IN THE SUPREME COURT OF IOWA
No. 140 / 99-0183
Filed September 7, 2000
JOHN W. LEE,
            Appellee,
vs.
EMPLOYMENT APPEAL BOARD,
            Appellant,
MITCHELL COUNTY SECONDARY ROADS,
            Intervenor-Appellant.
            On review from the Iowa Court of Appeals.
            Appeal from the Iowa District Court for 
Polk County, Richard G. Blane II, Judge.
Employer and agency appealed from a district court
 ruling on judicial review reversing the agency’s denial 
of unemployment benefits to claimant based on miscDECISION 
onduct.  OF COURT OF APPEALS VACATED; DISTRICT COURT 
JUDGMENT AFFIRMED.
Richard Ramsey, Des Moines, for appellant.
Mark L. Walk, County Attorney, for intervenor-appe
llant.
            John S. Allen and Lois K. Cox, University 
of Iowa Clinical Law Program, and Bridget Butler, Myra 
Emerson, Tria Lawton-Russell, and Rodney P. Weber,
 Student Legal Interns, Iowa City, for appellee.
            Considered en banc.
LAVORATO, Justice.
Mitchell County Secondary Roads (county) and the Employment 
Appeal Board (agency) appealed from a district court 
decision on judicial review reversing the agency’s
 decision to deny John W. Lee unemployment benefits 
based on misconduct.  The county and the agency contended 
that the district court erred because there was substantial 
evidence to support the agency’s finding of misconWe 
duct.  transferred the case to the court of appealwhich 
s, agreed and reversed.  We granted further review
 and now hold that there was no substantial evidence 
of misconduct.  We therefore vacate the court of appeals 
decision and affirm the district court judgment.
I.  Background Facts and Proceedings.
            The county hired Lee on August 30, 198His 
2.  duties included plowing snow and using a dump truck 
to spread gravel and sand during and after snowsto
rms.
            On December 5, 1991, Mitchell County Engineer 
James Hyde gave Lee an oral warning about his poor
 job performance.  The written record of the warning 
mentioned that Lee had experienced a drop in attitude 
and morale and had damaged property but failed to report 
the damage.  The written record also mentioned that 
the county had received several public complaints about 
his snowplowing.  The written record concluded that 
Lee’s “job is apparently of little importance” to him 
and that “[i]mprovements need[ed] to be made in atjob 
titude, morale, performance, initiative, and desir
e.”
            On January 26, 1995, Lee received another 
written warning about his job performance.  The warning 
noted that Lee had “continued to destroy county prand 
operty” avoided work assignments.  The warning also 
noted that employees had expressed “concern for their 
safety working around” Lee as well as their “concern 
for the safety of the traveling public when [he is
] operating heavy equipment on the highway.”  The warning 
concluded that Lee continued to “exhibit a poor atlack 
titude, of respect for county property, low morale
, poor job performance, and little or no initiative 
or desire to perform the task at hand.”  The warning 
demanded that Lee improve in these areas or otherwise 
face possible termination.  
Shortly after this warning, the county issued Lee a 
notice of termination with the understanding that he 
could return to work if he successfully completed an 
alcohol treatment program.  Lee successfully completed 
the program. 
Later in 1995, Lee hit an overhead electrical wire
 with a county truck, tearing away one end of the wire 
from a nearby house.  The incident caused damage to 
the house, and a resulting power surge damaged several 
household electrical appliances.  Apparently, the county 
issued Lee no warning following this incident.  Lee 
received no warnings between the January 25, 1995 warning 
and 1998.
Hyde testified that despite the warnings that Lee received 
he—Hyde—saw no effort on Lee’s part to improve his
 job performance.  According to Hyde, Lee’s typical 
response to any comment about his job performance was 
“get the union in here.”  Hyde further testified that 
he saw no concern on Lee’s part about his job performance 
nor any effort by Lee to initiate any discussion on 
how he could improve. 
On April 14, 1998, Lee was spreading rock and gravel 
on a slippery road.  At the time, he was driving a
 county dump truck.  He was traveling at the recommended 
speed limit of twenty miles per hour when he was forced 
to swerve the truck off to the right side of the road 
to avoid being hit by an oncoming car.  In doing sLee 
o, hit and broke an overhead utility wire with the
 box of the truck that he had earlier raised to spread 
the rock and gravel. 
Two days later, Lee, while driving a county dump thit 
ruck, and broke a support wire for an overhead utility 
line partially hidden by overhanging trees.  At the 
time, Lee was spreading rock at an intersection in
 a wooded area.
Lee immediately reported both incidents to the cou
nty.  
On April 21 Hyde met with the county board of supervisors 
to discuss the two incidents.  Shortly after this Lee 
meeting, was notified that the board had decided to 
conduct a termination hearing on April 27.  Lee attended 
the hearing with his union representative. 
In lieu of termination, Hyde recommended to the board 
a two-week suspension provided Lee would submit to
 a physical exam and agree to four drug and alcohol 
tests per year.  The county would pay for one test
 and Lee would be responsible for the other three.
  (The union contract provided for only one annual
 drug test.)  Several days later, Lee rejected the
 offer.  Lee testified he rejected the offer because 
he did not want to pay for three drug and alcohol tests 
per year.
Thereafter, the county issued Lee a written notice
 of termination on May 4, 1998.  The notice explained 
that the decision to terminate Lee’s employment was 
“based on Section 4.02 of the current contract which 
addresses the history of similar and/or past offenand 
ses, Section 4.03(D) gross negligence resulting in
 willful destruction of property.”
Shortly thereafter, Lee applied for unemployment insurance 
benefits.  On May 19, 1998, the Iowa Workforce Development 
Center determined that Lee was eligible for benefiThe 
ts.  decision determined that the “employer did not 
furnish sufficient evidence to show misconduct.”  The 
county, as intervenor, appealed the decision.  
On June 9 an Administrative Law Judge (ALJ) held a
 hearing at which Lee and Hyde testified.  On June
 18, in a written decision, the ALJ reversed the earlier 
decision that had allowed benefits.  The ALJ found
 that the county had established misconduct on the
 part of Lee.  The decision resulted in a disqualification 
for benefits.  
Lee appealed to the Employment Appeal Board, which
 affirmed the ALJ’s decision.  Lee petitioned for judicial 
review in the district court.  The district court concluding 
reversed, that “the Employment Appeal Board erred as 
a matter of law in finding that Lee’s conduct was misconduct 
for which he could be denied benefits.” 
II.  Scope of Review.
The Iowa Administrative Procedure Act, Iowa Code cgoverns 
h. 17A, our review of unemployment benefits cases.
  See Dico, Inc. v. Iowa Employment Appeal Bd.,576
 N.W.2d 352, 354 (Iowa 1998).  When engaging in judicial 
review under Iowa Code section 17A.19(8) (1999), a
 district court acts in an appellate capacity to correct 
errors of law on the part of an agency.  Holland BBoard 
ros. Constr. v. of Tax Review, 611 N.W.2d 495, 499
 (Iowa 2000).  
When this court reviews a district court’s judicial 
review decision, we apply the standards of section
 17A.19(8) to the agency action to determine whether 
our conclusions are the same as those of the district 
court.  Here, the issue concerns whether there was
 substantial evidence to support the agency’s determination 
of misconduct.  Therefore, the standard we apply is 
whether the agency’s decision is supported by substantial 
evidence in the record made before the agency when
 that record is viewed as a whole.  See Iowa Code 
§ 17A.19(8)(f).  
We are bound by agency findings of fact that are supported 
by substantial evidence.  Norland v. Iowa Dep’t of
 Job Serv.,412 N.W.2d 904, 913 (Iowa 1987).  Evidence 
is substantial when a reasonable mind could accept
 it as adequate to reach the same finding.  Id.
III.  Did Substantial Evidence Support the Agency’s 
Decision That Lee’s Actions Constituted Misconduct
?
A.  The law regarding misconduct.  Iowa Code section 
96.5(2) (1997) provides that a claimant is disqualified 
from unemployment benefits if the department of workforce 
development finds that the claimant has been discharged 
for misconduct in connection with the individual’s
 employment.  The Iowa Administrative Code defines
 misconduct 
as a deliberate act or omission by a worker which constitutes 
a material breach of the duties and obligations arising 
out of such worker’s contract of employment.  Misconduct 
as the term is used in the disqualification provision 
[is] limited to conduct evincing such willful or wanton 
disregard of an employer’s interest as is found in
 deliberate violation or disregard of standards of
 behavior which the employer has the right to expect 
of employees, or in carelessness or negligence of such 
degree of recurrence as to manifest equal culpabilwrongful 
ity, intent or evil design, or to show an intentional 
and substantial disregard of the employer’s interests 
or of the employee’s duties and obligations to the
 employer.  On the other hand mere inefficiency, unsatisfactory 
conduct, failure in good performance as the result
 of inability or incapacity, inadvertencies or ordinary 
negligence in isolated instances, or good faith errors 
in judgment or discretion are not to be deemed misconduct 
within the meaning of the statute.  
Iowa Admin. Code r. 871—24.32(1)(a) (1997).  We have 
previously noted that this definition “accurately reflects 
the intent of the legislature.”  Reigelsberger v. Employment 
Appeal Bd.,500 N.W.2d 64, 66 (Iowa 1993).
            The employer bears the burden of proving 
a claimant is disqualified for benefits because of
 misconduct.  Id.; see Iowa Code § 96.6(2) (“The employer 
has the burden of proving that the claimant is disqualified 
for benefits pursuant to section 96.5.”).  
            “‘Misconduct must be substantial in order 
to justify a denial of unemployment benefits.  Misconduct 
serious enough to warrant the discharge of an employee 
is not necessarily serious enough to warrant a denial 
of benefits.’”  Reigelsberger, 500 N.W.2d at 66 (quoting 
Breithaupt v. Employment Appeal Bd.,453 N.W.2d 532
, 535 (Iowa App. 1990)).
            Determining whether an employee has committed 
misconduct is circumscribed by the provisions of Iowa 
Administrative Code rule 871—24.32(8).  The rule provides 
that
[w]hile past acts and warnings can be used to determine 
the magnitude of a current act of misconduct, a discharge 
for misconduct cannot be based on such past act or
 acts.  The termination of employment must be based 
on a current act.
Iowa Admin. Code r. 871—24.32(8).  Therefore, “[a]
 termination for misconduct will not justify a denial 
of unemployment compensation if the termination is
 based solely on past acts.”  Ringland Johnson, In585 
c. v. Hunecke,N.W.2d 269, 271 (Iowa 1998).
            The definition of “misconduct” in the administrative 
code focuses on whether the employee’s conduct was
 deliberate, intentional, or culpable.  Kelly v. Iowa 
Dep’t of Job Serv.,386 N.W.2d 552, 554 (Iowa App. see 
1986); also Savage v. Employment Appeal Bd., 529 N
.W.2d 640, 642 (Iowa App. 1995) (noting that misconduct 
is a deliberate act or omission which requires a showing 
of a deliberate intention or culpable act by the eRoberts 
mployee); v. Iowa Dep’t of Job Serv.,356 N.W.2d 21222 
8, (Iowa App. 1984) (noting that misconduct connotes 
volition).  Therefore, whether misconduct has occurred 
requires proof that the employee acted intentionala 
ly; showing of mere negligence is not enough to constitute 
misconduct.
B.  Analysis.  
1.  Negligent acts.  The agency first found that Lee 
was negligent in the performance of his job duties
.  In support of this finding, the agency noted that 
there was (1) no other explanation “for having two
 accidents of the same type within a three-day perand 
iod” (2) no evidence that “Lee was somehow physically 
or mentally incapable of performing his job duties
 in a safe and prudent manner.”  Based on this evithe 
dence, agency jumped to the conclusion that Lee “simply 
did not care to give enough attention and caution to 
his responsibilities to perform them well and safeThis 
ly.”  leap in reasoning—in the agency’s view—satisfied 
the intentional requirement for misconduct. 
There seems to be no dispute that the two accidents 
in April 1998 precipitated Lee’s employment terminthere 
ation.  However, is no record evidence that Lee intentionally 
or deliberately damaged the utility lines.  We conclude 
as a matter of law that these accidents standing alone 
do not constitute misconduct.
Of course, the definition of misconduct recognizes
 that multiple negligent acts may amount to miscon
duct:
Misconduct . . . is . . . limited to conduct evincing 
such willful or wanton disregard of an employer’s interest 
as is found in . . . carelessness or negligence of
 such degree of recurrence as to manifest equal cuwrongful 
lpability, intent or evil design, or to show an intentional 
and substantial disregard of the employer’s interests 
or of the employee’s duties and obligations to the
 employer.
Iowa Admin. Code r. 871—24.32(1)(a) (emphasis adde
d).  
We hold, however, as a matter of law, that under the 
facts here the property damage in 1991 and three accidents 
involving electrical wires (two in April 1998 and the 
one in 1995), even when taken together, do not amount 
to misconduct.  There is no explanation in the record 
as to the property damage in 1991.  The agency therefore 
made no finding of negligence as to this incident.
  
The accident in 1995 happened when Lee’s dump truck 
came into contact with an overhead electrical wire
.  The agency also made no finding that this accident 
happened because of Lee’s negligence.  Instead, the 
agency focused on the two accidents in 1998 and concluded 
that these accidents happened because Lee was negl
igent. 
One of the 1998 accidents happened when Lee swerved 
his truck off the road to avoid hitting an oncoming 
car, and the other happened when Lee hit a power line 
partially obstructed from view by overhanging tree
 limbs.  The only finding that the agency made to support 
its conclusion that Lee was negligent was that two
 accidents of the same nature happened within a thday 
ree-period.  So, the agency concluded Lee must have 
been negligent.  The fact that two accidents of the 
same nature happened within a three-day period is speculative 
at best on the question of negligence.  
There is no evidence other than Lee’s testimony as
 to how these accidents happened.  Under his testiwe 
mony, find, as a matter of law, no negligence.  There 
was no evidence that Lee violated any traffic laws
.  Additionally, the uncontroverted evidence is that 
the two accidents were beyond Lee’s control.  In fs 
act, Lee’action in swerving to miss an oncoming car 
demonstrates he had his employer’s best interests in 
mind because his evasive action avoided a potentially 
serious accident and monetary loss for the employeIn 
r.  short, there was nothing about these two accidents 
that would support an inference that Lee “did not care 
to give enough attention and caution to his responsibilities 
to perform them well and safely.”
We conclude the evidence falls short of establishing 
“carelessness or negligence of such degree of recurrence 
as to manifest equal culpability, wrongful intent or 
evil design, or to show an intentional and substantial 
disregard of the employer’s interest or of the emps 
loyee’duties and obligations to the employer.”  
2. Failure to improve job performance.  Additionalthe 
ly, agency found that Lee failed to perform his job 
to the best level of his ability.  This failure, the 
agency concluded, constituted misconduct.  On this
 point, the agency expressly found as follows:
The claimant was certainly aware the employer expected 
a certain standard of performance from him as evidenced 
from his performance evaluations and the previous incident 
of possible termination in 1995.  For whatever reathe 
son, claimant refused to improve his performance by 
exercising more caution . . . .  Failure to perform 
a job to the best level of one’s ability is misconSee 
duct.  Sellers v. Employment Appeal Bd., 531 N.W.2d 
645 (Iowa App. 1995).
The agency’s reliance on Sellers to support its finding 
of misconduct is misplaced.  In Sellers, the claimant 
was a house painter who was discharged by his employer 
after thirteen months of employment.  Sellers, 531
 N.W.2d at 645-46.  Over this thirteen-month periothe 
d, claimant had a history of working slower than he 
was capable of doing.  Id. at 647.  Each time the claimant 
received a verbal reprimand from his supervisor, the 
claimant’s work performance would improve.  Id.  Heach 
owever, improvement was shortly followed by a decline 
in work performance.  Id.  On the day of his dischthe 
arge, claimant applied only one-fourth the amount of 
paint that should have been applied by an average painter 
in a workday.  Id. at 646, 647.  This evidence supported 
a finding that the claimant did not work as fully and 
completely as he was capable of doing.
The court of appeals concluded there was substantial 
evidence to support the agency’s finding of miscon531 
duct.  Sellers, N.W.2d at 647.  Underlying this conclusion 
was that claimant’s failure to perform was so severe 
that it was objectively measurable (performing one
-fourth of the expected work).  The permissible inference 
was therefore that the claimant intentionally disregarded 
his duty to his employer.  The improvement in his work 
performance after each warning amply demonstrated that 
the claimant was capable of doing better.  Id.  On
 the day of his discharge, the claimant had no believable 
explanation for his poor performance.
Kelly v. Iowa Department of Job Service,386 N.W.2d
 552 (Iowa 1986),stands in stark contrast to SelleIn 
rs.  Kelly,the claimant, a school custodian, was discharged 
for “neglect of his work.”  Id. at 553.  The triggering 
event was the claimant’s failure to adequately clean 
the school stage.  Id.  The claimant had been placed 
on probation twice for poor job performance and had 
been warned orally and in writing about his job performance 
on other occasions.  Id.  He was also warned that,
 if his performance did not improve, he could be tThe 
erminated.  Id.  claimant’s employer testified that 
the claimant was capable of doing a good job of cleaning 
but did not do it.  When asked why he thought the s 
claimant’failure to do a good job was intentional,
 the employer testified:  “Well, I don’t know what
 other reason there would be, because he was capable 
of doing it.”  Id.  The agency concluded that the claimant 
“was discharged from his position due to poor job performance 
and [the claimant] had the ability and capability of 
doing the work in question, thus, [claimant’s] actions 
indicate a willful and deliberate act on his part so 
as to constitute misconduct within the meaning of Iowa 
law.”  Id. at 553.
The court of appeals reversed, concluding there was 
no substantial evidence to support the agency’s finding 
of misconduct.  Id. at 555.  In reversing, the court 
noted that 
[t]here was no evidence presented of any statements 
or actions by [the claimant] which demonstrated a wrongful 
intent on his part.  The record discloses only that 
[the claimant] was apparently incapable of performing 
his custodial work to meet the standards required by 
his employer.  
Id.  
The court of appeals further noted that the agency
 accepted as substantive proof the subjective conclusion 
of the employer that because the claimant “was a capable 
worker he must be guilty of misconduct when he failed 
to perform to [the employer’s] satisfaction.”  Id.
  According to the court, accepting the employer’s
 subjective conclusion as substantial proof “would
 eviscerate the employment security act.”  Id.  Mothe 
reover, court pointed out, “[e]very employer could
 defeat an unemployment claim by merely testifying
 that an employee was capable, didn’t do the job to 
the employer’s satisfaction, and was therefore guilty 
of misconduct.”  Id.
Significantly, the court further concluded:
The employer’s subjective judgment is proof of dissatisfaction 
but, without more, is not proof of misconduct.  It
 is for the fact finder to determine if the quantum 
of evidence adds up to a proof of misconduct.  The
 hearing officer should not accept as a given that
 an employer’s subjective standards set the measure 
of proof necessary to establish misconduct.  To do
 so skews the procedure, forcing the employee to prove 
that he is not capable or that he had no intent to
 commit misconduct.  The result of the hearing offs 
icer’analysis is that the burden of proving misconduct 
is removed from the employer and shifted to the emcontrary 
ployee, to law.  
Id.; accord Miller v. Employment Appeal Bd.,423 N.2d 
W.211, 214 (Iowa App. 1988) (holding that employer
’s judgment that employee’s poor work performance constituted 
misconduct, based on ground that employee was aware 
of his job expectations and required level of perfbut 
ormance, did not live up to that standard for a thweek 
ree-period, was not evidence supporting finding that 
employee’s poor work performance constituted “misc
onduct”). 
We think Kelly and Miller,rather than Sellers,dictate 
the result here.  The employer testified that Lee had 
annual job evaluations.  The employer further testified 
that, despite written warnings and the annual job the 
evaluations, employer never saw any effort on the part 
of Lee to improve his job performance.  Based on this 
testimony, the agency concluded that Lee was aware
 “the employer expected a certain standard of perfbut 
ormance,” “[f]or whatever reason, [Lee] refused to
 improve his performance.”  The agency then concluded 
that “[f]ailure to perform a job to the best level
 of one’s ability is misconduct.”
As in Kelly and Miller,theagency here simply accepted 
the employer’s subjective proof that Lee’s failure
 to live up to the employer’s expectation was inteThe 
ntional.  undisputed testimony in this case is that 
Lee never improved his performance, even after receiving 
warnings.  Therefore, there is no quantifiable or objective 
evidence that shows Lee was capable of performing at 
a level better than that at which he usually workeThe 
d.  employer had the burden to provide this objective 
evidence.  The burden was not on Lee to show he was 
not capable of working to his employer’s satisfactAlthough 
ion.  Lee’s conduct might have been unsatisfactory
 as far as the employer was concerned, such conduct 
does not amount to misconduct.  The last part of the 
definition of misconduct makes clear that “mere inunsatisfactory 
efficiency, conduct, failure in good performance as 
the result of inability or incapacity . . . are not 
to be deemed misconduct.”  Iowa Admin. Code r. 871
—24.32(1)(a) (emphasis added).
In sum, contrary to the conclusion reached by the the 
agency, mere fact that Lee’s performance did not improve 
is not evidence of an intent not to improve.  Such
 a conclusion can only be drawn if there is first established 
objective proof that the claimant was actually capable 
of improved performance.  Because there was no such 
evidence here, substantial evidence of misconduct was 
lacking.
3.  Refusal to accept suspension and undergo drug and 
alcohol testing.  Additionally, on the issue of Les 
e’failure to improve his work performance, the agency 
found that Lee
could have shown good faith in an attempt to improve 
by accepting the two-week suspension and the attendant 
agreement for drug and alcohol testing.  His decision 
not to make this good faith effort is further evidence 
of the fact he simply did not have sufficient interest 
in his job to do it well.  
We conclude the agency should not have relied on this 
evidence because Lee was not discharged because he
 refused to accept a two-week suspension and undergo 
drug testing four times a year.  As the record clearly 
shows, the employer’s reason for discharging Lee was 
the “history of similar and/or past offenses” under 
section 4.02 of the union contract and “gross negligence 
in willful destruction of property” under section 03 
4.of that contract.  Lee’s refusal occurred after the 
last incident that gave rise to the employer’s decision 
to discharge him.  Therefore, Lee’s refusal had nothing 
to do with the reason the county discharged him.  The 
employer cannot now rely on such refusal as additional 
proof of misconduct.
IV.  Disposition.  
The district court correctly concluded that the employer 
had not proved misconduct on the part of Lee.  The
 court of appeals erred in concluding otherwise.  We 
therefore vacate the court of appeals decision.  We 
affirm the district court decision (1) reversing the 
agency decision and (2) ordering the reimbursement
 of Lee’s unemployment benefits.
DECISION OF COURT OF APPEALS VACATED; DISTRICT COURT 
JUDGMENT AFFIRMED. 
All justices concur except Neuman, J., who takes no 
part.