IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
IN AND FOR THE NEW CASTLE COUNTY
CAROL STEWART, )
Appellant, )
v.
CONNECTIONS, )
and UNEMPLOYMENT INSURANCE )
APPEAL BOARD, )
Appellees. )
Date Submitted: April 22, 2008
Date Decided: July 9, 2008
Upon Appeal from the
Unemployment Insurance Appeal Board.
AFFIRMED
O R D E R
This 9th day of July 2008, upon consideration of the appeal of Carol Stewart
("Ms. Stewart"), from a decision of the Unemployment Insurance Appeal Board (the
"Board") denying her claim for unemployment benefits against her former employer,
Connections ("Connections"),1 it appears to the Court that:
1. Ms. Stewart was employed as a staff member at the Chadwick Supervised
Apartments, a program run by Connections, from January 16, 2003 until June 5, 2007,
when her employment was terminated.2 On June 5, 2007, Ms. Stewart’s supervisor,
Sara Gundel ("Ms. Gundel"), approached Ms. Stewart with a performance write up
regarding her failure properly to complete Medicine Administration Reports
("MARs") for residents to whom she had administered medication.3 Ms. Stewart had
been written up for similar infractions in the past.4 Ms. Gundel reports that upon
presenting Ms. Stewart with the write up Ms. Stewart became irate and told Ms.
Gundel that she was "full of shit," "wait till (sic) they find something on you, I’m
gonna (sic) get something on you," and "fuck this" (repeatedly).5 Ms. Gundel then
sent Ms. Stewart home for the remainder of the day, but told her to report the
following morning at 10:00 a.m. for a meeting with Ms. Gundel and her supervisor.6
2. On June 6, 2007, the following morning, Ms. Stewart failed to show up
at the scheduled meeting.7 Later that same day Ms. Stewart spoke with Ms. Gundel
who directed her to contact Human Resources. Ms. Stewart claims to have called
Human Resources but received no answer. She is unsure whether she left a message.
At some later point, Ms. Stewart spoke with Human Resources and was informed that
her employment with Connections had been terminated.8
3. Ms. Stewart filed for unemployment compensation with the Delaware
Department of Labor ("DOL") on June 10, 2007.9 On July 3, 2007, a Claims Deputy
for the DOL determined that Connections terminated Ms. Stewart for misconduct in
connection with her work constituting just cause.10 Pursuant to 19 Del. C. § 3314(2),
this finding disqualified Ms. Stewart from receiving unemployment compensation.11
4. On July 6, 2007, Ms. Stewart appealed the Claims Deputy’s decision to
the Appeals Referee. After a hearing, the Appeals Referee issued her decision on
August 17, 2007, reversing the Claims Deputy’s determination that Ms. Stewart was
terminated for just cause. The Referee explained in her decision that the employer
failed to establish "willful and wanton misconduct" on Ms. Stewart’s part.12 The
Referee reasoned that Connections had failed to meet its evidentiary burden because
the evidence presented at the hearing regarding the incident leading to Ms. Stewart’s
termination was hearsay.13 As a result of the insufficient evidence, the Appeals
Referee concluded that Ms. Ms. Stewart was entitled to unemployment
compensation.14
5. On August 22, 2007, Connections appealed the Referee’s decision to the
Board and a hearing was held on September 19, 2007.15 The Board issued its decision
that same day, reversing the Referee’s decision upon concluding that Ms. Stewart’s
actions gave Connections just cause for termination because the misconduct was
willful and wanton.16 The Board determined that Ms. Grundel’s firsthand account of
the events leading to termination was credible and demonstrated Ms. Stewart had
engaged in an act of insubordination. This conduct gave Connections just cause to
terminate her employment.17 The Board relied upon the definition of insubordination
as set forth in Delaware case law. Courts have defined insubordination as "the refusal
to obey the order of a superior which the superior is entitled to give and have
obeyed."18 In making its determination, the Board applied this definition of
insubordination to the incident in question and found that Ms. Gundel, as Ms.
Stewart’s superior, was entitled to give the order that she attend a meeting the
morning following her aggressive outburst.19 The Board found Ms. Stewart’s failure
to obey this direction to be a clear case of insubordination, resulting in her termination
for just cause.20
6. On November 27, 2007, Ms. Stewart filed a pro se appeal of the Board’s
decision with this Court.21 She filed her one page Opening Brief on January 22, 2008.
No response was filed by the Board or Connections.22
7. This Court repeatedly has emphasized the limited extent of its appellate
review of administrative determinations. The Court’s review is confined to ensuring
that the hearing officer made no errors of law and determining whether "substantial
evidence" supports the hearing officer’s factual findings.23 Questions of law that arise
from the hearing officer’s decision are subject to de novo review, pursuant to Superior
Court Civil Rule 3(c), which requires the Court to determine whether the hearing
officer erred in formulating or applying legal precepts.24 Substantial evidence means
"such relevant evidence as a reasonable mind might accept as adequate to support a
conclusion."25 It is "more than a scintilla but less than a preponderance of the
evidence."26 The "substantial evidence" standard of review contemplates a significant
degree of deference to the hearing officer’s factual conclusions and its application of
those conclusions to the appropriate legal standards.27 In its review, the Court will
consider the record in the light most favorable to the prevailing party below.28
8. Pursuant to 19 Del. C. § 3314, an employee is disqualified from receiving
unemployment compensation if she is discharged for just cause. Just cause is defined
as "a willful or wanton act or pattern of conduct in violation of the employer’s
interest, the employee’s duties, or the employee’s expected standard of conduct."29
"Willful and wanton conduct is that which is evidenced by either conscious action, or
reckless indifference leading to a deviation from established and acceptable workplace
performance."30 There is no requirement that the conduct be performed with bad
motive or malice.31
9. The record before the Board consisted of the testimony of both Ms.
Stewart and Ms. Gundel, the superior at whom Ms. Stewart’s obscene tirade was
directed, and the evidentiary record of Ms. Stewart’s history of write ups for
unsatisfactory job performance.32 The Board, as fact finder, found Ms. Gundel’s
testimony to be more credible than that of Ms. Ms. Stewart, which it described as
"muddled and barely coherent."33 Ms. Gundel’s testimony and the evidentiary record
indicate that Ms. Stewart was directed to appear at 10:00 a.m. on the morning of June
6, 2007, to meet with Ms. Gundel and her supervisor so that she could answer for her
insubordination the day before. Ms. Stewart’s failure to appear amounts to disregard
of an order that a superior is entitled to give and have obeyed, an insubordinate act.
There was substantial evidence in the record to support the Board’s finding that
Connections had discharged Ms. Stewart for just cause. Additionally, the record
indicates that Ms. Stewart was warned on several occasions that her failure to comport
with the job standards set forth by Connections could result in the termination of her
employment.34
10. Based on the foregoing, the Court is satisfied that the Board applied the
correct legal standards and that its decision is supported by substantial evidence.35
Accordingly, the decision of the Board denying Ms. Stewart unemployment
compensation must be AFFIRMED.
IT IS SO ORDERED.
Judge Joseph R. Slights, III
Original to Prothonotary