Sturpe v. Unemployment Compensation Board of Review

823 A.2d 239, 25 A.L.R. 6th 635, 2003 Pa. Commw. LEXIS 283
CourtCommonwealth Court of Pennsylvania
DecidedMay 5, 2003
StatusPublished
Cited by9 cases

This text of 823 A.2d 239 (Sturpe v. Unemployment Compensation Board of Review) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sturpe v. Unemployment Compensation Board of Review, 823 A.2d 239, 25 A.L.R. 6th 635, 2003 Pa. Commw. LEXIS 283 (Pa. Ct. App. 2003).

Opinions

OPINION BY

President Judge COLINS.

Toni Sturpe petitions for review of the order of the Unemployment Compensation Board of Review (Board) denying her benefits under Section 402(b) of the Unemployment Compensation Law (Law),1 which provides that an employee is ineligible for benefits when her unemployment is the result of her voluntarily terminating her employment without a necessitous and compelling reason.

Sturpe began working for U.S. Airways as a buyer on October 24, 1988. Her husband was employed with Delta Airlines in Atlanta, Georgia, from which employment he was laid off sometime in 1994. He was recalled to work with Delta in 1996 in Fort Lauderdale, Florida, where he worked for about a year before transferring to Atlanta, Georgia for about two years, and then to Cincinnati, Ohio. Sturpe remained employed with U.S. Airways until on December 5, 2001, when she resigned, effective December 21, 2001, in order to relocate to Kentucky to be with her husband. Sturpe had no employment [242]*242commitment in Ohio or Kentucky. Continuing work with U.S. Airways was available to Sturpe in Pennsylvania.

Based on the evidence, the referee concluded that Sturpe failed to meet her burden of establishing that she left her employment for a necessitous and compelling reason because she failed to establish economic hardship in maintaining separate residences or an insurmountable commuting distance. The Board affirmed, adopting the referee’s findings and conclusions.

On appeal, Sturpe argues that the referee’s findings contain a number of errors and that he erred when he concluded that she failed to meet her burden of proving a necessitous and compelling reason for leaving her employment with U.S. Airways. Our review is limited to determining whether an error of law was committed, constitutional rights were violated, or necessary findings of fact are supported by substantial evidence. Gibson v. Unemployment Compensation Board of Review, 760 A.2d 492 (Pa.Cmwlth.2000). Substantial evidence is relevant evidence upon which a reasonable mind could base a conclusion. Feinberg v. Unemployment Compensation Board of Review, 160 Pa. Cmwlth. 524, 635 A.2d 682 (1993), petition for allowance of appeal denied, 539 Pa. 670, 652 A.2d 840 (1994). We must examine the evidence in the light most favorable to the party that prevailed before the Board, which in unemployment cases, is the ultimate fact finder. Gibson.

First we address Sturpe’s allegations of errors in the factual findings. The alleged errors are as follows: 1) the date on which Sturpe was first employed -with U.S. Airways, i.e., 1988 rather than 1998; 2) that her husband was “recalled” to work in Florida in 1996, and not “transferred”; and 3) that she remained in Pennsylvania until March 2002 and remained employed with U.S. Airways until March 2002. The Board acknowledges that the record contains no evidence that Sturpe remained in Pennsylvania until March 2002, and it acknowledges the typographical error in her employment date. We agree with the Board that these errors are harmless and have no effect on the outcome of this case.

Next we address the issue of whether Sturpe established necessitous and compelling reason for terminating her employment with U.S. Airways. An unemployment compensation claimant who has voluntarily terminated her employment may still be entitled to benefits if she shows that she left for a necessitous and compelling reason. Livingston v. Unemployment Compensation Board of Review, 702 A.2d 20 (Pa.Cmwlth.1997). “Necessitous and compelling reason” refers to real and substantial circumstances that force the employee to terminate employment and that would compel a reasonable person under those circumstances to act in the same manner. Id. Whether an employee had a necessitous and compelling reason to leave her employment is a question of law reviewable by this Court. Taylor v. Unemployment Compensation Board of Review, 474 Pa. 351, 378 A.2d 829 (1977).

Where a claimant terminates employment to join a relocating spouse, the claimant must demonstrate an economic hardship in maintaining two residences or that the move has posed an insurmountable commuting problem. Glen Mills Schools v. Unemployment Compensation Board of Review, 665 A.2d 561 (Pa. Cmwlth.1995); Hammond v. Unemployment Compensation Board of Review, 131 Pa.Cmwlth. 166, 569 A.2d 1013 (1990). The claimant must also show that her resignation was the direct result of her spouse’s relocation, i.e., the necessity to relocate must be caused by circumstances beyond the control of the claimant’s spouse [243]*243and not by personal preference, and the decision to relocate must be reasonable and be made in good faith. Id. These principles reflect the General Assembly’s intent to permit the obligation of joining one’s spouse, under the proper circumstances, to constitute cause of a necessitous and compelling nature to leave one’s employment. Id. The desire to maintain the family unit is not by itself sufficient cause to terminate one’s employment and receive benefits. Schechter v. Unemployment Compensation Board of Review, 89 Pa.Cmwlth. 24, 491 A.2d 938 (1985).

In Hammond, which is factually similar to the present case, the claimant and his ■wife maintained separate residences and endured commuting problems for one year when he was in Pennsylvania and she was in Mississippi. Because the commuting problem and successful maintenance of separate residences predated his spouse’s move to Oregon and the claimant’s termination of his employment to join his spouse in Oregon, we upheld the denial of benefits on the ground that the claimant failed to prove the requisite hardship as a result of his spouse’s relocation.

The result in Hammond was consistent with our earlier decision in Schechter, wherein the claimant and her husband maintained separate residences in Pennsylvania and Arlington, Virginia, for three years from 1980 to 1983 before the claimant quit her employment to join her spouse. In September 1982, the couple had their first child, and the family moved to Virginia in December 1982. At the end of her maternity leave in January 1983, the claimant resigned her employment. Although the move was motivated by the couple’s belief that maintaining separate households was no longer economically feasible and their desire to raise their child together, we upheld the denial of benefits on the grounds that the claimant failed to prove the necessary hardship, noting that the purpose of the law is not to finance a transition in family living arrangements that results in a temporary self-imposed hardship. 491 A.2d at 940.

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Sturpe v. Unemployment Compensation Board of Review
823 A.2d 239 (Commonwealth Court of Pennsylvania, 2003)

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Bluebook (online)
823 A.2d 239, 25 A.L.R. 6th 635, 2003 Pa. Commw. LEXIS 283, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sturpe-v-unemployment-compensation-board-of-review-pacommwct-2003.