William W. Weller v. Morris James LLP, and Unemployment Insurance Appeal Board

CourtSuperior Court of Delaware
DecidedNovember 30, 2023
DocketN23A-03-007 FWW
StatusPublished

This text of William W. Weller v. Morris James LLP, and Unemployment Insurance Appeal Board (William W. Weller v. Morris James LLP, and Unemployment Insurance Appeal Board) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
William W. Weller v. Morris James LLP, and Unemployment Insurance Appeal Board, (Del. Ct. App. 2023).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

WILLIAM W. WELLER, ) ) Appellant, ) ) v. ) C.A. No. N23A-03-007 FWW ) MORRIS JAMES LLP, and ) UNEMPLOYMENT INSURANCE ) APPEAL BOARD, ) ) Appellees. )

Submitted: August 25, 2023 Decided: November 30, 2023

MEMORANDUM OPINION

On Appeal from the Unemployment Insurance Appeal Board AFFIRMED

William W. Weller, pro se, 216 Oak Drive, Middletown, Delaware 19709, Appellant.

Jennifer C. Jauffret, Esquire, RICHARDS, LAYTON, & FINGER, P.A., 920 North King Street, Wilmington, Delaware 19801, Attorney for Appellee Morris James LLP.

Victoria W. Counihan, Esquire, Deputy Attorney General, DEPARTMENT OF JUSTICE, 820 North French Street, Wilmington, Delaware 19801, Attorney for Appellee Delaware Department of Labor, Division of Unemployment Insurance.

WHARTON, J. I. INTRODUCTION.

This appeal is from a decision of the Unemployment Insurance Appeal Board

(“UIAB”) affirming an Appeals Referee’s (“Referee”) decision finding Appellant

William W. Weller (“Weller”) ineligible for unemployment benefits from

September 17, 2022 to September 2, 2023.1 Weller and his former employer, the

law firm Morris James, LLP (“Morris James”) entered into a Separation Agreement

and Release (“Agreement”) on August 16, 2022, ending a nearly two decade

employer/employee relationship.2 The Agreement required Morris James to pay

Weller a lump sum of $94,450.00 (“Payment”) in exchange for multiple promises

from Weller.3 At the end of his employment, Weller filed a claim to receive

unemployment benefits from the Division of Unemployment Insurance

(“Division”).4 A Claims Deputy denied his unemployment benefits claim, finding

that the Payment, when pro-rated weekly, exceeded what he otherwise would have

received in weekly unemployment benefits.5 The Referee affirmed the Claims

Deputy’s determination.6 In turn, the UIAB affirmed the Referee.7 On appeal,

1 Weller v. Morris James, App. Docket No. 47115212 (UIAB Mar. 3, 2023), R. at 7. (UIAB’s Decision). 2 Agreement, R. at 104. 3 Id. at 104-105. 4 Claims Deputy’s Decision, R. at 118. 5 Id. 6 Referee’s Decision, R. at 100-02. 7 UIAB’s Decision, R. at 9. 1 Weller argues that the Referee and the UIAB committed various legal errors

warranting reversal. After carefully considering Weller’s arguments, the Court

disagrees. The UIAB’s decision is AFFIRMED.

II. FACTS AND PROCEDURAL HISTORY.

Weller was employed by Morris James as a paralegal for approximately 20

years from October 2002 to August 2022.8 On August 16, 2022, Weller signed the

Agreement requiring Morris James to pay him $94,450.00 in exchange for certain

promises from Weller.9 On September 11, 2022, he filed a claim to receive

unemployment benefits.10 A Claims Deputy determined that Weller was ineligible

for unemployment benefits due to him receiving $94,450.00 in severance pay.11

Weller appealed and testified at his hearing before the Referee that the

Agreement was not a severance agreement, but rather, an agreement settling a

whistleblower claim related to a complaint he had filed with the Office of

Disciplinary Counsel against a Morris James attorney.12 In support of that argument,

Weller attempted to introduce into the record an email labeled “Weller ODC” which

the Referee declined to admit,13 the Agreement which the Referee admitted,14 and

8 Appellant’s Op. Br. at 3, D.I. 14. 9 Agreement, R. at 104-105. 10 R. at 113. 11 Claims Deputy’s Decision, R. at 118. 12 Hr’g. Tr. (Dec. 21, 2022), R. 54-83, passim. 13 Id. R. at 62. 14 Id. R. at 69. 2 notes and a video from his meeting with Morris James which the Referee declined

to admit.15

The UIAB affirmed the Referee’s decision.16 It first observed that Weller’s

principal dispute with the Referee’s decision was his belief that the Payment should

not be viewed as severance, and thus, not affect his eligibility for uninsurance

benefits.17 The UIAB was unpersuaded by Weller’s two arguments in support of

that belief – first, that Morris James did not contest his unemployment filing, and

second, that Morris James intended the Payment to be a settlement of his

whistleblower claim.18 As to the first, the UIAB pointed out that only the Division

and the UIAB are empowered to make eligibility determinations and that Morris

James’ position does not control that determination.19 Similarly, as to the second,

the UIAB did not find Morris James’ motivation determinative of Weller’s eligibility

for benefits.20 Rather, it found that the appropriate analysis was to apply the facts to

Delaware law.21

15 Id. R. at 70. 16 UIAB’s Decision, R. at 9. 17 Id. R. at 8. 18 Id. 19 Id. 20 Id. 21 Id. 3 When it performed that analysis, the UIAB found that the Payment was a

severance.22 It found that Morris James paid Weller the equivalent of one year’s

salary in connection with the termination of their employment relationship.23 Citing

19 Del. C. § 3302(18), the UIAB pointed out that wages are defined as ‘“all

remuneration for personal services, including commissions, bonuses, dismissal

payments, holiday pay, back pay awards.”’24 The UIAB “believe[d] that generally

severance payments would be included in dismissal payments under § 3302(18).”25

Therefore, while the Payment was part of a settlement agreement that included the

resolution of other charges, the UIAB did not find that fact sufficient to take the

Payment out of the definition of “wages.”26 In sum, the UIAB found that Morris

James’ payment of one year’s salary was a payment of wages under § 3302(18). 27

Additionally, the UIAB found that a contrary result “would not serve the spirit of

the unemployment insurance law because [Weller] was not placed into the same

22 Id. 23 Id. 24 Id. (citing 19 Del. C. § 3302(18)). 25 Id. 26 Id. 27 Id. 4 economic instability as a worker terminated without any such payment.28 On March

10, 2023, Weller appealed the Board’s decision to this Court.29

III. THE PARTIES’ CONTENTIONS.

Weller contends that the Board’s decision was not free from legal error. It

incorrectly affirmed the Referee who violated his due process rights by relying on a

complete copy of the hearsay Separation Notice submitted by Morris James which

was not provided to him prior the hearing.30 It failed to reverse the Referee who

denied him an opportunity to present certain relevant evidence consisting of a video

of a Morris James Executive Committee meeting, his notes for that meeting, and the

ODC email.31 The Referee also improperly imposed an artificial hearing length and

restricted Weller’s right to present evidence.32 The UIAB also committed legal error

with respect to its findings concerning the intent of the Agreement.33 Weller also

takes issue with the UIAB’s denial of unemployment benefits based on “public

policy” and unemployment insurance law.34 Finally, Weller contends that since the

28 Id. at n. 3, R. 9 (quoting 19 Del. C. § 3301 ‘“As a guide to interpretation of this chapter, the public policy of this State is declared to be as follows: economic instability due to unemployment is a serious menace to the health, morals and welfare of the people of this State.”’) 29 R. at 4. 30 Appellant’s Op. Br. at 12-14, D.I. 14. 31 Id. at 15-17. 32 Id. 33 Id. at 17-20. 34 Id. at 21-23. 5 Payment was a settlement, it does not fall under the Delaware Unemployment Code

definition of “wages.”35

The Division first argues that the decision of the UIAB was free of legal

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