IN THE COURT OF APPEALS OF IOWA
No. 1-296 / 00-1434
Filed September 12, 2001
DANA DELAIR,
Appellant,
vs.
EMPLOYMENT APPEAL BOARD OF THE DEPARTMENT OF INSPECTION
AND APPEALS,
Appellee,
and
GERKIN WINDOWS AND DOOR,
Respondent.
Appeal from the Iowa District Court for
Woodbury County, Robert C. Clem, Judge.
The petitioner appeals the district court’s ruling
on judicial review that affirmed the respondent bs
oard’denial of his claim for unemployment benefits
. AFFIRMED.
Roger L. Carter of Carter Law Firm, Sioux
City, for appellant.
Richard R. Ramsey, Des Moines, for app
ellee.
Considered by Sackett, C.J., and Vogel
and Vaitheswaran, JJ.
VOGEL, J.
Danne Delair appeals the district court judgment upholding
the Employment Appeal Board’s denial of his claim for
unemployment benefits. Because the agency decision
was supported by substantial evidence, we affirm the
district court.
Background Facts and Proceedings. Danne Delair was
hired by Gerkin Windows and Doors to perform a job
known as “boxing up doors.” The job required Delair
to lift the doors off the assembly line and then carry
and stack them. Delair contended that prior to being
hired, he informed Gerkin he had been in an accideand
nt, as a result had a weight restriction that prohibited
constant lifting in excess of forty to sixty pounds
s.[1] Gerkin’employees testified they were told of
the accident, but did not recall Delair ever mentioning
a weight restriction. Although he had not weighed
the doors, Delair believed many exceeded sixty poand
unds, stated he “was told” that some doors weighed
up to one hundred pounds. Gerkin asserted that most
of its doors were in the thirty-seven to forty pound
range, with a small number weighing sixty pounds.
It denied producing heavier doors.
Less than two weeks after being hired, while performing
his job duties, Delair felt something snap in his He
neck. reported the injury to a supervisor, then left
to seek medical attention. Delair was seen by a nurse
practitioner, who gave Delair an excuse for missing
two days of work, but did not place any restrictions
on the work he could perform once he returned to GIn
erkin. her progress notes the nurse practitioner
recorded the following: “Note given to be off work
today and tomorrow. Talked with him perhaps needing
to consider finding other work with the physical demands
of his current position. While he acknowledges thhe
is, is unsure of what he might do.”
After Delair returned to work, following the two excused
days, he informed Gerkin he would have to quit his
job if he was required to continue lifting heavy There
doors. is conflicting evidence as to whether Gerkin
was informed of the contents of the nurse practitis
oner’notes. Delair was then placed in a different
position where no heavy lifting would be required
. Delair put in a full day at the new position, but
early in his shift on the second day, the absence of
other employees prompted Gerkin to return Delair to
his former duties. Delair did not object to being
returned to a heavy-lifting task, and performed his
old job, without complaint, for about an hour. He
then informed his supervisors he was physically unable
to execute the current job tasks, and quit.
Delair filed a claim for unemployment compensation
, but was found to be ineligible for benefits by a
representative of Iowa Workforce Development. He
appealed this decision to Iowa Workforce Developms
ent’Unemployment Insurance Appeals Section, which affirmed
the ineligibility determination on the basis Delair
had voluntarily quit his employment without good cause
attributable to the employer. After the Employment
Appeal Board also affirmed the benefits denial, Delair
filed a petition for judicial review with the district
court. When the district court found substantial evidence
in the record to support the agency finding, Delair
filed this appeal.
Scope of Review. When a district court renders a decision
pursuant to Iowa Code section 17A.19, review is limited
to correcting errors at law. See Aluminum Co. of America
v. Musal, 622 N.W.2d 476, 478 (Iowa 2001).A party challenging
agency action bears the burden of demonstrating the
action’s invalidity and resulting prejudice. Iowa
Code § 17A.19(8)(a) (West Supp. 1999). This can be
shown in a number of ways, including proof that the
action was ultra vires, unconstitutional, legally arbitrary
erroneous, or capricious. See generally Iowa Code
§ 17A.19(10) (West Supp. 1999). A party can also
successfully challenge an agency action by demonstrating
the action was unsupported by substantial evidence
in the record, when that record is viewed as a whIowa
ole. Code § 17A.19(10)(f) (West Supp. 1999). See also
Koehler Elec. v. Wills, 608 N.W.2d 1, 3 (Iowa 2000
). Substantial evidence is that which would allow
a reasonable mind to reach the same conclusion as
the decision maker. See Koehler, 608 N.W.2d at 3.
Good Cause. A worker is not eligible for unemployment
benefits if he or she voluntarily quits without good
cause attributable to the employer. Iowa Code § 9When
6.5(1) (1999). a worker quits due to illness, that
quit is attributable to the employer if the illness
is aggravated by work conditions. See White v. Employment
Appeal Bd., 487 N.W.2d 342, 345 (Iowa 1992). Howethe
ver, worker must
present competent evidence showing adequate health
reasons to justify termination; before quitting have
informed the employer of the work-related health problem
and inform the employer that the individual intends
to quit unless the problem is corrected or the individual
is reasonably accommodated.
Iowa Admin. Code r. 871-24.26(6)(b).
As noted by the Iowa Supreme Court in Suluki v. Employment
Appeal Bd.:
We think it is logical, reasonable, fair, and practical
to require – as a condition of entitlement to unemployment
benefits – an employee to give an employer notice of
work-related health problems before quitting. Such
a requirement would enable an employer to correct the
working conditions causing the problem or provide the
employee with different job duties. Then if the employer
does not correct the problem or otherwise reasonably
accommodate the employee, the employee would have good
cause to quit. Such a requirement could result in
eliminating the need for the employee to seek unemployment
compensation benefits in the first place.
Suluki v. Employment Appeal Bd., 503 N.W.2d 402, 405
(Iowa 1993).
This notice requirement is not satisfied
by “preliminary understandings” about a work restriction
discussed at the time the worker is hired. See Cobb
v. Employment Appeal Bd., 506 N.W.2d 445, 448 (Iowa
1993). Rather, it is incumbent upon the employee to
remind the employer, at the time a task is assignethat
d, a restriction is being violated. See id. Notice
given at the time of the quit is notice “after the
fact,” because it does not allow the employer an opportunity
to resolve the problem. Id.
When applying these standards to the agency
record, there is substantial evidence to support a
finding Delair voluntarily quit without good cause
attributable to his employer. While the record indicates
his job duties did aggravate his preexisting neck and
back problem, nothing outside of Delair’s own testimony
affirmatively demonstrated that this problem compelled
or required him to quit his job. The nurse practis
tioner’notes stated only that she told him he should
consider finding a less demanding job. The agency
was free to interpret these notes as amounting to
something less than a medical direction to quit eparticularly
mployment, in light of the fact the nurse practitioner
did not find it necessary to place any medical restriction
on Delair’s return to work.
Similarly, the record sufficiently indicates
that Delair failed to provide Gerkin with adequate
notice of his intent to quit. Even if the agency
believed Delair’s testimony that Gerkin was on notice
of his weight restrictions at the time of hire, and
that his position did require him to lift amounts in
excess of the restriction, under Cobb such information
does not satisfy the notice requirement. Cobb, 506
N.W.2d at 448. Although Delair did tell his emploupon
yer, his return to work, that he would quit if he was
required to do heavy lifting, he did not protest when
the employer returned him to his old duties. Nor did
he, after discovering that his old job was now physically
difficult, remind the employer of his prior statement
and allow Gerkin an opportunity to provide a light
-duty accommodation.
An employer must be allowed an opportunity to provide
reasonable accommodations, after receiving notice.
See Suluki, 503 N.W.2d at 405. If an employee chooses
to silently endure an inappropriate or physically aggravating
job assignment, he cannot rely on prior notifications
to satisfy his notice obligation. See Cobb, 506 N
.W.2d at 448. Here, the time between Delair’s first
notice of intent to quit and his actual resignation
was punctuated by a heavy-lifting assignment to which
he raised neither protest nor complaint. His second
notice of intent to quit, occurring contemporaneously
with his resignation, did not allow Gerkin an opportunity
to make a reasonable accommodation. See id.
Given all the foregoing, the evidence substantially
supports the agency determination of voluntary quit
without good cause attributable to the employer. The
agency decision was not in any other manner arbitrthe
ary, capricious, result of a misapplication of law
, or violative of agency rule or procedure. We therefore
affirm the decision of the district court.
AFFIRMED.
[1] The accident referred to by Delair was a car
accident occurring in the 1980s, which resulted in
a broken neck.