IN THE DISTRICT COURT OF APPEAL
                                              FIRST DISTRICT, STATE OF FLORIDA

                                              NOT  FINAL  UNTIL TIME EXPIRES TO
NADINE G. MENDELSOHN,                         FILE  MOTION  FOR  REHEARING AND
                                              DISPOSITION THEREOF IF FILED
      Appellant,

v.                                            CASE NO. 1D02-377

F L O R I D A   U N E M P L O Y M E N T
APPEALS COMMISSION,

      Appellee.

_____________________________/


Opinion filed June 26, 2003.

An appeal from Order of Unemployment Appeals Commission.
 
Nadine G. Mendelsohn, Pro Se.

John D. Maher of Unemployment Appeals Commission, Tallahassee, for Appellee.





ALLEN, C.J.

      The appellant challenges an order by which the Unemployment Appeals
Commission upheld an appeals referee's dismissal of an administrative appeal after the
appellant failed to appear at the scheduled hearing.  The appellant sought Commission
review of the referee's decision, attempting to invoke such review with a request for
a redetermination.  The Commission concluded that the request was not timely filed
and that the referee's decision had thus become final, whereby the case was
dismissed.

       The record indicates that the appellant faxed a request for a redetermination to
the local appeals office, but that the fax was sent and received more than twenty days
after the referee's dismissal order was mailed to the appellant.  The request was thus
an untimely filing under section 443.151(4)(b)3, Florida Statutes, and the Commission
noted  that  the  appeal  was  outside  the  statutory  time  limit.  However, because the
appellant asserted that she had sent an earlier fax, the Commission remanded the case
to the appeals referee for evidence as to this allegation.

       At the hearing, the appellant testified that she had sent an earlier fax, but she
acknowledged  that  her  fax  machine  does  not  indicate whether a transmission is
successfully delivered.  She also indicated that she was having problems with her fax
machine, and that it would sometimes shut off before a transmission was made.  The
appellant testified that she did not think that had happened with her earlier fax, and she
submitted a copy of a phone bill showing a one minute call to a local number on that
date.  However, the appellant did not present any evidence to confirm that the
transmission was actually completed or received.  


       In  the  order  now  being  appealed,  the  Commission  found  that  the appellant's
redetermination  request  was  untimely.  This finding was made after an evidentiary
hearing according with the requirements of  Ebersol  v.  Unemployment  Appeals
Commission, 28 Florida Law Weekly D1052 (Fla. 5th DCA April 25, 2003).  Appellate
review  of  this  factual  finding  is  governed  by  §120.68(7)(b), Florida Statutes, which
precludes  an  assessment as to the weight of the evidence and instead directs that
factual determinations should be set aside when unsupported by competent substantial
evidence.  But there was such evidentiary support for the Commission's determination
here, given the appellant's testimony regarding the problems with her fax machine and
the absence of any evidence to show that a timely fax request was ever received for
filing in the appeals office.  

       Because  the  appellant  failed  to  establish  a  timely  filing under section
443.151(4)(b)3,  the  case  below was properly dismissed and the appealed order is
therefore affirmed.

HAWKES, J., CONCURS; BENTON, J., DISSENTS WITH OPINION.







BENTON, J., dissenting.

      The Unemployment Appeals Commission noticed a hearing for January 4, 2002,
specifying  that  "timeliness  of  the  appeal  to  the  Unemployment  Appeals  Commission
is the only issue to be discussed at this hearing."  The subject of the present appeal is
the  Commission's subsequent order dismissing Ms. Mendelsohn's administrative
appeal to the Commission as untimely.

      With  respect  to  the  timeliness  of  such  administrative appeals, Florida
Administrative Code Rule 60BB-5.005 provides:

             (1) The appeal shall be filed within 20 calendar days of the
             date the determination or redetermination was mailed to the
             appellant's last known address . . . .
             (2) The appeal shall be filed by mailing the appeal document
             . . . ; by facsimile transmission of the appeal document to
             any location designated in subsections 60BB- 5.004(1), (2),
             and (3), F.A.C.; or by hand delivery . . . .
             (3) Appeals filed by mail shall be considered to have been
             filed when postmarked by the United States Postal Service.
             Appeals  filed  by  hand  delivery or facsimile shall be
             considered to have been filed when date stamped received
             at the authorized location. 
             (4) Upon receipt of an appeal delivered in person or by
             facsimile  transmission,  the  Commission,  Agency for
             Workforce Innovation, or Office of Appeals employee shall
             record the date of receipt on the appeal document.

The order which Ms. Mendelsohn sought to appeal administratively was mailed to her
on October 16, 2001.


       Monday, November 5, 2001, was the twentieth day after October 16, 2001, and
therefore  the  deadline  for  filing  the  administrative  appeal.  Ms. Mendelsohn testified
that  she  filed  an  appeal  by  facsimile  transmission  on  November  2,  2001,  three  days
before the deadline.  See Perenzuela v. Fla. Unemployment Appeals Comm'n, 779 So.
2d 670 (Fla. 3d DCA 2001); see generally Miller v. State, 838 So. 2d 667 (Fla. 1st
DCA 2003).  

              Referee:         When  did  you  send  the  letter of appeal to
                               Fort Lauderdale?
              Mendelsohn: I faxed it on November 2nd.
              Referee:         How did you send it to them?
              Mendelsohn: I faxed it, which is what I had always done
                               before.

The referee tested this assertion by cross-examination along two lines, first inquiring
of Ms. Mendelsohn why, if she had faxed appeal papers on November 2, 2001, she
had sent a second fax on November 6, 2001:

              Referee:         Okay, but­and so what made you contact
                               Fort Lauderdale on November 6th?
              Mendelsohn: I  faxed over the letter from my attorney
                               along  with  another  letter  stating  here's
                               additional documents.   That's
                               number­number two. 
              Referee:         Document  number two that I mailed out to
                               you?
              Mendelsohn: Document  number  two, right and a request
                               for  redetermination,  appeal  faxed  to  you
                               November 2nd, I stated I would be sending
                               supplemental documentation and that was
                            the supplemental documentation.

In his second line of cross-examination, the referee questioned Ms. Mendelsohn as to
whether  the  facsimile  transmission  that  she  thought  she  had  accomplished on
November 2, 2001, had actually taken place.  She testified that it had, and that she
would have been aware if it had not been transmitted:

             Referee:       Prior to November 2nd, you had problems ­
             Mendelsohn: Yeah, I'd been having problems with it for a
                            while and it may have cut off or a call may
                            have come in.  We have what is it, ring
                            master?
             Referee:       I don't know.
             Mendelsohn: Call­call  waiting,  caller  id,  and if I don't
                            code  in  a  start  70  I  think it is, then a call
                            comes  in  and  it  shuts  off  the  fax,  and that
                            might­might have happened.
             Referee:       That could have happened on the 2nd of
                            November?
             Mendelsohn: No, it didn't happen on the 2nd.  Because if
                            it would have happened on the 2nd, I would
                            have tried to refax it.

The referee's cross-examination did not shake Ms. Mendelsohn's testimony that she
faxed  a  notice  of  appeal  on  November 2, 2001, that there had been no problem in
effecting that particular transmission, and that if there had been she would have been
aware of it.  Nobody put on evidence to contradict her testimony on any point.

      Nothing in the order under review explains the referee's fact finding.  The order
makes no reference to November 2, 2001, nor to any of the evidence adduced at the
hearing.  In broad boilerplate language, the order reads:

                      The appeals referee's decision was mailed to the
             appellant's  last  known  address  on  October 16, 2001, and
             the appeal to the Unemployment Appeals Commission was
             filed on November 6, 2001.
                    The  Florida  Unemployment Compensation law
             provides  that  the  referee's  decision  shall  be  final  unless,
             within 20 days from the date of mailing of notice thereof to
             the  parties'  last  known addresses, an appeal is initiated to
             the Unemployment Appeals Commission.  An appeal to the
             Commission was not filed within 20 days.

No  evidence  whatsoever, much less substantial, competent evidence, supports the
referee's  finding  that  an  "appeal  to  the  Commission was not filed within 20 days."
The  order  should  be  reversed  and  the  case should be remanded to the Commission
for a decision on the merits.

      A  telephone  bill  received  as  an  exhibit  at  the  hearing corroborates unrebutted
testimony that the fax call went through on November 2, 2001.  Even uncorroborated
testimony that mail has been sent or that a facsimile transmission has been made raises
a presumption of delivery.   

             See In re Hairopoulos, 118 F.3d 1240, 1244 (8th Cir.1997)
             ("A  letter  properly  addressed  and mailed is presumed to
             have  been  delivered  to  the  addressee.");  Wagner  Tractor,
             Inc. v. Shields, 381 F.2d 441, 446 (9th Cir.1967) ("There is
             a presumption of receipt after proper dispatch of a telegram
             analogous to letters properly mailed."). We see no
             principled reason why a jury would not be able to make the
             same inference regarding other forms of
              communication--such  as  facsimiles, electronic mail, and
              in-house  computer message systems--provided they are
              accepted  as  generally  reliable and that the particular
              message is properly dispatched. See, e.g., United States v.
              Galiczynski,  44  F.Supp.2d  707,  714  (E.D.Pa.) ("The
              rebuttable  presumption  of  service  by  mailing,  or  in  this
              case,  by  fax, can be established by pointing to
              circumstantial  evidence,  such  as  evidence  of  standard
              operating office procedures or business practices regularly
              used  concerning the mailing or faxing of documents by a
              party."),  aff'd,  203  F.3d  818  (3d  Cir.1999);  American
              Paging of Texas, Inc. v. El Paso Paging, Inc., 9 S.W.3d
              237, 240 (Tex.App.1999) ("Admission of evidence showing
              a  telephonic  document transfer to the recipient's current
              telecopier  number  gives  rise  to  a  presumption that notice
              was  duly  received  by  the  addressee.");  SSI  Med.  Servs.,
              Inc. v. State, 146 N.J. 614, 685 A.2d 1, 5- 6 & n. 1 (1996)
              (discussing nature of evidence required to raise
              presumption of mailing and receipt for electronic mail).

Kennell  v.  Gates,  215  F.3d  825,  829  (8th  Cir.  2000).  This presumption went
unrebutted  here.  Nobody testified that the Commission did not receive the fax Ms.
Mendelsohn  testified she sent on November 2, 2001 (or even that Commission staff
failed to date stamp it on November 2, 2001).  Ms. Mendelsohn was the only witness
who testified at the hearing. 

       For the foregoing reasons, I respectfully dissent.