IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
IN AND FOR NEW CASTLE COUNTY
IRVING THOMPKINS JR., )
Appellant, )
v.
FRANCISCAN ELDER CARE )
and the UNEMPLOYMENT )
INSURANCE APPEAL BOARD )
Appellees.
Submitted: March 17, 2008
Decided: June 27, 2008
MEMORANDUM OPINION
Appeal from Unemployment Insurance Appeal Board. AFFIRMED.
CARPENTER, J.
Introduction
Before this Court is Irving Thompkins’ ("Appellant") appeal from the
Department of Labor, Division of Unemployment Insurance Appeal Board’s
("Board") decision, where it found that Mr. Thompkins was discharged by his
employer, Franciscan Elder Care, ("Appellee") for just cause. Upon review of the
record in this matter, the Court finds the Board’s decision is supported by substantial
evidence and is therefore AFFIRMED.
Facts
Appellant was an employee of Franciscan Elder Care for approximately ten and
a half years. During that time period Appellant had a substantial record for tardiness
and absenteeism, and was issued several warnings and suspensions. Appellant
maintains his frequent absences were due to his wife’s medical condition. On
December 28, 2006, Appellant was suspended for two days and was warned that
further violations of attendance policies would result in his termination. Appellee
claims Appellant continued to violate company policies and on March 27, 2007
Appellant was given the option to resign or be terminated. He chose to resign.
As a consequence of his resignation, Appellant sought unemployment benefits
through the Division of Unemployment Insurance, which found him ineligible due
to the fact that Appellant had voluntarily resigned. Appellant appealed the decision
and the Referee determined that Appellant had been constructively discharged from
his position, as opposed to voluntarily resigning, but that the discharge was based on
Appellant’s wilful and wanton misconduct, rendering him ineligible for
unemployment benefits pursuant to 19 Del. C. §3314(2).1
Appellant appealed the Referee’s decision and on September 5, 2007 the Board
held a hearing to address the appeal. The Appellant and Ann Rutkowski, Appellee’s
representative, appeared and testified. In its decision the Board affirmed the
Referee’s decision denying unemployment benefits to Appellant, finding that he was
discharged from his employment for just cause.2 Subsequently, Appellant filed the
instant appeal, to which Appellee has responded. The following represents the
Court’s decision on the matter.
Standard of Review
This Court’s role in reviewing an appeal from the Board is limited to an
evaluation of the record, in the light most favorable to the prevailing party, to
determine if it includes substantial evidence that a reasonable mind accepts as
adequate support for the conclusion and is free from legal error.3 Therefore, the Court
does not address issues of credibility or independently weigh the evidence presented
to the Board.4 If the record supports the Board’s findings, the Court must accept
those findings even though the Court might reach a different conclusion on the facts
presented.5
Discussion
The question before this Court is whether the Board had substantial evidence
to determine that Appellant acted wilfully and wantonly when he continually violated
Appellee’s attendance policies, providing his employer "just cause" for his
termination, and excluding him from eligibility to receive employment benefits. The
Court finds that the answer to this question is yes and that the Board had substantial
evidence to reach its conclusion.
At the Board’s hearing, Appellee had the burden of proving by a preponderance
of the evidence that Appellant was terminated for just cause. Just cause is a "wilful
or wanton act or pattern of conduct in violation of the employer’s interest, the
employee’s duties, or the employer’s expected standard of conduct."6 This includes
conduct that is a conscious act by the claimant, or "reckless indifference leading to
a deviation from established and acceptable workplace performance."7 Additionally,
"just cause" exists if an employee violated a company rule, especially if he was on
notice of the rule.8
First, the Board agreed with the Referee’s determination that Appellant was
discharged from his employment as it is defined under the statute. Appellant was told
on his last day of work that he was going to be "let go," but was given the choice of
resigning as opposed to being terminated, and Appellant chose the former, not
wanting to tarnish his employment history with a termination. The Referee found that
because Appellant would have been discharged had he not resigned, he was in effect
"constructively discharged" from his position, triggering the application of 19 Del.
C. 3314(2). The Board in turn treated Appellant’s forced resignation as a discharge.
The Court agrees with this finding.
Second, Appellant testified before the Appeals Referee that he knew he was
in danger of losing his job if he continued violating the attendance polices.
THE REFEREE:
Mr. Thompkins, you did receive the
discipline in the suspension back in
December of ‘06 for excessive tardiness and
other attendance issues, is that correct?
IRVING THOMPKINS: Yes.
THE REFEREE:
Yes. And you knew that if you continued to
be late for work and miss work with an
unexcused absence that eventually you were
going to be terminated from your
employment?
IRVING THOMPKINS: Yes but I had a problem. My wife had sugar
real bad and had to go to the hospital with
her. . . 9
This testimony reflects that the Appellant was on notice that this pattern of
conduct was in violation of his employer’s interest and his failure to modify this
behavior would result in his termination. While the Court is sympathetic to
Appellant’s proffered reason for his absences, it appears that there was a gradual
disciplinary effort by the Appellee to raise its concerns with the Appellant, which
continued to be ignored by him. While appreciative of the Appellant’s wife’s medical
condition, the unique nature of Franciscan Elder Care’s work requires it to have a
reliable workforce, and the Appellant’s absences left them with no alternative other
than termination. Therefore, after examining the record below, the Court finds that
there was substantial evidence before the Board to show that Appellant was
discharged from his employment for just cause, and the Board’s decision is affirmed.
Conclusion
For the foregoing reasons, the decision of the Board is AFFIRMED.
IT IS SO ORDERED.
Judge William C. Carpenter, Jr.