Proctor v. Maine Unemployment Ins. Comm'n

CourtSuperior Court of Maine
DecidedNovember 9, 2012
DocketCUMap-12-02
StatusUnpublished

This text of Proctor v. Maine Unemployment Ins. Comm'n (Proctor v. Maine Unemployment Ins. Comm'n) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Proctor v. Maine Unemployment Ins. Comm'n, (Me. Super. Ct. 2012).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss. CIVIL ACTION Docket No. AP-1~-~7 J:'j)J.()J..Nl- l ~/?D/2 MALCOLM PROCTOR,

Plaintiff,

v. ORDER

MAINE UNEMPLOYMENT INSURANCE STATE OF MAINE COMMISSION, Cumb~r!~nd. S7:>, Clerk's Offic-e

Defendant. NOV 0 J 2012 RECEIVED Before the court is plaintiff Malcolm Proctor's appeal from a November 29, 2011

decision of the Maine Unemployment Insurance Commission determining that Proctor

had voluntarily left his employment without good cause attributable to his employment

and was therefore ineligible for unemployment benefits. R. 1-6.

There are two issues raised on this appeal. The first arises from the procedural

history of the proceedings before the Commission. This involves the question of

whether good cause existed for the employer's failure to participate in a telephonic

hearing before a Hearing Officer. The second is whether, if good cause existed, there is

substantial evidence to support the Commission's decision that Proctor had voluntarily

left employment without good cause attributable to his employment.

Procedural History

Proctor left his employment with his employer, Mega Industries LLC, on October

25, 2010. The initial administrative decision of the deputy at the Bureau of Unemployment Compensation determined that Proctor's separation was voluntary and

without good cause attributable to his employment. (R. 200).

Proctor appealed that decision, and a telephonic hearing was scheduled before

an Administrative Hearing Officer on January 24, 2011. (R. 198). The hearing went

forward on that date but the employer did not participate in the hearing under

circumstances discussed below. In the absence of any participation by the employer, the

hearing officer decided the case based solely on the evidence presented by Proctor and

reversed the deputy's decision, concluding that Proctor had left his employment with

good cause attributable to his employment. (R. 155-58).

The employer than appealed to the Commission, arguing that there had been

good cause for its failure to participate in the telephonic hearing. (R. 10-12). The

Commission determined, pursuant to 12-172 C.M.R. Ch. 5 § 1(B)(1)(b), that the

employer had shown good cause for its failure to participate in the telephonic hearing.

Having found good cause, the Commission then conducted a hearing on the

substantive issues, see ~ and determined that Proctor had voluntarily left his

employment without good cause attributable to that employment. (R. 1-5).

Good Cause

Proctor argues that the Commission erred in determining that the employer had

shown good cause for its failure to participate by telephone. The applicable rule

provides in pertinent part as follows:

B. Disposition without full hearing.

1. The commission or the Division of Administrative Hearings may make informal disposition of any adjudicatory proceeding by default when the appealing party fails to appear at the scheduled hearing, provided notice of the consequences of such

2 failure to appear has been given said party. Any such default may be set aside by the commission or Division of Administrative Hearings for good cause shown. The procedure for good cause hearings is as follows:

a. Upon written request setting forth the reasons for failing to appear, the Division of Administrative Hearings may provide a good cause hearing to the appealing party that failed to appear at the hearing before the Division of Administrative Hearings. If the Division of Administrative Hearings determines that good cause exists, it will conduct a hearing on the underlying substantive issues. Similarly, upon written request setting forth the reasons for failing to appear at a Commission hearing, the Commission may provide a good cause hearing to the appealing party that failed to appear. A hearing on the underlying substantive issues shall be conducted only if the Commission determines that good cause exists.

b. Upon written request setting forth the reasons for failing to appear, the Commission may provide a good cause hearing to the non- appealing party that failed to appear before the Division of Administrative Hearings. If the Commission determines that good cause exists, it will conduct a hearing on the underlying substantive issues.

12-172 C.M.R. Ch. 5 § 1(B)(1). Because the employer was the non-appealing party in this

case section 1(B)(1)(b) of the rule is applicable.

The evidence before the Commission on this issue was that the employer had

been available and waiting to participate in the January 24, 2011 telephonic hearing but

that - for some technical reason - the Hearing Officer's attempt to telephone the

employer had been blocked by call blocking. The employer receives business calls on

that telephone line, had not instituted call blocking, and was unaware that any call

3 blocking would be in effect. Moreover, the employer attempted to call the Hearing

Officer when no telephone call was received but was told that the hearing officer was in

a hearing and could not be disturbed. (R. 23).

Proctor argues that the employer should have been aware of the potential for call

blocking because the notice given for the January 24, 2011 telephonic hearing included

language informing participants that they should contact their telephone company

before the hearing "as many telephone companies automatically block these types of

calls." (R. 198).

Based on that notice the Commission could have found that the employer had

not shown good cause for its failure to participate. However, as was noted at the

Commission hearing, the Commission has a standard practice - notwithstanding the

notice referred to by Proctor - of treating as excusable the first occasion that a party fails

to participate because of inadvertent call blocking. (R. 26-27). 1 It was within the

Commission's discretion to follow that practice in this case.

Proctor also argues that the Commission's determination in this case is

inconsistent with the definition of "good cause" found at 12-172 C.M.R. ch. 1 § 1(T).

That definition reads as follows:

For the purposes of the Employment Security Law and regulations, the Commission determines that "good cause" shall be when the unemployed individual is ill, or when illness of the unemployed individual's spouse or children, or parents, or stepparents, brothers or sisters, or relatives who have been acting in the capacity of a parent of either the claimant or spouse, require his or her presence; or he or she is in attendance at a funeral of such relative; or required by religious conviction to observe a religious holiday; or

1 The Commission's practice recognizes that parties have no reason to know that, even though they do not have call blocking and their phones receive all other kinds of calls, calls from hearing officers in unemployment cases are somehow routed to call blocking. On this issue, it also bears emphasis that the notice of the telephonic hearing stated that call blocking would be treated as a failure to appear that "may" result in dismissal of the appeal. (R. 198).

4 required by law to perform either a military or civil duty; or other cause of a necessitous and compelling nature. Incarceration as a result of a conviction for a felony or misdemeanor is excluded from the definition of "good cause."

(emphasis added).

There are two problems with Proctor's argument. The first is that the definition

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