IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
IN AND FOR KENT COUNTY
MARIANA ROBLEDO, )
)
Appellant, )
) C.A. No. 00A-09-001 HDR
v. )
)
STRATUS and UNEMPLOYMENT )
INSURANCE APPEAL BOARD, )
)
Appellees. )
Submitted: January 25, 2001
Decided: March 27, 2001
Mariana Robledo, Milford, Delaware, pro se.
James J. Hanley, Esq., Deputy Attorney General, Department of Justice,
Wilmington, Delaware, for Appellee Unemployment Insurance Appeal Board.
Upon Appeal from a Decision of the
Unemployment Insurance Appeal Board
AFFIRMED
RIDGELY, President Judge
O R D E R
This 27th day of March, 2001, upon consideration of the parties’ briefs and
the record below, it appears that:
(1) Mariana Robledo ("Claimant") appeals from the decision of the
Unemployment Insurance Appeals Board ("Board") which held that her appeal
before the Board was untimely and therefore the Board did not have jurisdiction
to hear the merits of her case.
(2) On April 1, 2000, the Claimant left her employment with Stratus
because she thought she had another job. She then filed a claim for
unemployment compensation benefits. Following a fact finding interview, the
Claims Deputy denied the Claimant’s application because she voluntarily quit
her employment without good cause. The Claimant filed a timely appeal from
this decision to the Appeals Referee ("Referee"). On July 18, 2000, the Referee
affirmed the Claims Deputy’s disqualification. On July 31, 2000, the Claimant
filed her appeal with the Board. The Board held a hearing and concluded that
the Claimant’s appeal should be dismissed for failure to comply with the 10-day
filing deadline contained in 19 Del. C. § 3318(c). The Claimant now appeals from
that decision.
(3) The Court’s review of the Board’s decision is twofold. First, the
Court must determine if there are facts to support the finding that the appeal
was untimely. Second, the Court must determine whether the Board abused its
discretion by not exercising, sua sponte, its power to review the record for an
injustice despite the untimely appeal.1
(4) In reviewing the factual findings of the Board, the Court must
determine whether the findings are supported by substantial evidence and free
from legal error.2 Substantial evidence means such relevant evidence as a
reasonable mind might accept as adequate to support a conclusion.3
(5) 19 Del. C. § 3318(c) states that a Referee’s decision "shall be deemed
to be final unless within 10 days after the date of notification or mailing of such
decision further appeal is initiated pursuant to § 3320 of this title."4 The ten-day
period referred to in § 3318(c) begins to run on the date of the mailing unless the
mail fails to reach a party due to the Department of Labor’s error.
The Claimant asserts that she was justified in filing her appeal three days
past due because she had traveled to Texas, did not return until July 27, 2000,
and did not pick up her mail until the appeal deadline of July 28, 2000. Also, the
Claimant admits that she failed to pick up her mail at the Texas address which
she had provided to the Referee for notice purposes.
(6) Properly addressed mail is presumed to be received by the
addressee.6 The addressee’s mere denial of receipt of the notice is insufficient to
rebut this presumption.7 Further, it is "reasonable to expect that a claimant
awaiting an important decision from an appeal tribunal would regularly check
the locations at which [s]he receives mail."8
Here, the decision was properly mailed both to the Claimant’s home
address and the Texas address she provided. Neither was returned as
"undeliverable." Moreover, there is no evidence of error by an employee of the
Department of Labor.
Based on the above findings, the Board’s determination that the notice was
properly mailed to the Claimant and that the subsequent appeal was untimely
filed was based on substantial evidence. Therefore, the Board properly held that
19 Del. C. § 3318(c) created a jurisdictional bar to its consideration of the
Claimant’s untimely appeal.
(7) The Board does have authority under 19 Del. C. § 3320 to "act sua
sponte beyond the ten day appeal period to consider a case where no valid appeal
has been filed by the parties."9 However, this authority is used only "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."10 Absent an
abuse of discretion, this Court must uphold the Board’s decision.11
Here the Board found that "the facts in this case do not involve
circumstances so severe as to require that it assume jurisdiction in this case."12
The Claimant has admitted that she received the notice on the last day
designated for appeal, and further has admitted that she failed to check her mail
at the Texas address she provided to the Referee or to notify the Department of
any other address in Texas. The Claimant cannot show any error on the part of
the Department of Labor that might have delayed the Claimant’s receipt of the
decision or delayed her filing of the appeal. On these facts there was no abuse of
discretion by the Board.
NOW, THEREFORE, IT IS ORDERED that the decision of the
Unemployment Insurance Appeal Board is AFFIRMED.
/s/ Henry duPont Ridgely
President Judge
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