McKean-Coffman v. Employment Division

824 P.2d 410, 312 Or. 543, 1992 Ore. LEXIS 3
CourtOregon Supreme Court
DecidedJanuary 3, 1992
DocketEAB 89-AB-1298; CA A62926; SC S37747
StatusPublished
Cited by47 cases

This text of 824 P.2d 410 (McKean-Coffman v. Employment Division) is published on Counsel Stack Legal Research, covering Oregon Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McKean-Coffman v. Employment Division, 824 P.2d 410, 312 Or. 543, 1992 Ore. LEXIS 3 (Or. 1992).

Opinion

*545 VANHOOMISSEN, J.

This case involves a question of statutory construction. Marcia McKean-Coffman (claimant) seeks review of a Court of Appeals’ decision affirming an Employment Appeals Board (EAB) holding that she is disqualified from receiving unemployment benefits because she received her vested retirement fiinds in a lump sum payment when her employment was terminated. McKean-Coffman v. Employment Div., 104 Or App 345, 801 P2d 858 (1990). The issue is whether, within the meaning of ORS 657.205(1), an unemployment compensation claimant to whom retirement funds have been paid in a lump sum “received” a retirement “payment” where she timely rolled the funds over into an Individual Retirement Account (IRA). We conclude that such a claimant is not disqualified. We reverse the Court of Appeals’ decision and remand this case to EAB for a new determination of unemployment benefits.

Claimant worked as a secretary for a financial institution (employer) from 1984 to 1989. In June 1989, she was discharged by employer because her job description was changed and she was unable to become trained in- her new position. Employer told claimant that her vested retirement funds of $8,334 would be paid to her and that she had the option of receiving the funds in a lump-sum or in periodic payments. 1 Because of the adverse tax consequences to claimant if she had elected to receive periodic payments, claimant elected to receive her retirement funds in a lump sum, which she then rolled over into an IRA within the time allowed by federal tax law. 2 Claimant thereafter submitted a claim for unemployment benefits. ORS 657.150 et seq. 3

*546 The Employment Division (Division) denied claimant unemployment benefits on the ground that she had received a lump sum payment of retirement funds when her employment terminated, which she could have received in the form of periodic payments, and that if she had elected to receive the funds in periodic payments they would have exceeded the weekly benefit amount to which she otherwise would have been entitled. In other words, the mere availability of that option permitted the Division to treat claimant as though she had elected to receive the distribution in the form of periodic payments. The Division relied on ORS 657.205 4 and OAR 471-30-020. 5

Claimant requested a hearing. She argued that she had not “received” her retirement funds within the meaning of ORS 657.205 and OAR 471-30-020, but merely had rolled them over into another qualified retirement program. She asserted that the Division should not have considered her retirement funds in determining her eligibility for unemployment benefits. The referee set aside the Division’s denial, explaining:

*547 “Neither [ORS 657.205 nor OAR 471-30-020] apply in this case. Claimant did not retire from employer, she was discharged. She did not receive a pension or lump-sum settlement, merely rolled over her potential retirement fund into another retirement fund. This action shall not constitute a receipt of a lump-sum payment pursuant to a retirement. It would be an abuse of the referee’s descretion [sic] to apply the above rule and statute to deny claimant benefits under the facts of this case.”

On the Division’s application for review, EAB adopted the referee’s findings. EAB agreed, however, with the Division’s interpretation of the statute:

“Under ORS 657.205, retirement pay is disqualifying if payment is received under a plan maintained or contributed to by a base year employer of the individual. In the case at hand, [employer] was the base year employer. That employer did contribute to a plan under which the payment in issue was received by the claimant. The statute disqualfies [sic] the claimant.
“* * * The claimant received retirement pay. Whatever the claimant chose to do with that lump sum payment would not avoid the disqualification.”

Accordingly, EAB set aside the referee’s decision.

The Court of Appeals affirmed. It stated:

“For purposes of ORS 657.205, it is irrelevant what a claimant actually does with the funds after receipt. She could have elected to keep the funds in the original retirement plan, in which case she would not have ‘received’ them. However, she elected to withdraw the funds, and held them for two weeks before rolling them over into the IRA. She did receive them. Whatever claimant chose to do with the funds after having actually received them is not relevant.” McKean-Coffman v. Employment Div., supra, 104 Or App at 348-49 (footnote omitted).

We review to determine whether EAB has erroneously interpreted a provision of law. 6

*548 The question before this court is one of first impression. The question is whether, within the meaning of ORS 657.205, claimant has “received a governmental or other pension, retirement or retired pay, annuity, or other similar periodic payment” which would reduce or eliminate the unemployment benefits that she otherwise would be entitled to receive.

Claimant argues that the disbursal of her retirement funds by employer followed by her timely rollover of the funds into an IRA is tantamount to a simple transfer of funds from one qualified retirement plan to another. Thus, she asserts she did not “receive” those funds within the meaning of ORS 657.205, because she does not now have the funds available to her for her immediate use without incurring a substantial early withdrawal penalty. She argues further that the Division’s interpretation would produce an absurd result that is contrary to state and federal tax policy. Finally, claimant argues that EAB erred in its construction of ORS 657.205 by applying the statute to retirement benefits that are not received in “periodic payments,” and by applying the statute to persons who are not retired.

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Bluebook (online)
824 P.2d 410, 312 Or. 543, 1992 Ore. LEXIS 3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mckean-coffman-v-employment-division-or-1992.