Phillip Clay, Jr. v. Virginia Employment Commission

CourtCourt of Appeals of Virginia
DecidedJune 14, 2022
Docket1048213
StatusUnpublished

This text of Phillip Clay, Jr. v. Virginia Employment Commission (Phillip Clay, Jr. v. Virginia Employment Commission) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Phillip Clay, Jr. v. Virginia Employment Commission, (Va. Ct. App. 2022).

Opinion

COURT OF APPEALS OF VIRGINIA UNPUBLISHED

Present: Judges Russell, Friedman and Callins Argued at Salem, Virginia

PHILLIP CLAY, JR. MEMORANDUM OPINION* v. Record No. 1048-21-3 JUDGE FRANK K. FRIEDMAN JUNE 14, 2022 VIRGINIA EMPLOYMENT COMMISSION

FROM THE CIRCUIT COURT OF CAMPBELL COUNTY John T. Cook, Judge

Blake K. Huddleston (James B. Feinman; James B. Feinman & Associates, on briefs), for appellant.

Elizabeth B. Peay, Senior Assistant Attorney General (Jason S. Miyares, Attorney General; Monique A. Miles, Deputy Attorney General; Joshua N. Lief, Senior Assistant Attorney General and Chief, on brief), for appellee.

Phillip Clay, Jr. (“Clay”) appeals the circuit court’s order affirming the decision of the

Virginia Employment Commission (“VEC” or “Commission”) denying his request for

unemployment benefits. Clay’s employer initially contested his efforts to qualify for

unemployment benefits. After the employer prevailed before the deputy commissioner at the first

level of review, Clay announced his intention to pursue appellate relief. The employer then

indicated that it would not “contest benefits” going forward and that it “declines to participate

further in the appeals process.” Despite the employer’s absence from the subsequent proceedings,

the Commission continued to find that Clay was disqualified from receiving benefits, based upon

the record established before the deputy commissioner and incorporated into subsequent review.

* Pursuant to Code § 17.1-413, this opinion is not designated for publication. The circuit court upheld the VEC’s determination. Clay alleges: (1) there was insufficient evidence

to prove he committed misconduct, (2) the circuit court’s decision wrongly disregarded the

employer’s burden to prove misconduct, and (3) it was error to find that he was disqualified from

receiving benefits. Upon reviewing the record and arguments of the parties, we affirm the circuit

court’s decision.

BACKGROUND

“Like the circuit court, we must ‘consider the evidence in the light most favorable to the

findings by the Commission.’” Smith v. Va. Emp. Comm’n, 59 Va. App. 516, 520 (2012)

(quoting Va. Emp. Comm’n v. Trent, 55 Va. App. 560, 565 (2010)).

The Underlying Incident

Clay was employed as an assembly welder by BWXT Nuclear Operations Group, Inc.

(“employer”) in Lynchburg, Virginia from May 27, 2003, until his termination on June 6, 2019.

To get into the work area, employees were required to pass through a security checkpoint and

explosive detector—a safety procedure set up through the Federal Nuclear Regulatory

Commission. On May 28, 2019, Clay arrived at work; there were two turnstiles leading through

the security checkpoint, but one of them was closed. Clay, choosing not to wait in the line,

“opened a rope barrier to a roped-off area, and walked through it, on his way to an explosive

detector” despite a sign that read “Do Not Enter/Closed Strap.” His actions were caught on

video.

When hired, Clay received training on employer’s security procedures and rules. Clay

acknowledged employer’s policies, which required, among other things, that Clay comply with

security procedures. Employer’s policies indicated that some conduct was so serious it could be

cause for immediate termination, including “failure to comply with a Policy or Procedure

resulting in significant potential for personal injury, property damage, or adverse regulatory

-2- action” and “[g]ross negligence of duties, any willful violation of company policies and

procedures, or any undesirable performance.” Employer suspended Clay the same day the

offense occurred, investigated the incident, and subsequently discharged him for breach of

security measures.

The Deputy Commissioner Disqualifies Clay from Benefits.

Clay subsequently filed for unemployment benefits. Employer filed documentation

supporting its argument that Clay was disqualified for misconduct. This filing included a record

of facts explaining the security breach/misconduct. The facts presented relating to the rule

violation were largely undisputed. The employer explained the discharge as follows:

This is a nuclear facility. All safety procedures and protocols are set through the Federal Nuclear Regulatory Commission. On 5/28/19 he pulled one of those rope barriers that said do not enter down and entered the metal detector area. It’s a secured facility and that line was closed. You have to pass through the security guards. This was a breech [sic] of security and he was terminated. He did not have authorization to go through the line. This was observed on video. . . . You cannot just walk through a barrier at a secured nuclear facility on your own.

For his part, Clay gave a very candid description of his conduct:

I went through a security barrier without permission. It’s one of those rope line barriers. Ussually [sic] the security guard waives me through. On this day no security guard waived me through. I onpened [sic] the barrier (even though it said this lane closed) and headed for the bomb and metal detector area. I did not thing [sic] I had done anything wrong. This was the only time I did it without authorization from the security guard . . . I agree I did not have permission on that day to go through it. I was not in a hurry. I was not late I just thought I was doing security a favor.

Here, Clay acknowledged that he had crossed the barrier without authorization, he had never

done so before without permission, and the line was marked closed.

Based on the record, a deputy commissioner found that Clay was discharged for a

violation of the employer’s policy. The deputy concluded that Clay was disqualified from

-3- receiving unemployment benefits because the evidence was “sufficient to establish that Clay was

discharged due to misconduct in connection with work.” Clay appealed the deputy

commissioner’s decision to an appeals examiner.

When Clay Challenges the Deputy Commissioner’s Ruling, the Evidence from the Initial Hearing is Made a Part of the Record on Appeal.

In connection with his appeal of the deputy’s denial of benefits, Clay sought a subpoena

seeking documents from employer detailing similar incidents and related discipline of other

employees for similar offenses. The request was denied by the examiner—although the ruling

left open the possibility that the discovery request could be revisited if necessary. No request to

reopen the issue was ever pursued.

Subsequently, rather than appear for the appeal, employer notified the VEC that it “does

not contest benefits in the above referenced matter. As such, the Respondent respectfully

declines to participate further in the appeals process.” The employer, consistent with this notice,

did not appear at the appeal proceedings before the appeals examiner or the VEC, nor did it file

any additional documentation.

At the appeal before the appeals examiner, Clay was the only live witness. He confirmed

again that he had passed through the barrier without security’s approval. He indicated that he

was not aware of a rule he had violated and there was no signage telling him not to breach the

barrier. He also claimed that he and others had “bypassed the straps” in the past and had not

been discharged. The appeals examiner considered Clay’s testimony along with the underlying

record from below. He determined that although the employer had failed to appear to contest the

benefits, the record made plain that Clay had violated the work rule and breached security. He

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Related

Smith v. Virginia Employment Commission
721 S.E.2d 18 (Court of Appeals of Virginia, 2012)
Williamson v. Virginia Employment Commission
690 S.E.2d 304 (Court of Appeals of Virginia, 2010)
Virginia Employment Commission v. Trent
687 S.E.2d 99 (Court of Appeals of Virginia, 2010)
McNamara v. Virginia Employment Commission
681 S.E.2d 67 (Court of Appeals of Virginia, 2009)
Logan v. Commonwealth
622 S.E.2d 771 (Court of Appeals of Virginia, 2005)
Carolyn M. Snyder v. VEC and Blue Shield, etc.
477 S.E.2d 785 (Court of Appeals of Virginia, 1996)
Commonwealth, DSS v. James Flaneary
469 S.E.2d 79 (Court of Appeals of Virginia, 1996)
Israel v. Virginia Employment Commission
372 S.E.2d 207 (Court of Appeals of Virginia, 1988)
Whitt v. Race Fork Coal Corp.
441 S.E.2d 357 (Court of Appeals of Virginia, 1994)
Branch v. Virginia Employment Commission & Virginia Chemical Co.
249 S.E.2d 180 (Supreme Court of Virginia, 1978)
Virginia Employment Commission v. Gantt
376 S.E.2d 808 (Court of Appeals of Virginia, 1989)
Ford Motor Co. v. Unemployment Compensation Commission
63 S.E.2d 28 (Supreme Court of Virginia, 1951)
Craft v. Virginia Employment Commission
383 S.E.2d 271 (Court of Appeals of Virginia, 1989)
Brady v. Human Resource Institute of Norfolk, Inc.
340 S.E.2d 797 (Supreme Court of Virginia, 1986)

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