IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
DEOBRAH L. GEORGE )
Appellant, )
v. )
UNEMPLOYMENT INSURANCE APPEAL BOARD, )
Appellee. )
ON APPEAL FROM THE
UNEMPLOYMENT INSURANCE APPEAL BOARD
AFFIRMED
Submitted: August 18, 2008
Decided: September 9, 2008
This 9th day of September, 2008, upon consideration of the appeal of
Deborah L. George ("George") from the decision of the Unemployment
Insurance Appeal Board ("the Board") ordering repayment of benefits
wrongfully received, it appears to the Court that:
1. George filed an unemployment insurance claim on June 3,
2007. On the basis of that claim, George received $73 per week for the
weeks ending June 9, 2007 through October 13, 2007.1 At the time her
claim was filed, George signed the required Form UC-410 acknowledging
her obligation to repay all unemployment benefits disbursed during a
disqualification period if a claims deputy, appeals referee, the Board, or a
court later determined her to be subject to disqualification.2
2. George was contacted by Caldwell Staffing on September 7,
2007, regarding a position with the Boy Scouts of America ("the Boy
Scouts"). George denies that she was ever formally offered a position,3 but
nevertheless expressed to Caldwell Staffing that she would refuse
employment with the Boy Scouts. George apparently told Caldwell Staffing
personnel that the Boy Scouts "supported the war," and that the Boy Scouts’
pro-war stance would conflict with her religious beliefs.4 Caldwell Staffing
conducted an Internet search that revealed no indications the Boy Scouts had
taken a position on war efforts.5
3. Subsequently, Caldwell Staffing informed the Department of
Labor ("DOL") that George had refused assignments. On November 6,
2007, a DOL Claims Deputy issued a determination that George was
disqualified from receiving unemployment benefits, effective for the week
ending September 8, 2007, for refusing to accept an offer of suitable work.6
The Notice of Determination indicated that George’s disqualification would
be used to establish an overpayment and further provided that the
determination would become final unless appealed by November 16, 2007.7
George did not appeal.
4. On December 21, 2007, a DOL Claims Deputy issued a
determination that George had received $438 in overpaid benefits, or $73 for
the six weeks from September 8, 2007 to October 13, 2007.8 George timely
appealed this determination, but having failed to challenge her
disqualification in the first place, her efforts to argue that there was no
overpayment were unavailing. At a hearing before an Appeals Referee on
January 22, 2008, George testified as to her religious objections to the Boy
Scouts, her claims that she had never received a job offer, and her history of
medical and emotional problems, which she said prevented her from
appealing her disqualification.9 This testimony was presented over repeated
cautions from the Appeals Referee that the substantive merits of George’s
disqualification were not at issue, because the disqualification had already
become final.10 The Appeals Referee found that there had been a benefits
overpayment.11 George timely appealed the Appeals Referee’s decision, and
the Board affirmed.12
5. The Appeals Referee stated in his findings of fact that George
"suffered medically and was emotionally incapable of responding to
decisions mailed" in reference to George’s failure to appeal her
disqualification.13 While the Board’s decision noted George’s objections to
her disqualification and her contention that she was unable to timely appeal
the original ineligibility decision. The Board affirmed the overpayment,
finding "no evidence of error on the part of the [DOL] which might have
delayed claimant’s appeal of the initial determination, at which time she
could have made her factual arguments."14
6. George filed a pro se appeal of the Board’s decision to this
Court on April 24, 2008.15 In her brief, George continues to argue the
substantive merits of her disqualification, reiterating her claims that she
could not have declined a position with the Boy Scouts because she never
received a formal offer and that she did not appeal her disqualification as a
result of medical and emotional problems.16 George’s brief does not raise
any challenges to the overpayment distinct from her arguments regarding the
unappealed disqualification, nor are any separate arguments specific to the
overpayment determination found in the record below.17 The Board did not
submit a brief in this matter.18
7. This Court’s appellate review of decisions of the Board is
limited. The Court’s function is to determine whether the Board’s findings
and conclusions are supported by substantial evidence and free from legal
error.19 The substantial evidence standard is satisfied if the Board’s ruling is
supported by "such relevant evidence as a reasonable mind might accept as
adequate to support a conclusion."20 The Court does not weigh evidence,
decide questions of credibility, or engage in fact-finding in reviewing a
Board decision.21 Where the Board has made a discretionary decision, the
scope of the Court’s inquiry includes examining the Board’s action for abuse
of discretion.22 A discretionary decision will be upheld absent an abuse of
discretion2324
8. Under 19 Del. C. § 3318(b), a Claims Deputy’s determination
that an individual is disqualified from receiving unemployment benefits
becomes final if no appeal is filed within ten days.25 This ten-day period is
"an express statutory condition of jurisdiction that is both mandatory and
dispositive."26 Where a failure to timely appeal is due to "unintentional or
accidental actions" by the claimant, and was not caused by administrative
error, the disqualification becomes final after the running of the ten days and
19 Del. C. § 3318(b) operates as a jurisdictional bar to further appeal.27
9. In this case, the Board’s decision to affirm the overpayment
determination was supported by substantial evidence. As the Board
correctly noted, George never contested that she received the benefits at
issue and never appealed the determination that she was disqualified from
receiving them based upon a refusal to accept suitable work.28 George was
notified of the ten-day appeals period at the time she was determined to be
disqualified29 and did not initiate an appeal. Although the Appeals Referee
permitted George to offer testimony regarding the disqualification and her
failure to appeal that decision in order to clarify the history of her claim, this
information is irrelevant to George’s appeal from the overpayment
determination. The Board therefore properly held that George did not
exhaust her administrative remedies in challenging her disqualification by
appealing to an Appeals Referee, and was barred from doing so by the
running of the appeals period.30
10. To the extent that George’s Opening Brief continues to press
arguments regarding the merits of her disqualification and her failure to
appeal that decision, this Court lacks jurisdiction to consider those
arguments because of George’s failure to exhaust her administrative
remedies.31 An appeal from an overpayment determination cannot be made
into a vehicle to challenge the merits of a finalized disqualification decision
when the claimant has failed to perfect an appeal from that disqualification.
11. Where a disqualification has become final, the only issues for
this Court upon review of the Board’s overpayment determination are
whether substantial evidence supports the Board’s finding that the
overpayment was sought from the correct individual and that the amount of
overpayment was accurately assessed.32 George does not dispute her receipt
of the benefits or the computation of the overpayment amount, and the
record clearly supports that George was responsible for the overpayment,
that she received notification of it, and that the amount of overpayment was
accurately assessed in the Board’s decision.33
12. The Board’s refusal to assume jurisdiction sua sponte to
consider the merits of the disqualification determination was not an abuse of
discretion. The Board lacks authority to hear an appeal brought by a party
after the ten-day appeals period under 19 Del. C. § 3318(b).34 Where no
valid timely appeal has been filed, however, the Board possesses discretion
under § 3320 to review the record sua sponte if the failure to timely appeal
was caused by administrative error or if "the interests of justice would not be
served by inaction."35 Cases in which the Board assumes jurisdiction sua
13. Here, the Board’s refusal to consider the merits of George’s
disqualification sua sponte was within its discretion. George’s failure to
timely appeal was not caused by administrative error. It is highly unlikely
that George’s alleged physical and emotional conditions, for which she did
not provide corroboration at the hearing before the Appeals Referee, would
have constituted good cause for failing to timely appeal her
disqualification,37 particularly when she was able to timely appeal the
overpayment determination. The circumstances were not extraordinary or
"severe" such that the Board was required to act in the interests of justice.38
The Board therefore did not abuse its discretion by declining to assume
jurisdiction sua sponte to consider George’s substantive arguments
regarding her disqualification.
14. For the foregoing reasons, the decision of the Board is hereby
AFFIRMED.
IT IS SO ORDERED.