Silva v. Kansas Employment Security Bd. of Review

CourtCourt of Appeals of Kansas
DecidedAugust 29, 2025
Docket127811
StatusUnpublished

This text of Silva v. Kansas Employment Security Bd. of Review (Silva v. Kansas Employment Security Bd. of Review) is published on Counsel Stack Legal Research, covering Court of Appeals of Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Silva v. Kansas Employment Security Bd. of Review, (kanctapp 2025).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 127,811

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

JOE EDWARD SILVA, Appellee,

v.

KANSAS EMPLOYMENT SECURITY BOARD OF REVIEW, Appellant.

MEMORANDUM OPINION

Appeal from Sedgwick District Court; ERIC COMMER, judge. Submitted without oral argument. Opinion filed August 29, 2025. Reversed.

Jessica A. Bryson, special assistant attorney general, Kansas Department of Labor, for appellant.

No appearance by appellee.

Before SCHROEDER, P.J., HILL and GARDNER, JJ.

PER CURIAM: The Kansas Employment Security Board of Review (the Board) appeals the Sedgwick County District Court's order that held Joe Edward Silva was entitled to unemployment assistance benefits. The Board argues that this decision was in error because the district court misinterpreted several applicable statutes. Silva did not file a brief on appeal. After review, we reverse the district court and affirm the Board's decision.

1 FACTUAL AND PROCEDURAL BACKGROUND

Since 1982, Silva was employed with Silva Security Service, a Wichita business owned and operated by Silva's father. His responsibilities included the sale and installation of ATMs.

According to Silva, in November 2020 he was hospitalized for sclerosis of the liver, complications from Hepatitis C, and upper gastrointestinal bleeding. In early December 2020, Silva was released from the hospital into hospice care in hopes of getting a liver transplant. He never returned to work.

While in hospice care, Silva, with the help of his social workers and hospice nursing staff, repeatedly made attempts to file for unemployment benefits through the Kansas Department of Labor (the agency). But Silva did not successfully file a claim until October 2021, so his benefit year was established as beginning October 3, 2021, per statute. He reported his last day of work at Silva Security as November 27, 2020. The application process informed Silva that he must seek work, which included applying for jobs, to receive benefits.

In October 2021, Silva participated in a telephone interview with an agency representative. During that interview, Silva told the representative that he had quit his job with Silva Security because of medical issues; that he was unable to work due to that medical issue as of November 20, 2020, which was his last day of work; and that his healthcare provider had not released him to work but recommended bedrest.

Silva filed several weekly claims for regular unemployment benefits for the weeks ending October 23, 2021, through January 15, 2022. These weekly claims for benefits are required to be filed each week the claimant is unemployed. Each weekly claim asks three questions: during the week being claimed, were you able to work; were you available to

2 work; and did you look for work. The application requires claimants to certify that the information they provide is complete, correct and true to the best of their knowledge and belief.

Silva also submitted a "Health Care Provider's Certification" to the agency. This form is used to determine whether a claimant is entitled to unemployment benefits when their departure from work is due to medical reasons. The form was filled out by Silva's health care provider, Rick Friesen. The form asked: "Did you advise claimant to leave work?" and Friesen checked the box indicating "no." He then wrote to the side: "I haven't seen him for this condition [illegible]." The signature on this note is dated December 13, 2021, and was filed with the agency on December 15, 2021. Although Friesen indicated he was not the provider who had advised Silva to leave work, he indicated Silva became unable to work on December 5, 2020, and it was unknown when Silva would be able to return to full-time work.

The form asked the certifying medical provider to describe the medical condition in lay terms. Friesen wrote "weakness, dizziness, nausea, mental fogginess, dysphoria, and poor work balance." Finally, Friesen checked "no" to these two questions: "Is claimant able to continue employment in customary occupation?" and "Able to work full- time in another occupation?"

Based on the answers to the questions in the weekly claims, the agency issued three Notices of Determination, each of which stated Silva was ineligible for unemployment benefits on dates beginning on December 5, 2020, October 3, 2021, and April 3, 2022. The Notice of Determination for benefits beginning December 5, 2020, stated that Silva was disqualified for benefits because he "voluntarily left work due to illness or injury" and he "was not advised to leave work by a licensed and practicing health care provider." During Silva's appeal of that determination, the referee stated this indicated that Silva was not qualified for unemployment benefits beginning on October 3,

3 2021, because he was not able to work. The Notice of Determination for benefits beginning April 3, 2022, stated that Silva was disqualified for benefits because Silva "is unable to work."

Silva appealed these determinations and participated in a telephone hearing with an agency referee in August 2023. Silva testified that around Thanksgiving 2020 he informed his employer, his father, that he was no longer able to work. According to Silva, his father wanted to continue to pay him, but Silva declined this offer because his medical condition prevented him from working and has prevented him from working since then. He also testified that because of his diagnosis and issue with his mail service, his appeal was filed about six months after the required date.

Later in August 2023, the appeals referee issued decisions on Silva's appeals. For the benefits starting December 5, 2020, the appeals referee found that Silva's excusable neglect allowed him to bring the untimely appeal. Still, Silva was disqualified from unemployment benefits because, although he had a compelling emergency to leave his employment, he had not made reasonable attempts to preserve the work before voluntarily leaving, so he did not meet the exception to disqualification in K.S.A. 44- 706(a)(11).

"The claimant had good personal reasons for voluntarily leaving the employment, but due to his medical condition, the claimant has not shown good cause attributable to the work or the employer necessary to qualify for unemployment insurance benefits. The claimant is disqualified for unemployment insurance benefits because the claimant voluntarily quit the work without good cause attributable to the work or the employer."

For the benefits starting April 3, 2022, the appeals referee found that Silva's excusable neglect allowed him to bring the untimely appeal. But again, the referee found that Silva was ineligible for unemployment benefits because he was not able or available to work. To be qualified for unemployment benefits, a claimant must be able and 4 available to work. K.S.A. 44-705(c). "Ability to work" requires a claimant show he or she is "able to perform the duties of such claimant's customary occupation or the duties of other occupations for which the claimant is reasonably fitted by training or experience." K.S.A. 44-705(c)(1). And "availability for work" is shown by "the claimant's pursuit of the full course of action most reasonably calculated to result in the claimant's reemployment." K.S.A. 44-705(c)(1).

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Silva v. Kansas Employment Security Bd. of Review, Counsel Stack Legal Research, https://law.counselstack.com/opinion/silva-v-kansas-employment-security-bd-of-review-kanctapp-2025.