Pettry v. Ohio Dept. of Job & Family Servs.

2023 Ohio 4350
CourtOhio Court of Appeals
DecidedDecember 4, 2023
Docket23CA011937
StatusPublished

This text of 2023 Ohio 4350 (Pettry v. Ohio Dept. of Job & Family Servs.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pettry v. Ohio Dept. of Job & Family Servs., 2023 Ohio 4350 (Ohio Ct. App. 2023).

Opinion

[Cite as Pettry v. Ohio Dept. of Job & Family Servs., 2023-Ohio-4350.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF LORAIN )

BEANITA DOUGLAS C.A. No. 23CA011937

Appellant

v. APPEAL FROM JUDGMENT ENTERED IN THE DIRECTOR, OHIO DEPT. OF JOB & COURT OF COMMON PLEAS FAMILY SERVICES, et al. COUNTY OF LORAIN, OHIO CASE No. 22-CV-205348 Appellees

DECISION AND JOURNAL ENTRY

Dated: December 4, 2023

HENSAL, Presiding Judge.

{¶1} Beanita Pettry, fka Beanita Douglas, appeals an order of the Lorain County

Court of Common Pleas that affirmed a determination of the Unemployment Compensation

Review Commission (“UCRC”). This Court affirms.

I.

{¶2} Ms. Pettry’s employment with Rite Aid was terminated after she provided

information about gift cards to an individual who impersonated another Rite Aid employee

in the course of a financial scam. Ms. Pettry applied for unemployment benefits, but her

application was initially disallowed based on the conclusion that she was discharged with

just cause. Ms. Pettry appealed the initial determination, and the disallowance of her

application was affirmed. Ms. Pettry appealed the redetermination to the UCRC under

Revised Code Section 4141.281. The hearing officer determined that although Ms. Pettry 2

“was the victim of a well-executed scam,” she violated Rite Aid’s policy addressing

prepaid payment cards, which led to a substantial monetary loss. Based on that conclusion,

the hearing officer affirmed the redetermination and disallowed her application for

benefits. Ms. Pettry requested review of the hearing officer’s determination by the UCRC.

The UCRC allowed the request but affirmed the hearing officer’s decision.

{¶3} Ms. Pettry appealed the UCRC’s decision to the Lorain County Court of

Common Pleas as permitted by Section 4141.282. The trial court concluded that the

determination that Ms. Pettry was discharged for just cause was supported by competent,

credible evidence and that the UCRC’s decision was not unlawful, unreasonable, or against

the manifest weight of the evidence. Ms. Pettry appealed.

II.

ASSIGNMENT OF ERROR

THE DECISION OF THE UCRC HEARING OFFICER IS ERRONEOUS IN THAT IT IS UNLAWFUL, UNREASONABLE, AND AGAINST THE MANIFEST WEIGHT OF THE EVIDENCE.

{¶4} Ms. Pettry’s assignment of error argues that the conclusion that she was

discharged for just cause is unlawful, unreasonable, and against the manifest weight of the

evidence. This Court does not agree.

{¶5} A decision by the UCRC that a claimant was discharged with just cause can

be reviewed by the court of common pleas, and “[i]f the court finds that the decision of the

commission was unlawful, unreasonable, or against the manifest weight of the evidence, it

shall reverse, vacate, or modify the decision, or remand the matter to the commission.

Otherwise, the court shall affirm the decision of the [UCRC].” Williams v. Ohio Dept. of 3

Job and Family Servs., 129 Ohio St.3d 332, 2011-Ohio-2897, ¶ 20, quoting R.C.

4141.282(H). This power of review is “limited,” and as such, a reviewing court cannot

make factual findings or determine the credibility of witnesses. Irvine v. State Unemp.

Comp. Bd. of Rev., 19 Ohio St.3d 15, 18. This Court must apply the same standard of

review to just-cause determinations by the UCRC. Durgan v. Ohio Bur. of Emp. Servs.,

110 Ohio App.3d 545, 551 (9th Dist.1996), citing Tzangas, Plakas & Mannos v. Ohio Bur.

of Emp. Servs, 73 Ohio St.3d 694, 696-697 (1995).

{¶6} Under Section 4141.29(D)(2)(a), no individual who has “quit work without

just cause or has been discharged for just cause in connection with the individual’s work”

may receive unemployment compensation. “Just cause” means “that which, to an

ordinarily intelligent person, is a justifiable reason for doing or not doing a particular act.”

Irvine at 17, quoting Peyton v. Sun T.V. & Appliances, 44 Ohio App.2d 10, 12 (10th

Dist.1975). When considering whether an employee has been terminated for just cause,

“[f]ault on behalf of the employee is an essential component[.]” Tzangas at paragraph two

of the syllabus. The existence of fault, however, “cannot be rigidly defined” and must be

evaluated with consideration for the facts in each case. Id. at 698, citing Irvine at 17. As

the Supreme Court of Ohio has explained,

The [Unemployment Compensation] Act does not exist to protect employees from themselves, but to protect them from economic forces over which they have no control. When an employee is at fault, he is no longer the victim of fortune’s whims, but is instead directly responsible for his own predicament. Fault on the employee’s part separates him from the Act’s intent and the Act’s protection. Thus, fault is essential to the unique chemistry of a just cause termination. 4

Id. at 697-698. Fault denotes culpability on the part of the employee. Sprowls v. Ohio

Dept. of Job & Family Servs., 156 Ohio App.3d 513, 2004-Ohio-1317, ¶ 22. “A mere

causal nexus between the termination and some circumstance or condition affecting the

employee is insufficient to show that the termination was for just cause.” Id. Conversely,

“the employee must * * * demonstrate[e] he [or she] was without fault in the incident

resulting in his termination to show he is entitled to unemployment compensation.”

(Emphasis added.) Clucas v. RT 80 Express, Inc., 9th Dist. Lorain No. 11CA009989, 2012-

Ohio-1259, ¶ 7, citing Irvine at 17.

{¶7} Ms. Pettry has argued that the hearing officer’s conclusion that she violated

company policy is against the manifest weight of the evidence and that the record does not

support the conclusion that she was at fault in the incident that led to her discharge. The

hearing officer determined that Ms. Pettry violated Rite Aid’s policy regarding prepaid

cards, which includes Rite Aid gift cards. According to the hearing officer, that policy

“states that Rite Aid employees must never attempt to activate or provide a prepaid card

account number or PIN if being instructed to do so by an incoming phone call.” The

hearing officer also noted that the policy provides for disciplinary action up to and

including termination of employment for violations, and the hearing officer observed that

Ms. Pettry had been trained on the policy. The hearing officer found that on July 15, 2021,

a person called the store where Ms. Pettry worked, impersonated another Rite Aid

employee, and instructed Ms. Pettry to call another phone number to help resolve a prepaid

card scam. The individual instructed Ms. Pettry to act quickly. When she complied, a

different individual instructed Ms. Pettry to “go to a register, scan seven prepaid cards, and 5

put a certain amount of funds on each card. He also asked for the transaction and PIN

numbers on the cards, which [she] provided. [Ms. Pettry] placed a total of $3,368.65 on

the seven prepaid cards.” The hearing officer noted that Ms. Pettry did not believe that she

was activating gift cards and explained that shortly after the incident, Ms. Pettry was

notified that the store had been scammed. Ms. Pettry’s employment was terminated on

July 23, 2021.

{¶8} As the hearing officer explained, Rite Aid has a policy addressing prepaid

cards, including Rite Aid gift cards. That policy applies to all employees, and it provides:

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Related

Williams v. Ohio Department of Job & Family Services
2011 Ohio 2897 (Ohio Supreme Court, 2011)
Charles Livingston & Sons, Inc. v. Constance
185 N.E.2d 655 (Ohio Court of Appeals, 1962)
Sprowls v. Ohio Department of Job & Family Services
806 N.E.2d 1030 (Ohio Court of Appeals, 2004)
Peyton v. Sun T v. & Appliances
335 N.E.2d 751 (Ohio Court of Appeals, 1975)
Durgan v. Ohio Bureau of Employment Services
674 N.E.2d 1208 (Ohio Court of Appeals, 1996)
Irvine v. State
482 N.E.2d 587 (Ohio Supreme Court, 1985)
Tzangas, Plakas & Mannos v. Administrator
73 Ohio St. 3d 694 (Ohio Supreme Court, 1995)

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2023 Ohio 4350, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pettry-v-ohio-dept-of-job-family-servs-ohioctapp-2023.