:25-19)." N.J.S.A. 43:21-5(j). Employers' accounts are

unaffected. Ibid.

3 A-5997-12T2 The statute identifies six categories of evidence that

suffice as proof of victimization. At issue in our case is the

sixth category, which refers to "documentation or certification"

from various professionals who have "assisted the individual in

dealing with the domestic violence." Ibid.

For the purposes of this subsection (j), the individual shall be treated as being a victim of domestic violence if the individual provides one or more of the following:

(1) A restraining order or other documentation of equitable relief issued by a court of competent jurisdiction;

(2) A police record documenting the domestic violence;

(3) Documentation that the perpetrator of the domestic violence has been convicted of one or more of the offenses enumerated in section 3 of P.L.1991, c.261 (C.2C:25-19);

(4) Medical documentation of the domestic violence;

(5) Certification from a certified Domestic Violence Specialist or the director of a designated domestic violence agency that the individual is a victim of domestic violence; or

(6) Other documentation or certification of the domestic violence provided by a social worker, member of the clergy, shelter worker or other professional who has assisted the individual in dealing with the domestic violence.

[Ibid.]

4 A-5997-12T2 The Tribunal hearing was conducted in two sessions on May

28 and May 30, 2013. The only witnesses were L.C.; her friend,

D.S.; and her former supervisor, M.M. They all appeared by

telephone.

The witnesses testified without dispute that L.C.'s husband

humiliated her, damaged her property, and physically assaulted

her. L.C. testified that she and her husband began living

separately in their home in late 2011 or early 2012. She often

stayed in the homes of friends. In February or March 2012, she

sought permission from the court to relocate with their teenage

children. Her husband responded a few months later by filing

for divorce. The proceedings that followed were contentious.

L.C. testified that her husband forced her to sleep in the

basement in a sleeping bag. She was also subjected to

demeaning, coarse, and insulting language from her husband and,

at her husband's instigation, her children. One morning, she

awoke to find all four of her tires flattened. She contended

she was too afraid to file a domestic violence complaint against

her husband. But, she asserted that police had to respond to

their home on multiple occasions because of their domestic

disputes.

She testified that she essentially surrendered to all her

husband's demands in the divorce action, including his request

5 A-5997-12T2 for sole custody of their children, and sole possession of the

marital home. The divorce was finalized on March 12, 2013, one

day after L.C.'s last day on the job at Lakeland Bank. L.C.

moved to Utah the following week. L.C. stated, "I left with

nothing but my clothes."

D.S. testified that while L.C.'s divorce action was

pending, L.C. would often sleep at her house, to flee

mistreatment by her husband. D.S. stated that L.C. lost about

thirty pounds, apparently related to her emotional distress.

Further, D.S. asserted that L.C.'s husband was mentally

unstable, and on one occasion, shoved L.C. around. As his

condition deteriorated, D.S. testified, "I was afraid that he

would snap and kill her."

M.M. testified that L.C. disclosed her ongoing difficulties

with her husband. M.M. confirmed that L.C. indicated to her

that she was a victim of domestic violence.

The evidence regarding the causal connection between L.C.'s

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110 A.3d 949, 439 N.J. Super. 581, 2015 N.J. Super. LEXIS 39, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lc-v-board-of-review-department-of-labor-and-lakeland-bank-njsuperctappdiv-2015.