IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
IRIS JOYCE DOBNACK, )
)
Claimant-Appellant, )
)
v. ) C.A. No. 02A-04-13 JRS
)
COLONIAL SECURITY SERVICE, )
)
Employer-Appellee, )
)
and )
)
UNEMPLOYMENT INSURANCE )
APPEAL BOARD, )
)
Appellee. )
Submitted: October 24, 2002
Decided: January 23, 2003
O R D E R
This 23rd day of January, 2003, upon consideration of the pro se appeal of Iris
Joyce Dobnack ("Ms. Dobnack") from the decision of the Unemployment Insurance
Appeal Board (the "Board"), dated April 10, 2002, rejecting her application for
benefits, the Appellant’s brief and the record below, it appears to the Court that:
1. Colonial Security Service ("Colonial Security") employed Ms. Dobnack
from April 2001 to December 2001 as a security guard at Brandywine Park
Condominiums. On December 24, 2001, Charles Grimes ("Mr. Grimes") announced
that Tamatha Burress would replace him as the new supervisor at the Brandywine
Park Condominiums and that there might be some changes in the employee schedules.
The parties disagree on Ms. Dobnack’s response to this announcement. Colonial
Security presented witnesses who stated that Ms. Dobnack complained loudly and
used profanity. Ms. Dobnack denies being loud and abusive, but she admits that she
was "mad" when Mr. Grimes told her that her hours would be reduced. Both parties
agree that Ms. Dobnack voluntarily left the job site without authorization before the
end of her shift.
2. According to a representative of Colonial Security, Ken Farrell ("Mr.
Farrell"), and Colonial Security’s disciplinary report, Ms. Dobnack was terminated
for insubordination, leaving her post without authorization, and abusive language and
behavior, effective as of December 24th. Approximately a week later, she contacted
Samuel Chickadel ("Mr. Chickadel"), the Vice President of Colonial Security, who
indicated to Ms. Dobnack that he might be able to offer some weekend work to her.
Ms. Dobnack continued to communicate with Colonial Security, but she was never
re-hired in any capacity.
3. Ms. Dobnack filed a request for benefits with the Delaware Department of
Labor, Division of Unemployment Insurance on January 6, 2002. The Claims
Deputy denied her request under Title 19, Section 3315(2) of the Delaware Code,2
finding that Ms. Dobnack "was terminated for insubordination, profanity, and leaving
her post."3 The Claims Deputy concluded that "the employer had just cause to
terminate the claimant." Ms. Dobnack appealed the Deputy’s findings. In the
hearing before the Appeals Referee, Colonial Security did not present any witnesses
to the incident on December 24th. Accordingly, the Referee accepted Ms.
Dobnack’s testimony and granted Ms. Dobnack’s request for benefits. Colonial
Security then appealed to the Board. At this hearing, Colonial Security offered the
testimony of three witnesses to the events of December 24th. To rebut this evidence,
Ms. Dobnack testified on her own behalf and presented the testimony of her exhusband,
John Dobnack. The Board found Colonial Security’s witnesses more
persuasive and reversed the Referee’s decision granting benefits. The Board
concluded that the "claimant’s behavior rose to the level of willful or wanton conduct
and provided the employer with just cause for claimant’s discharge."
4. In the current appeal, Ms. Dobnack disputes the Board’s finding that she
was discharged for "just cause."6 Instead, she contends that she quit her job and that
she had just cause to do so. Specifically, she argues that she was justified in leaving
her job when she was advised that her work hours would be substantially reduced by
the new management. She also contends that the Board’s decision was based solely
upon hearsay. And she questions the absence of certain witnesses from the hearing.
5. The role of the Court when reviewing an appeal from the Board is well
settled. The Court reviews the Board’s decision to determine whether its factual
findings are supported by substantial evidence and reviews its ultimate decision to
ensure that it is free from legal error. Substantial evidence has been defined as
relevant evidence that a reasonable mind might accept as an adequate basis to support
a conclusion. Substantial evidence requires "more than a scintilla but less than a
preponderance" of evidence to support the finding. The Court does not weigh
evidence, assess credibility, or make independent factual findings. The Board’s
findings in these evidentiary matters are considered conclusive.
6. As a part of its findings, the Board adopted the Referee’s conclusion that
Ms. Dobnack was terminated (as opposed to voluntarily separating from her
employer) and that Section 3315(2) governs Ms. Dobnack’s case. Under Section
3315(2), an employee is not qualified to receive benefits "[f]or the week in which the
individual was discharged from his work for just cause in connection with the
individu al’s work and for each week thereafter until the individual has been employed
in each of 4 subsequent weeks." "Just cause" is defined as a "wilful or wanton act
in violation of either the employer’s interest, or of the employee’s duties, or of the
expected standard of conduct." The employer has the burden to prove that the
employee was discharged for "just cause" by a preponderance of the evidence.
Alternatively, if the Board had found that Ms. Dobnack quit her job, the Board would
have applied Section 3315(1), which only allows the claimant to recover benefits if
she carries the burden of proving that she voluntarily terminated her employment for
"good cause." "Good cause" is a reason that "would justify one in voluntarily
leaving the ranks of the employed and joining the ranks of the unemployed." Some
examples of "good cause" to quit include nonpayment of wages, a substantial
reduction in wages or hours, or a substantial deviation from the original terms of
employment.
7. The Board’s factual finding that Ms. Dobnack was terminated is supported
by substantial evidence. The Board accepted Colonial Security’s version of the facts
as true. Mr. Farrell asserted that Ms. Dobnack was discharged for insubordination,
leaving the work site, and abusive language. Her termination was documented in a
disciplinary action report, which was entered as an exhibit in the Referee’s hearing.
The Court concludes that the substantial evidence in the record supports the Board’s
finding that Ms. Dobnack was discharged.
8. Three witnesses at the scene of the December 24th incident described Ms.
Dobnack’s outburst and subsequent exit from the workplace. Ms. Dobnack herself
admits to being "mad" for having her hours reduced and to leaving the job site
without express permission from Mr. Grimes. This testimony is more than adequate
to support the Board’s finding that Ms. Dobnack reacted in a loud and abusive
manner to Mr. Grimes’ announcement of the new supervisor and left her post without
permission.
9. Delaware courts consider the use of obscenity without provocation to be
wilful and wanton misconduct, establishing "just cause" for termination. And a
single instance of misconduct is sufficient to establish "just cause." The substantial
evidence supports the Board’s conclusion that Mr. Grimes did not provoke Ms.
Dobnack in any manner. Therefore, by presenting testimony of Ms. Dobnack’s
unprovoked outburst, Colonial Security has met its burden to demonstrate that Ms.
Dobnack was fired for "just cause."
10. Ms. Dobnack’s last two arguments may be summarily rejected. She first
claims that the Board based its decision on hearsay. Under Delaware law, the Board
may not base its decision solely on hearsay; hearsay evidence is permissible if it
accompanies other probative evidence sufficient to support the finding.21 Here, the
Board did not rely solely upon hearsay; it also relied upon the direct testimony of
Colonial Security’s three witnesses to derive the facts necessary to reach its decision.
In addition, Ms. Dobnack questions the absence of Jack Monaco, a representative of
Brandywine Park Condominiums, and other alleged witnesses to the December 24th
incident, from the hearings before the Board and the Referee. In hearings before the
Board and the Referee, each party may present their case as they choose. To prevail,
the parties must meet the evidentiary standards articulated in Section 3315(2) and any
other applicable sections of the Delaware Code. Neither party is required to present
certain witnesses or certain evidence. The absence of a witness or witnesses from the
hearings, by itself, is not a basis to question to the Board’s findings.
11. Based on the foregoing, the decision of the Board denying Ms.
Dobnack’s benefits is AFFIRMED.
IT IS SO ORDERED.
Judge Joseph R. Slights, III
Original to Prothonotary
cc: Iris Joyce Dobnack
Joseph J. Longobardi, III, Esquire
Stephani J. Ballard, Esquire