S.S. LLC v. Review Board of the Indiana Department of Workforce Development

953 N.E.2d 597, 2011 Ind. App. LEXIS 1625, 2011 WL 3757633
CourtIndiana Court of Appeals
DecidedAugust 25, 2011
Docket93A02-1101-EX-56
StatusPublished
Cited by12 cases

This text of 953 N.E.2d 597 (S.S. LLC v. Review Board of the Indiana Department of Workforce Development) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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S.S. LLC v. Review Board of the Indiana Department of Workforce Development, 953 N.E.2d 597, 2011 Ind. App. LEXIS 1625, 2011 WL 3757633 (Ind. Ct. App. 2011).

Opinions

OPINION

NAJAM, Judge.

STATEMENT OF THE CASE

S.S. LLC (“S.S.”)1 appeals the decision of the Review Board of the Indiana Department of Workforce Development (“Review Board”) in favor of D.H. on her claim for unemployment benefits. S.S. raises a single issue for our review, namely, whether the Review Board erred when it concluded that D.H. was not terminated for just cause.

We affirm.

FACTS AND PROCEDURAL HISTORY

D.H. applied for unemployment compensation benefits after leaving her employment with S.S. The Indiana Department of Workforce Development issued an initial determination of benefits on July 23, 2010, [599]*599concluding that D.H. was eligible for unemployment benefits. S.S. appealed, and the Administrative Law Judge (“ALJ”) who presided over the appeal concluded that S.S. had discharged D.H. for just cause and that D.H. was not entitled to unemployment benefits. D.H. appealed to the Review Board, which made the following findings and conclusions in reversing the ALJ’s denial of benefits to D.H.:

The Review Board adopts and incorporates the findings of fact of the Administrative Law Judge except to the extent inconsistent with this decision and as modified herein. The Claimant was present and participated in the hearing by telephone. The Employer also participated in the hearing by telephone and was represented by Perry Combs, Administrator.1
[Internal footnote 1: The Review Board cannot overturn an Administrative Law Judge’s decision based solely on a determination of demeanor credibility. Stanley v. Review Bd., 528 N.E.2d 811, 815 (Ind.Ct.App.1988). Because the parties participated in the hearing by telephone, any explicit or implicit credibility determinations made by the Administrative Law Judge were not based on her observations of the witnesses’ demeanor. “[T]o make an accurate credibility assessment based on demeanor one must be in a position to observe the witnesses as they testify.” Id. No demeanor credibility determinations can be made based on the testimony offered in a telephone hearing. Because the Review Board listened to the hearing recording, the Review Board is in the same position as the Administrative Law Judge to make determinations of credibility regarding the witnesses’ testimony. Of the different components of credibility, “only demean- or credibility remains outside the reviewing authority’s abilities to assess.” Wampler v. Review Bd., 498 N.E.2d 998, 999 (Ind.Ct.App.1986). Thus, the Review Board is free to reject the Administrative Law Judge’s findings of credibility and to make its own determinations as to the credibility of the witnesses at the hearing.]
The Employer is a nursing home. The Claimant worked full-time for the Employer as an activity director. The Claimant began working for the Employer on July 28, 1997. The Claimant became separated from employment on May 24, 2010.
On May 24, 2010, the Employer’s Representative and the Assistant Director of Nursing met with the Claimant for the purpose of administering a third written warning. During the meeting, the Claimant’s employment terminated.
During the hearing, the Employer’s Representative testified that the Claimant became very upset and walked out of the meeting without permission. The Employer has a written policy in its employee handbook that states, “walking off the shift without the permission of your Supervisor will be considered a voluntary resignation.” Emp. Ex. E2. The Claimant signed an acknowledgement form indicating that she received a copy of the employee handbook and understood its contents. Emp. Ex. E3. Because the Claimant had not been given permission to leave, the Employer considered her to have voluntarily resigned her employment. The Employer’s Representative also contended that the Employer had no intention of discharging the Claimant during the meeting.
The Claimant, however, testified that she was told she was being discharged for receiving four warnings within a three week time-frame. She further testified that when she received her third written warning during the meet[600]*600ing, the warning stated that she was discharged from employment. See Emp. Ex. 4. The Claimant also testified that the Employer has a policy that states accumulating three written warnings is grounds for discharge, and she had received three written warnings. She left the meeting after the Employer’s Representative informed her that she had been relieved of her duties and asked her to leave.
Because the parties presented conflicting testimony regarding the circumstances of the Claimant’s separation from employment, the Review Board must make a credibility determination. The Review Board finds the Claimant’s testimony more credible. The Review Board also finds that the Claimant correctly testified as to the Employer’s stated reason for her discharge.
The Employer has [a] written policy in its employee handbook that states, “[A] total of three (3) written warnings of any kind, in one (1) year is cause for immediate termination.” See Emp. Ex. E4. Per the third written warning, this policy is contained on page 59 of the employee handbook. Emp. Ex. E4. Also, according to the contents of the third written warning, the Claimant received a verbal warning on March 31, 2010; a first written warning on April 15, 2010; and a second written warning on May 3, 2010. Emp. Ex. E4. On May 24, 2010, the Claimant received her third written warning and was discharged from employment. Emp. Ex. E4.
The Employer’s Representative presented no evidence regarding why the Claimant was disciplined on any occasion. The Employer’s Representative also presented no evidence regarding the enforcement of the Employer’s discipline policy.
The Administrative Law Judge found that Claimant walked out of the meeting without permission in violation of the Employer’s policy. The Administrative Law Judge determined that the Claimant knowingly violated a reasonable and uniformly enforced Employer rule. The Administrative Law Judge concluded that the Employer discharged the Claimant for just cause....
CONCLUSIONS OF LAW: An Administrative Law Judge cannot change the Employer’s stated reason for discharge. Voss v. Review Board, 533 N.E.2d 1020 (Ind.Ct.App.1989). In Foss v. Review Board, ... the employer provided its employee a written discharge document stating that the discharge was for excessive telephone usage. At the Administrative Law Judge hearing, the employer advanced other reasons to discharge the employee. The court held that the Review Board was limited to considering the employer’s stated reason for discharge. Accord: Hehr v. Review Bd., 534 N.E.2d 1122 (Ind.Ct.App.1989); Parkinson [Parkison ] v. James River Corp.,

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953 N.E.2d 597, 2011 Ind. App. LEXIS 1625, 2011 WL 3757633, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ss-llc-v-review-board-of-the-indiana-department-of-workforce-development-indctapp-2011.