IN THE SUPERIOR COURT OF THE STATE OF DELAWARE 
IN AND FOR NEW CASTLE COUNTY 

PAL of WILMINGTON, ) 
 Appellant, ) 
v. ) 
CAROL GRAHAM, Claimant, and ) 
UNEMPLOYMENT INSURANCE ) 
APPEAL BOARD, ) 
Appellees. ) 

Date Submitted: March 3, 2008 
Date Decided: June 18, 2008 

OPINION 
 
Upon Appeal of the Decision of the Industrial Accident Board. 
AFFIRMED. 


I. Introduction 

Plaintiff appeals the decision of the Unemployment Insurance Appeal 
Board denying its request for a rehearing and granting Claimant 
unemployment benefits. For the reasons set forth below, the Court finds that 
the Board’s decision to grant Claimant unemployment benefits is supported 
by substantial evidence and that the Board did not abuse its discretion when 
it denied Plaintiff’s request for a rehearing. Accordingly, the Board’s 
decision is AFFIRMED. 


II. Statement of Facts 




 In April 2004, Claimant Carol Graham ("Graham") began working as 
an administrator for Plaintiff, the Police Athletic League of Wilmington 
("PALW"). In December 2005, Graham accepted the position of Director of 
Programs with PALW. PALW advised her that it would review her 
performance in the first three months of employment. On April 5, 2006, 
Velda Jones-Potter, the president of the board of directors, presented 
Graham with her evaluation. According to the evaluation, Graham 
demonstrated deficiencies in areas essential to her role as Director of 
Programs. To address her deficient work performance, PALW created a 
sixty day performance plan, which included a reevaluation of Graham’s 
progress after the first thirty days. The objective of the plan was "to present 
again to [Graham] the tasks for which she is responsible, evaluate progress 
toward successful completion of these tasks, and determine what, if any, role 
[Graham] shall have in the PALW organization going forward" for the 
period of January through March 2006.1 During that time, Graham was to 
"provide a weekly written status of her work and shall meet weekly with the 
Executive Director to review progress with these assignments."2 At the end 
of the first thirty days, Graham’s performance was to be "reviewed, at which 
time PALW [would] take corrective action if necessary up to and including 
termination."3 

Before implementing the plan, PALW asked Graham to sign it. 
Graham refused to sign and submitted her voluntary resignation on April 6, 
2006. Graham interpreted the plan as "an ultimatum,"4 and refused to 
participate because the plan addressed her duties in her previous 
administrative position, rather than in her current position.5 Although 
PALW accepted her resignation on April 7, 2006, Sylvia Lewis-Harris 
("Lewis-Harris") responded on behalf of PALW, and rebutted Grahams’s 
allegations that she was told to either sign a corrective action plan or resign. 
Lewis-Harris, who was Graham’s supervisor at the time, wrote: 

We received your voluntary resignation letter on April 6, 2006. 
That letter is, however, false and misleading. In the meeting on 
April 5, you were never asked for your resignation. Mrs. Potter 
and I documented and reviewed the history of your 
performance, a sixty-day work plan, and the process for 
monitoring your performance going forward. You voiced 
disagreement with some aspects of the performance assessment, 
which you also documented. We acknowledged your right to 
disagree with the assessment and accepted the document as 
submitted. 

There was no ultimatum given. Mrs. Potter and I explained that 
the only requirement was that you perform the job for which 
you would be compensated. These requirements were detailed 
in the sixty-day work plan. The option to resign, if you were 
not in agreement with the work plan was discussed. You 
indicated that you were unwilling to agree to follow the work 
plan and that you preferred to voluntarily resign your position.6 


 On August 18, 2006, Graham filed for unemployment benefits. On 
September 25, 2006, the Claims Deputy held that Graham was qualified to 
receive unemployment benefits. PALW timely appealed that decision to the 
Appeals Referee. After holding a hearing on December 18, 2006, the 
Appeals Referee reversed the decision of the Claims Deputy. The Referee 
determined that "[t]here was no evidence that this is the case of resignation 
in lieu of discharge."7 The Referee found that Graham resigned without 
good cause, noting that she "voluntarily resigned her position because she 
did not agree with the evaluation and did not wish to sign for the evaluation 
and the performance plan."8 She concluded: 

The employer was reasonable in its expectation that the 
claimant would adhere to the proposed performance plan. Part 
of being an employee is accepting coaching and criticism from 
the employer. Employees may not always agree with an 
employer’s evaluation of their job performance but disagreeing 
with the evaluation does not give an employee the recourse of 
leaving gainful employment to join the ranks of the 
unemployed. . . . The claimant’s unemployment is the result of 
his own choice and his own doing.9 

Graham appealed the Referee’s decision to the Unemployment 
Insurance Appeal Board (the "Board") on December 29, 2006. Due notice 
was sent to both parties that a hearing was scheduled for February 14, 2007. 
On February 6, 2007, PALW requested that the hearing date be changed. 
The Board granted PALW’s request and rescheduled the hearing to February 
28, 2007. The Board sent notice to PALW and its counsel on February 12, 
2007. 

Neither PALW nor its counsel was in attendance at the hearing held 
on February 28, 2007. Upon questioning by the Board, the Board Secretary 
stated that she sent PALW and its counsel notice stating that the hearing had 
been rescheduled to February 28, 2007.10 Both PALW and its counsel, 
however, contend that they were not notified of the new date. Although the 
Board records indicate that notice was sent to the attention of Lewis-Harris 
for PALW, there is no documentary evidence that notice was sent to 
counsel. PALW also claims that it never received the notice. No mail, 
however, was returned to the Department of Labor as undelivered.11 

The Board went forward with the hearing despite PALW’s absence. 
At the hearing, Lewis-Harris, who had since been terminated by PALW, 
testified on behalf of Graham. In contradiction to the letter she issued on 
behalf of PALW, Lewis-Harris testified that Graham was given an 
ultimatum to sign the evaluation.12 Based on this new evidence, the Board 
found that Graham was induced to resign under pressure and qualified for 
benefits. Notably, the Board determined that "[t]he wording of the 
performance plan, without any other evidence, would be sufficient to lead to 
[sic] Board to the conclusion that the claimant was being given an ultimatum 
and was threaten [sic] with future action that all but guaranteed her 
termination."13 It also determined that the plan "certainly tends to contradict 
the testimony of the board president before the Referee[.]"14 The Board 
concluded that PALW’s decision to evaluate Graham with a sixty day 
performance plan, which included a mandatory reevaluation after the first 
thirty days, "speaks for itself, and . . . was clearly an ultimatum, which at 
least implied the intention to terminate the claimant at the end of 30 days."1516 

PALW requested a rehearing on April 5, 2007, five days before the 
Board’s decision became final on April 10, 2007. On April 27, 2007, the 
Board denied PALW’s request for a rehearing because the Board found that 
PALW’s failure to appear was not the result of a departmental error or 
extraordinary circumstance. In its decision, the Board noted that "notice was 
sent to both the Employer and Employer’s counsel."17 PALW then filed the 
instant appeal to this Court. 

III. Parties’ Contentions 

 PALW raises three arguments on appeal. First, PALW submits that 
the Board abused its discretion when it refused to hold a rehearing because 
neither PALW nor its counsel received the twenty-day notice required by 29 
Del. C. § 10122. In support of this argument, PALW contends that (1) 
Lewis-Harris admitted at the hearing that she did not receive notice for 
PALW; (2) there is no evidence that either counsel or PALW received notice 
of the February 28, 2007 hearing date; (3) the Board knew that PALW was 
represented by counsel who had appeared at all prior hearings; and (4) the 
Board’s decision to rely on testimony from the Board Secretary that notice 
was sent is legally insufficient. Second, PALW submits that the Board’s 
decision that Graham was qualified for unemployment benefits was not 
based on substantial evidence because (1) Graham testified that she 
voluntarily resigned; (2) there was no evidence showing PALW intended to 
terminate Graham; and (3) the Board’s decision that Lewis-Harris was 
credible failed to consider her motive to lie and her letter in which she 
rebutted Graham’s assertion of an ultimatum. Finally, PALW argues that 
the Board committed an error of law because it applied the improper 
"constructive discharge" legal standard, rather than the appropriate 
"voluntary quit" standard. 

 In response, the Board contends that it must only give parties five-
days’ notice under Division of Unemployment Insurance Regulation 19 and 
is not subject to the twenty-day requirement of 29 Del. C. § 10122. The 
Board further submits that, despite a lack of documentary evidence 
establishing that notice was sent to PALW and counsel, the testimony of the 
Board Secretary and the presumption that mail sent to the correct address is 
received is sufficient to establish that PALW received notice of the new 
hearing date. Thus, the Board did not abuse its discretion in denying 
PALW’s request for a rehearing. The Board makes no arguments as to the 
substantive finding that Graham is qualified for benefits. Similarly, Graham 
did not file a brief in response to PALW’s contentions. 

IV. Standard of Review 

This Court’s appellate review of a Board decision is limited. In 
reviewing the decisions of the Board, this Court must determine whether its 
findings and conclusions are "free from legal error and supported by 
substantial evidence in the record."18 Substantial evidence means "such 
relevant evidence as a reasonable mind might accept as adequate to support 
a conclusion."19 The "substantial evidence" standard means "more than a 
scintilla but less than a preponderance of the evidence."20 The Court "does 
not weigh the evidence, determine questions of credibility, or make its own 
factual findings."21 

A discretionary decision of the Board will be upheld absent an abuse 
of discretion.22 An abuse of discretion occurs when the Board "acts 
arbitrarily or capriciously"23 or "exceeds the bounds of reason in view of the 
circumstances and has ignored recognized rules of law or practice so as to 
produce injustice."24 The Court reviews questions of law de novo to 
determine "whether the Board erred in formulating or applying legal 
precepts."25 

Where a party requests a rehearing, the Board has discretion to 
consider whether to reopen a case where no valid appeal has been filed by 
either party.26 The Board will only revisit a decision "where there has been 
some administrative error on the part of the Department of Labor which 
deprived the claimant of the opportunity to file a timely appeal, or in those 
cases where the interest of justice would not be served by inaction."27 
Absent an abuse of discretion, the Board’s decision must be affirmed. 


V. Analysis 

A. The Board did not Abuse its Discretion When it Refused to Hold a 
Rehearing 

Due process requires that a party have a full and fair opportunity to be 
heard in its own defense.28 The procedural requirements and formality of 
that opportunity vary depending on the circumstances.29 In the context of a 
hearing before the Unemployment Insurance Appeal Board, the party whose 
rights may be affected is entitled to notice and a hearing.30 Proper notice 
requires that the party receive an adequate, proper and lawful notification of 
the agency action that will affect its right in a meaningful time and 
manner.31 Stated another way, due process requires that "the notice inform 
the party of the time, place, and date of the hearing and the subject matter of 
the proceedings."32 For example, in Turkey’s Inc. v. Peterson, the Court 
held that due process was satisfied where an employer was notified of the 
claimant’s application for benefits, her appeal, the hearings, the right to 
subpoena witnesses, and the right to retain counsel if so desired.33 For 
purposes of sending notice of an appeal to the Unemployment Insurance 
Appeal Board, Delaware Division of Unemployment Insurance Regulation 
Number 19, rather than 29 Del. C. § 10122, governs the timing of notice.34 
Regulation 19 requires that the Board mail the parties notice at least five 
days before the hearing.35 

Due process requirements are fulfilled when they are "accomplished 
by a method reasonably calculated to afford the party an opportunity to be 
heard."36 For notice to be effective, it must be received.37 In Delaware, 
notice that is correctly addressed, stamped and mailed is presumed to have 
been received by the party to whom it was addressed.38 Lack of evidence of 
any mailing error by the Department of Labor supports the presumption that 
properly mailed and addressed mail was received.39 For example, in the 
case of Reagan National Advertising, Inc. v. Unemployment Insurance 
Appeal Board, the Court held that direct testimony from the claims deputy 
that she mailed notice was sufficient, despite any documentary evidence of 
mailing, to establish that notice was sent to the p

This presumption may be rebutted, however, by evidence that notice 
was never received.41 Only where there is evidence that the Board was at 
fault for a misdelivery will a party’s right to due process be violated.42 In 
contrast, if notice is properly addressed by the agency and not received 
because of some fault of the party to whom it was addressed, the notice may 
still be deemed sufficient even if the party did not receive it.43 A party’s 
right to due process will not be violated where notice was not received as a 
result of the party’s failure to inform the agency of her correct address.44 

In this case, the Board did not abuse its discretion in refusing to grant 
PALW a rehearing. At the hearing, the Board’s Secretary testified that she 
mailed notice to both PALW and its counsel. In fact, PALW does not 
dispute that the Department of Labor sent notice to its office.45 Due process 
only requires that the party in interest receive notice by "a method 
reasonably calculated to afford the party an opportunity to be heard."46 
Here, a method reasonably calculated to afford PALW a chance to appear 
before the Board was employed. The agency sent properly mailed and 
stamped notice to PALW’s address on file. That is sufficient to afford 
PALW due process. 

PALW contends that it never received notice because Lewis-Harris 
testified that she did not receive the notice. PALW, however, misconstrues 
the requirements of due process. That Lewis-Harris did not receive the 
notice because she was no longer employed with PALW is immaterial. 
PALW, as the true party in interest, had a duty to not only inform the 
Department of Labor that Lewis-Harris was no longer employed with the 
organization, but also to inform counsel of the change in the hearing date.47 
Moreover, PALW’s failure to inform the Department of Labor of Lewis-
Harris’s termination is not a departmental error. There is no evidence of 
"misdelivery" or that PALW’s failure to receive notice was the fault of the 
Department of Labor. As a result, the Board had substantial evidence before 
it to determine that PALW was sent notice. 

The Court further notes that there is no requirement that counsel for a 
party receive notice in the context of an agency hearing. Similarly, that the 
Board knew that PALW was represented by counsel is not relevant as to 
whether PALW received proper notice. Rather, due process requires that the 
party receive notice of the hearing.48 Just as in Reagan National 
Advertising, Inc., the Board had before it direct testimony that notice was 
properly sent to both PALW and its counsel. Counsel for PALW has offered 
no authority, nor can the Court find any, supporting its assertion that counsel 
must also receive notice in the context of an agency hearing where it is 
undisputed that the actual party in interest was sent proper notice. Because 
PALW was sent proper notice of the new hearing date and the Board 
Secretary testified that she sent notice to both PALW and its counsel, the 
Board had sufficient evidence with which to find that appropriate notice was 
sent. 

PALW relies heavily on the case of Kostyshyn v. Unemployment 
Insurance Appeal Board49 to argue that the Board abused its discretion. In 
that case, the claimant sought to reopen the Board’s decision and testified 
that he did not receive notice of the hearing. The Board found his testimony 
to lack credibility and refused to reopen the decision. On appeal, this Court 
reversed and found insufficient evidence to support the Board’s finding that 
notice was sent: 

Although it is within the province of the Appeal Board to 
determine claimant's credibility, the record must nevertheless 
show that notice was sent before it may be presumed that it was 
received. The only things in the record on this are the statement 
of the Board’s attorney that the notice was sent and a copy of a 
notice which claimant testified that he received on the date of 
the hearing on his motion to reopen. There was neither 
testimony by the person who sent the notice nor explanation of 
the procedure for sending notices that would support a finding 
that the notice was sent.50 

 Kostyshyn is distinguishable from this case. Unlike Kostyshyn, the 
Board’s Secretary testified that she sent proper notice to PALW. In fact, the 
Board records indicate that notice was sent to PALW to the attention of 
Sylvia Lewis-Harris.51 Although PALW stresses that there is no record of 
how notice was sent, what procedures were followed, or whether postage 
was prepaid, the Board Secretary testified that she mailed notice to PALW 
and that notice was sent to PALW to the attention of Lewis-Harris. Notably, 
the Board Secretary sent notice to the same address that she had sent prior 
notices for the initial hearing, all of which were received.52 This evidence 
demonstrates that the Board had sufficient evidence before it to conclude 
that notice was sent properly. As a result, the Board’s decision to deny 
PALW’s request for a rehearing was not an abuse of discretion. 

B. The Board’s Decision is Supported by Substantial Evidence 

PALW argues that the Board’s decision that Graham is entitled to 
benefits is not supported by substantial evidence. Specifically, PALW 
contends that Graham was not pressured to resign and resigned voluntarily. 

Section 3314 of Title 19 of the Delaware Code provides that "[a]n 
individual shall be disqualified for benefits: (1) [f]or the week in which the 
individual left work voluntarily without good cause attributable to such work 
. . . ." The employee has good cause to leave where the cause "would justify 
one in voluntarily leaving the ranks of the employed and joining the ranks of 
the unemployed."53 Good cause does not exist, however, merely because 
the employer creates an undesirable situation.54 Rather, the employee must 
first "do something akin to exhausting his administrative remedies" by, for 
example, notifying the employer of the undesirable situation.55 Although 
"voluntarily" means "proceeding from one’s own choice or full consent," 
Delaware courts have held that an employee does not leave voluntarily 
where she was induced under pressure to leave her job.56 In such a case, the 
employee’s resignation is "tantamount to a discharge . . . without just 
cause", and the employee may receive benefits.57 

In this case, the Board’s decision that Graham was induced under 
pressure to resign is supported by substantial evidence. The Board first 
determined that the evaluation plan crafted for Graham focused mostly on 
her previous position as an administrator, rather than on her current position 
as a program director.58 The Board held that the language of the plan 
indicated that the document was "clearly an ultimatum, which at least 
implied the intention to terminate the claimant at the end of 30 days."59 For 
example, the plan was implemented to "determine what, if any, role Carol 
shall have in the PALW organization going forward."60 Similarly, PALW 
reserved the right to "take corrective action if necessary up to and including 
termination."61 Even though PALW is correct that the Board’s decision 
does not address the motive of Lewis-Harris or the discrepancy between her 
testimony and the letter she authored while employed by PALW, the Board 
stated that "[t]he wording of the performance plan, without any other 
evidence, would be sufficient to lead the Board to the conclusion that the 
claimant was being given an ultimatum and was threaten [sic] with future 
action that all but guaranteed her termination."62 The Board further found 
that the testimony of Lewis-Harris, who testified that Graham was given an 
ultimatum, was credible. As a result, the Board had sufficient evidence 
before it to find that Graham’s resignation was not voluntary. 

PALW relies on Short v. Unemployment Insurance Appeal Board and 
Phoenix Steel63 and Redding v. Medical Center of Delaware64 to argue that 
Graham voluntarily quit and was not constructively discharged. In Short, 
the claimant resigned from his employment after being laid off for one year. 
While laid off, the claimant had the right to bid on other jobs with the 
company, but it was unlikely that he could return to his former position. By 
resigning, however, the claimant was able to receive $1,900.00 in severance 
pay, even though he would lose the ability to bid on different positions. The 
Court affirmed the Board’s decision that "the claimant was given a choice, 
which he made on his own, without any inducement by the employer other 
than monetary."65 

In Redding, Redding’s employer wanted to demote her for deficient 
performance. After Redding opposed the demotion, her employer offered 
her a ninety-day evaluation period. Redding’s performance failed to 
improve, and she was demoted to the only other available position in her 
department. Because she refused to accept this position, her employer 
informed her that she would be terminated. Instead, Redding chose to 
resign. On appeal, this Court affirmed the Board’s decision that Redding did 
not qualify for benefits because the employer’s offer to place Redding in a 
position with fewer responsibilities did not induce her to resign.66 

The holdings in Short and Redding do not persuade the Court that the 
Board erred. In both Short and Redding, the claimants were given options 
for different jobs within the organization rather than termination. Moreover, 
in neither case did the employer’s actions suggest an intention to terminate 
the claimant. In contrast, neither the evaluation plan nor the comments 
made by Graham’s superiors present an option for Graham. Although 
Graham was not explicitly forced to sign the evaluation plan, the wording of 
the plan was laden with implicit threats that she would be terminated, rather 
than reassigned. The language of the plan suggested, at least implicitly, that 
Graham must either accept the new evaluation, which mainly addressed her 
old position, or risk termination. This interpretation was supported by the 
testimony of Lewis-Harris at the Board hearing. Graham "exhausted her 
administrative remedies" by voicing disagreement with the plan and 
documenting those disagreements.67 The Board correctly applied the proper 
"constructive discharge" standard because there was substantial evidence 
that Graham’s resignation was induced under pressure to resign. Thus, the 
holdings in Short and Redding are unavailing. 

Importantly, although PALW stresses that there was no explicit threat 
to terminate Graham, that she chose to resign, and that the Board’s decision 
failed to consider Lewis-Harris’s motive to lie, this Court cannot weigh the 
evidence, make factual determinations, or weigh the credibility of witnesses. 
Rather, this Court can only determine whether the Board’s decision is 
supported by substantial evidence. In this case, the language of the 
performance plan implied that Graham would be forced to resign if she did 
not sign the plan, Graham’s testimony that she was threatened with a forced 
resignation and the supporting testimony of Lewis-Harris, which the Board 
found to be credible, is evidence adequate to support the Board’s decision. 
As a result, the Board’s decision is supported by substantial evidence. 


VI. Conclusion 

The Court finds that the Board did not abuse its discretion when it 
refused to reopen its March 30, 2007 decision because there was sufficient 
evidence in the record to demonstrate that PALW was sent proper notice. 
The Court also concludes that the Board’s decision finding Graham qualified 
for benefits is supported by substantial evidence. According, the Board’s 
decision is AFFIRMED. 

IT IS SO ORDERED. 

__________________________ 

Jan R. Jurden, Judge