REPORTED


  IN THE COURT OF SPECIAL APPEALS


                OF MARYLAND


                 No. 0933


           SEPTEMBER TERM, 2001


                                   




     LAUREL RACING ASSOCIATION
    LIMITED PARTNERSHIP ET AL.


                    v.


   JOSEPHA M. BABENDREIER ET AL.




                                   





Kenney,
Krauser,
Bloom, Theodore G., (Ret'd,
                   specially assigned),



                          JJ.




                                   


           Opinion by Kenney, J.


                                   




              Filed: September 3, 2002


       Appellants, the Laurel Racing Association Limited Partnership


("Laurel Racing"), the Maryland Jockey Club of Baltimore City, Inc.


("MJC"), and Race Track Payroll Account, Inc. ("RTPA"),1 appeal the


decision of the Circuit Court for Anne Arundel County in favor of


appellees, Josepha Babendreier, the Board of Appeals (the "Board"),


and the Department of Labor, Licensing and Regulation ("DLLR").2


The Board had affirmed its hearing examiner's ruling that


Babendreier was eligible for unemployment benefits.  We have


consolidated and reworded appellant's questions for review as


follows:3



       1 Laurel Racing and MJC were not parties to the unemployment proceedings before the
Department of Labor, Licensing and Regulation, but joined RTPA as petitioners before the
Circuit Court for Anne Arundel County.  They claim standing based upon the collective
bargaining agreement they entered into with the United Food and Commercial Workers Union,
Local 27.

       2 The Board filed a response to RTPA's petition for judicial review before the circuit
court and a brief in this appeal.  Md. Code Ann. (1991, 1999 Repl. Vol., 2000 Supp.), § 8-
512(a)(3) of the Labor and Employment Article ("LE"), provides: "The Board of Appeals may be
a party to an appeal under this section and may be represented by the Attorney General[.] "

       3 Appellants presented the following questions:


               I.      Did the Circuit Court exceed its authority by affirming the
                       Board's Decision on a ground that was not relied on by the
                       Hearing Examiner?
               II.     Did the Circuit Judge err by failing to address the
                       Appellants' argument concerning the arbitrary nature of the
                       Board's decision, and by failing to find the agency's action
                       arbitrary in light of its directly inconsistent decision in
                       Keller?
               III.    Did the Circuit Judge and the Board of Appeals err by
                       finding that Appellee Babendreier was eligible for
                       unemployment benefits, despite her failure to be fully
                       available to work as required by the Court of Appeals'
                       Decision in Robinson?


                                              -2-




               Did the Board err in concluding that
               Babendreier was "available" for work pursuant
               to the Labor & Employment Article, § 8-
               903(a)(1)(ii) of the Maryland Annotated Code?


       Finding no error, we affirm.


                        FACTUAL AND PROCEDURAL BACKGROUND


       Appellants own and operate Laurel Park and Pimlico Race Course


("Pimlico"), in addition to Rosecroft Raceway, a live racing and


simulcast venue for live races held at other tracks.  Babendreier


was employed as a Mutuel Department teller by RTPA, which provides


employee and payroll services at the race tracks.4


       For many years, Laurel Park and Pimlico employees have been


represented by United Food and Commercial Worker's Union, Local 27





Babendreier presented the question as follows:


               Did the UI claimant, Josepha M. Babendreier, satisfy her
               obligation under Lab. & Employ. § 8-903(a)(1)(iii) to be "actively
               seeking work" when she applied for full-time employment at least
               twice each week with prospective employers nearby her home,
               although she did not travel 60 miles a day from her home in
               Damascus, [Maryland,] to the Employer's "live track" at Pimlico
               Race Course to sign-in to apply for work each day of the
               Employer's race meet?


 The Board posed the question as follows:


               Based upon the undisputed facts found by the agency, could a
               reasoning mind reasonably conclude that Babendreier was
               available for work within the meaning of § 8-903(a)(1)(iii)?

       4 A mutuel teller accepts bets from patrons.  These tellers are all unionized and have a
specified seniority system.


                                              -3-


(the "Union" or "UFCW 27"), of which Babendreier was a member.


Their employment relationship is governed by the collective


bargaining agreement (the "Agreement" or "Separate Agreements"),


effective July 1, 1996, through June 10, 1998, by and between


Laurel Park and Pimlico, collectively referred to therein as "Mile


Tracks," and the Union.   On or about May 31, 1998, a "Memorandum


Agreement" was executed, which included RTPA as an "Employer under


the Separate Agreements," in addition to Laurel Park and Pimlico.5


The Agreement reads, in pertinent part:


                                         AGREEMENT


                      These separate Agreements are made and
              entered into by LAUREL RACING ASSOC., INC.,
              generally known as LAUREL PARK, and THE
              MARYLAND JOCKEY CLUB OF BALTIMORE CITY, Inc.,
              generally known as a PIMLICO RACE COURSE (each
              being referred to as the "Employer" and the
              two Employers together constituting the
              Maryland Mile Thoroughbred Race Tracks
              licensed by the Maryland Racing Commission and
              being sometimes hereinafter collectively
              referred to as the "Mile Tracks," and UNITED
              FOOD AND COMMERCIAL WORKERS UNION, LOCAL 27
              (herein referred to as the "Union"), as of the
              1st day of July, 1996.


                                        WITNESSETH


                      In consideration of the mutual promises
              contained in this Agreement, and for other
              good and valuable consideration, each Employer
              agrees with the Union as follows:





       5 The "Memorandum Agreement" also extended the effective date of the Agreement
"through and including June 30, 2000," and included a provision regarding seniority for any
"Regular Employee" assigned to work at Rosecroft Raceway, but who elected to sign-in at either
Laurel Park or Pimlico.


                         -4-


                        * * *


                      ARTICLE 4
                      Seniority


Section 1.


     a.       The purpose of seniority is to
              provide a right of preference in
              employment measured by length of
              continuous service with the
              Employer, including service prior to
              the effective date of this
              Agreement.  Except as set forth in
              Section 1(c) of this Article, an
              employee shall have no preference
              for work assignment until he has
              obtained seniority standing as a
              Regular, Extra or Saturday/Holiday
              Employee in accordance with Section
              2 of this Article.


     b.       All employees shall be considered
              Probationary Employees at an
              Employer's track until they have
              completed 30 days of work from the
              date they first began to work at
              such track.  A Probationary Employee
              shall have no rights to any work
              assignment and the decision of the
              Employer in its sole discretion
              whether or not to give such
              Probationary Employee any work
              assignment shall be final.


     c.       All employees who have completed the
              30 days probationary work period but
              have no Regular, Extra or
              Saturday/Holiday seniority standing
              shall be placed on a "Days Worked
              Seniority List" in the order of
              total days worked for the Employer.
              The employee with the most days
              worked shall be selected first for
              purposes of work assignment.  Each
              department at each Employer's track
              shall maintain its own work list and
              the Mutuel Department at each


                        -5-


      Employer*s track shall post such
      list on a weekly basis on its main
      bulletin board.  Any employee who
      disputes his order of placement on
      the Days Worked Seniority List must
      bring such dispute to the attention
      of his Department Head on the day
      the list is posted.  Failure by the
      employee to do so is at the
      employee*s own risk and the Employer
      shall have no liability for not
      having given such employee a work
      assignment on that or any previous
      day.


                   * * *


e.    The most senior employee within a
      department shall have the right to
      work on any given day in the
      department in which he has
      seniority.  (For example, if there
      are 20 positions in the Parking
      Department, then the 20 employees
      with the most Parking Department
      seniority will be assigned those 20
      positions.  The 21st employee
      according to seniority will not have
      the right to work before any of the
      first 20 senior employees.)


      Thus, on a normal racing day with
      the exception of Saturdays and
      Holidays, job assignments shall be
      filled as follows:


              First:           b y   R e g u l a r
                               employees.


              Second:          by Extra employees.


              Third:           by Saturday and
                               Holiday employees.


              Fourth:          by employees on the
                               D a y s   W o r k e d
                               Seniority List at
                               the running track.


                                   -6-


                           Fifth:         by any other
                                          employees at the
                                          sole discretion of
                                           the Employer.


                                  * * *


                               ARTICLE 5
                                Layoffs


      Section 1.


             The determination of whether there shall
             be a layoff is the prerogative of the
             Employer.  If employees in any
             classification in Schedule A[6] are to be
             laid off,  the Employer shall lay off
             employees in such classifications in
             accordance with their departmental
             seniority; that is, commencing with the
             employee having the least departmental
             seniority in the affected classification.
             Extra Employees shall be laid off before
             Regular Employees; and, in the case of
             S a t u r d a y / H o l i d a y   j o b s   o n l y ,
             Saturday/Holiday Employees shall be laid
             off before Extra Employees on regular
             workdays (i.e., days other than Saturday
             and Holidays).  However, layoffs out of
             the Mutuel Department Money Room shall be
             by sub-departmental seniority, unless
             this results in the employee not working;
             then Money Room layoffs shall be by
             departmental seniority.


                                  * * *


      Section 6.


             Any Regular Employee who is laid off
             under this Article shall remain a Regular
             Employee for the duration of the calendar
             year in which he is laid off.  If he does
             not work enough days to maintain his
             Regular seniority, he shall be placed at




6 Babendreier was a Schedule A employee.  


                                  -7-


               the top of the Extra list in the
               following year, and shall then be slotted
               for the third year onto a seniority list
               according to the days worked in the
               previous year.  However, if he is
               restored to the Regular seniority list
               within three (3) years after the date of
               his layoff, his seniority as a Regular
               shall include the seniority he had
               accrued prior to the date of his layoff,
               unless he has lost his seniority pursuant
               to any of reasons 1 through 4 of Section
               6 of Article 4.


                                  * * *


          Section 9.


               When the work force is increased, or when
               there is work available, following a
               layoff, the Employer shall recall
               employees to a classification in the
               reverse order in which they were laid
               off, so that the last employee laid off
               in any classification shall be the first
               recalled in that classification.
               Employees who bumped downward, upward or
               laterally as a result of the layoff shall
               be returned to their usual
               classifications in the reverse order in
               which they bumped during a layoff.


     The Agreement did not require Babendreier to report to work


each day, did not require appellants to notify employees that work


was available on any given day, and did not require employees to


inquire about the availability of work.  Although no contact was


required by either Babendreier or her employer, appellants mailed


to all employees a postcard offering work assignments in advance of


the Preakness, the Pimlico Special, and the Kentucky Derby.


     When live racing meets alternate between Laurel Park and


                                                -8-


Pimlico, each venue utilizes a separate employee seniority list


based upon an employee's period of service at that respective


track.  When live racing takes place at a particular track, the


race is simulcast at the other track and at Rosecroft.


       Babendreier primarily worked during the Laurel Park meets, but


received work assignments for special events at the Pimlico meets.


As a result of her tenure at Laurel Park, Babendreier was


designated with "Extra-Employee" seniority,7 guarantying her work


during Laurel Park's "live racing days."8  On July 12, 1998,


Babendreier was one of eight "bid winners" for positions as "full-


time tellers at Rosecroft for the Laurel Meet." She thereby became


a full-time "Regular Employee" on the Laurel Park seniority


roster.9


       Babendreier maintained, however, only a "Days Worked" status





       7 An "Extra Employee" "refers to an employee who has attained and continuously
maintains Regular Seniority standing under the terms of Article 4" of the Agreement.

       8 "[L]ive racing days" and "racing days" are defined in the Agreement as "any days on
which live or live and simulcast racing is conducted by the Employer."  Live racing days are
assigned to MJC entities by the Maryland Racing Commission and are grouped into "meets."

       9 On February 21, 2000, a bid was posted for three full-time teller positions at Rosecroft
for the "Pimlico at Laurel Meet."  One of the bid winners, Judy O'Haver, was a "Days Worked"
employee with a Union date of October 28, 1998.  On March 24, 2000, a subsequent bid was
posted for seven full-time tellers at Rosecroft for the Pimlico meet.  In both instances,
Babendreier failed to apply for the vacant positions, although she was almost assured of being
awarded either bid.  This evidence was offered by appellants to prove that work was available to
Babendreier for the Pimlico meets, but that she failed to accept guaranteed work assignments.


                                              -9-


at Pimlico.10  As a result, she was not guaranteed work at Pimlico


when live meets were held at that track.11  To be eligible for work


at Pimlico, Babendreier, on a day-by-day basis, had to commute to


the  track, sign in, and wait to see whether her "Days Worked"


seniority status provided her with a work assignment.  If enough


other workers signing in had a higher seniority status, Babendreier


risked not being assigned work that day.


       Between October 1999 and February 20, 2000, during the Laurel


Park meets, Babendreier worked at her regularly-scheduled


assignment as a teller at Rosecroft.  On or about February 20,


2000, Laurel's winter meet ended and live racing at Pimlico


commenced.  Except for the Preakness and the Pimlico Special stakes


race, Babendreier did not seek any Pimlico work assignments.


       On or about April 1, 2000, Babendreier filed a claim for


benefits with DLLR, which RTPA opposed.  The claims examiner


granted her claim for unemployment benefits on April 25, 2000.


RTPA appealed the claims examiner's determination to the Division


of Appeals.


       On June 5, 2000, a hearing was held before a DLLR hearing




       10 The record indicates that as of May 21, 2000, Babendreier was ranked 17th on the
Pimlico "Days Worked" list, with 121 days worked at Pimlico during her twenty years of
employment.

       11 "Days Worked Seniority List Employee" is defined in the Agreement as "an employee
who has completed his [or her] thirty day probationary period but has not attained or has not
continuously maintained Saturday/Holiday, Extra or Regular Seniority standing under the term of
Article 4."


                                 -10-


examiner for the purpose of determining Babendreier's unemployment


benefits eligibility.  RTPA argued that Babendreier was not


entitled to unemployment benefits because she was an active


employee, who had failed to make herself "available for work"


pursuant to Md. Code Ann. (1991, 1999 Repl. Vol., 2000 Supp.), § 8-


903(a)(1)(ii) of the Labor and Employment Article ("LE").  RTPA


introduced evidence that if Babendreier had traveled to Pimlico and


signed-in, she would have been assigned work on "every single


Saturday" and many other days during the Pimlico meets.


Babendreier argued that she was not an active employee, based on


the transfer of meets from Laurel to Pimlico, and that she had been


"laid-off."  She acknowledged that she had not pursued work at


Pimlico during its meets.  Instead, and rather than commuting sixty


miles to Pimlico without any guarantee of receiving a work


assignment, she decided to look for full-time work closer to her


home.


     After the hearing, the hearing examiner rendered the following


decision:


                           FINDINGS OF FACT


             The claimant's benefit year commenced August
             24, 1999.  The claimant's week benefit amount
             is $239.  The employer operates two
             thoroughbred horseracing tracks in Maryland,
             Laurel Park and Pimlico.  The employer's
             premises are open throughout the year.  Live
             racing alternates between the two racing
             venues.  When there is no live racing,
             simulcast racing is available to patrons
             attending the racecourse.


                     -11-


Each racetrack has a separate seniority list.
When live racing takes place at the Laurel
Park, the claimant is guaranteed work due to
her seniority status.


     When live racing shifts to Pimlico, the
claimant's work at Laurel Park ends.  Again,
the claimant is not guaranteed work at
Pimlico, but in order to be eligible for work
at Pimlico, the claimant is obligated to
report to Pimlico and sign up for work. If
work is offered, the claimant is assigned
work.  If no work is available, the claimant
is not offered work.  The claimant receives no
compensation for showing up at Pimlico in
search of work.


After the claimant filed for benefits, the
claimant worked from October 12, 1999 through
February 21, 2000.  Live racing at Laurel
Racecourse ended on February 20, 2000.
Thereafter, the claimant worked two other
events for her employer.  These were special
events, the Pimlico Special and the Preakness.
Other than these two events, the claimant
sought work elsewhere. The claimant lives 60
miles away from the Pimlico racecourse.  The
claimant did not report to Pimlico to sign up
and see if work was available.  The claimant
opted to seek work near her home.  The
claimant has been seeking full-time work.  The
claimant has been making two job contacts per
week as mandated under the law.  The
claimant's reason for not seeking work at
Pimlico is because she is not guaranteed work
at Pimlico.


               CONCLUSIONS OF LAW


Md. Code Ann., Labor & Emp. Article, Section
8-1003 (Supp. 1996) provides for a
disqualification from benefits where the
claimant is discharged or suspended as a
disciplinary measure for misconduct connected
with the work.  The term "misconduct" is
undefined in the statute but has been defined
as "... a transgression of some established
rule or policy of the employer, the commission


                       -12-


of a forbidden act, a dereliction of duty, or
a course of wrongful conduct committed by an
employee, within the scope of his employment
relationship, during hours of employment, or
on the employer*s premises." Rogers v. Radio
Shack. 271 Md. 126, 132, 314 A.2d 113 (1974).


Md. Code Ann., Labor & Emp. Article, Section
8-903 (Supp. 1996) provides that a claimant
for unemployment insurance benefits shall be
(1) able to work (2) available for work; and
(3) actively seeking work. In Robinson v.
Maryland Employment Sec. Bd., 202 Md. 515, 97
A.2d 300 (1953), the Court of Appeals held
that a claimant may not impose restrictions
upon his or her willingness to work and still
be available as the statute requires.


           EVALUATION OF EVIDENCE


The claimant has not been separated from her
position of record.  The claimant is
guaranteed work when live racing takes place
at Laurel Park.  Therefore, the claimant's
separation constitutes a layoff.  In a layoff
the employer bears the burden of proving, by a
preponderance of evidence, that the claimant's
layoff was due to some degree of misconduct on
the claimant's behalf.


There is insufficient [evidence] to establish
that the claimant's layoff was due to any
degree of misconduct.  The nature of the
employer's business is the reason for the
claimant's layoff status.  Based on these
facts, there is no degree of misconduct on the
claimant's behalf.  Therefore, the Hearing
Examiner will reach and rule upon the next
issue in this case.


In review of the contract agreement between
the claimant and her employer, the claimant is
guaranteed work only at the Laurel Park.  The
claimant is not guaranteed work at the Pimlico
racecourse.  In review of the documents
presented, the claimant is obligated to attend
Pimlico and seek work during her layoff
status.


                              -13-


          The credible evidence establishes that the
          claimant has been seeking full time work
          opportunities during her layoff status.  These
          opportunities are separate and apart from her
          seeking work at Pimlico Raceway.  Based on the
          evidence presented, the claimant is in
          compliance with the above-cited law.


          If during the claimant's layoff period, the
          employer makes the claimant an offer and the
          claimant refuses the offer, the employer has a
          remedy under Md. Code Annotated, Labor and
          Emp. Article, Title 8, Section 1005.


                            DECISION


          IT IS HELD THAT the claimant was discharged,
          but not for gross misconduct or misconduct
          connected with the work, within the meaning of
          Md. Code Ann., Labor & Emp. Article, Sections
          8-1002 or 8-1003 (Supp. 1996).  No
          disqualification is imposed based upon the
          claimant's separation from employment with
          Racetrack Payroll Account.  The claimant may
          contact the local employment office concerning
          the other eligibility requirements of the law.


          IT IS HELD THAT the claimant is able,
          available and actively seeking work within the
          meaning of Md. Code Ann., Labor & Emp.
          Article, Section 8-903 (Supp. 1996).  Benefits
          are allowed for the week beginning February
          19, 2000 and thereafter, provided that the
          claimant meets the other eligibility
          requirements of the Maryland Unemployment
          Insurance Law.


          The determination of the Claim Specialist is
          affirmed.


     RTPA filed a petition for review with the Board.  On October


19, 2000, the Board affirmed the hearing examiner's decision.  On


November 20, 2000, appellants filed in the Circuit Court for Anne


Arundel County a petition for judicial review.  The Board moved to


                                                -14-


remand the case to the Board, requesting in its proposed order that


the court submit the following questions to a hearing examiner:12


              (a) Did the labor agreement require the
              claimant to report to Pimlico Race Course
              while it was holding live racing?


              (b) If the labor agreement did require her to
              report to Pimlico, did her failure to report
              render her available for work, within the
              meaning of § 8-903(a)(1)(ii), even though
              reporting to Pimlico did not guarantee that
              she would get work?


              (c) Was the claimant's failure to report to
              Pimlico a failure to actively seek work,
              within the meaning of § 8-903(a)(1)(iii), even
              though she was seeking work elsewhere?


              (d) Was there an offer of suitable employment
              to the claimant from the employer?  If so, did
              the claimant refuse that offer?  If so, did
              she have good cause for the refusal?


Appellants opposed the Board's motion to remand and sought counsel


fees.


       In its June 6, 2001 opinion and order, the circuit court


considered whether Babendreier "was not available for work because


she declined to go to Pimlico where she was not guaranteed work."


The court noted:




       12 These questions appeared in the proposed order, whereas the motion contained the
following questions:


                        (a) Did the labor agreement require the claimant to report to
              Pimlico Race Course while it was holding live racing?
                        (b) If the labor agreement did require her to report to
              Pimlico, did her failure to report render her unavailable for work
              even though reporting to the track did not guarantee that she would
              get work?


                                 -15-


                 Ms. Babendreier lives sixty miles from
         Pimlico.  The examiner found she had tried to
         get work elsewhere, including making two
         contacts per week.  However, she didn't want
         to go and work where she had low seniority
         with the understanding she wasn't guaranteed
         any work.
                 We agree that Ms. Babendreier cannot
         impose unreasonable conditions upon her
         willingness to work and still be considered
         available.  Robinson v. Maryland Employment
         Sec. Bd., 202 Md. 515.  The Examiner
         determined that her declining to go to Pimlico
         was a reasonable conclusion to reach.
         However, the Board reached a different
         conclusion on facts that appear to be close to
         the ones in the Keller case (9-22-99).
                 If we consider the decision of the Board
         of Appeals without Keller, we would find
         substantial justification for the Board's
         decision.  If we need to reach our conclusion
         on the facts and the law, we find that it is
         not reasonable to make her go to Pimlico for
         work that does not necessarily exist.
                 There is an argument as to who should
         have called whom to see if there was work.
         Our understanding is that she had to show up
         and take her chances, but if there was work
         the employer could [have] certainly called her
         and cut its losses.
                 The Board moved to remand.  Upon our
         ruling, we don't believe that [it] is
         necessary.  However, there was a reasonable
         possibility that the remand might have been
         necessary; we reject any claim of lack of
         substantial justification, and award no fees.
                 Accordingly, it is this [31st] day of May,
         2001
                 ORDERED that the decision of the Board of
         Appeals is affirmed.  Appellant to pay costs.
          [Emphasis in original.]


Appellants filed a notice of appeal on July 3, 2001.


                         STANDARD OF REVIEW


          The scope of judicial review of a
          determination by the Board in an unemployment


                                 -16-


          compensation insurance case is set forth in §
          8-512(d):


               "Scope of review. ­ In a judicial
               proceeding under this section,
               findings of fact of the Board of
               Appeals are conclusive and the
               jurisdiction of the court is
               confined to questions of law if:


                       (1) findings of fact are
                       supported by evidence
                       that is competent,
                       material, and substantial
                       in view of the entire
                       record; and 


                       (2) there is no fraud.


          Under this statute, the reviewing court shall
          determine only: "(1) the legality of the
          decision and (2) whether there was substantial
          evidence from the record as a whole to support
          the decision."  The reviewing court may not
          reject a decision of the Board supported by
          substantial evidence unless that decision is
          wrong as a matter of law.  The test for
          determining whether the Board's findings of
          fact are supported by substantial evidence is
          whether reasoning minds could reach the same
          conclusion from the facts relied upon by the
          Board. [Citations omitted.]


Department of Labor, Licensing & Regulation v. Hider, 349 Md. 71,


77-78, 706 A.2d 1073 (1998).


     If, however, we find "no substantial or sufficient evidence to


support the factual findings of the Board, the Board's decision


will be reversed because it was arbitrary and illegal."  Eastern


Outdoor Adver. Co. v. Mayor & City Council of Baltimore, 128 Md.


App. 494, 515, 739 A.2d 854 (1999), cert. denied, 358 Md. 163, 747


A.2d 644 (2000).  The substantial evidence test is an "assessment


                               -17-


of whether the record before the Board contained at least `a little


more than a scintilla of evidence' to support the Board's


scrutinized action."  Friends of the Ridge v. Baltimore Gas & Elec.


Co., 120 Md. App. 444, 466, 707 A.2d 866 (1998), vacated in part,


352 Md. 645, 724 A.2d 34 (1999) (citation omitted).  The existence


of substantial evidence "pushes the Board's decision into the


unassailable realm of a judgment call, one for which we may not


substitute our own exercise of discretion."  Friends of the Ridge,


120 Md. App. at 466.


                            DISCUSSION


     Appellants claim that Babendreier was unavailable for work by


refusing to sign in at Pimlico and wait for an opportunity to


receive a work assignment.  Appellants contend that, by her failure


to do so, she imposed conditions and limitations on her willingness


to work and therefore was not "available for work" pursuant to LE


§ 8-903(a)(1)(ii).  In addition, they contend that the Board acted


in an arbitrary manner in reaching an opposite conclusion than it


reached in Keller v. Race Track Payroll Account, Inc., No. 2876-BR-


99 (1999).


     Appellees argue that the Board properly held that Babendreier


was "available" for work within the meaning of the unemployment


eligibility statute.  They claim this decision was both legally


correct and supported by substantial evidence in the record.  They


further assert that if Babendreier would be "required to make


                                               -18-


herself available to a specific employer, whether or not that


employer could ensure that she would be given work[,]" she would


thereby limit her chances to interview for and accept other


employment.  In other words, if she made herself available to the


appellants for work that was not guaranteed, she would not be


available to the rest of the employment market.


        Maryland's unemployment insurance law is remedial in nature


and is intended to prevent economic insecurity and alleviate the


consequences of "involuntary unemployment and economic distress."


Johns Hopkins Univ. v. Board of Labor, 134 Md. App. 653, 659, 761


A.2d 350 (2000); see LE § 8-102.13  An individual is considered to





        13 LE § 8-102 provides:


        (a) Interpretation and application. ­ This section is a guide to the interpretation and
application of this title.
        (b) Findings. ­ The General Assembly finds that:
                (1) economic insecurity due to unemployment is a serious menace to the health,
morals, and welfare of the people of the State;
                (2) involuntary unemployment is a subject of general interest and concern that
requires appropriate action by the General Assembly to prevent the spread of involuntary
unemployment and to lighten its burden, which often falls with crushing force on the
unemployed worker and the family of the unemployed worker;
                (3) the achievement of security for society requires protection against involuntary
unemployment, which is the greatest hazard of our economic lives; and
                (4) security for society can be provided by encouraging employers to provide
more stable employment and by the systematic accumulation of funds during periods of
employment to provide benefits for periods of unemployment, maintaining the purchasing power,
and limiting the serious social consequences of poor relief assistance.
        (c) Statement of policy. ­ The General Assembly declares that, in its considered
judgment, the public good and the general welfare of the citizens of the State require the
enactment of this title, under the police powers of the State, for the compulsory setting aside of
unemployment reserves to be used for the benefit of individuals unemployed through no fault of
their own.


                                -19-


be unemployed in any week during which the individual:  


               (1) does not perform work for which wages
          are payable; or
               (2) performs less than full-time work for
          which wages payable are less than the weekly
          benefit amount that would be assigned to the
          individual plus allowances for dependants.


LE § 8-801(b).  Eligibility for individual unemployment benefits


requires, in pertinent part:


          (a)  In general. ­ (1) Except as otherwise
          provided in this section, to be eligible for
          benefits an individual shall be:
               (i) able to work;
               (ii) available for work; and
               (iii) actively seeking work.
             (2) In determining whether an individual
          actively is seeking work, the Secretary shall
          consider:
               (i) whether the individual has made an
          effort that is reasonable and that would be
          expected of an unemployed individual who
          honestly is looking for work; and
               (ii) the extent of the effort in relation
          to the labor market conditions in the area in
          which the individual is seeking work.
          [Emphasis added.]


LE § 8-903.


     That Babendreier was "able to" and was "actively seeking" work


is not contested.  The record indicates that she pursued at least


two jobs per week, as required by law.  The pivotal issue is


whether she was "available for work" when she did not seek non-


guaranteed work assignments during the Pimlico meet.


     Appellants argue that we should reverse the Board's decision


because it did not follow the result that it reached in Keller,


                                                 -20-


supra.  In that case, Keller, a "Saturday/Holiday Employee"14 at


Laurel Park and a "Regular Employee" at Pimlico, was disqualified


from receiving unemployment benefits because she did not seek work


at Laurel Park on days other than Saturdays and holidays.  Keller,


like Babendreier, did not seek work on additional days because the


work was not guaranteed.15  The hearing examiner in Keller noted


that, "there is sufficient evidence to show that the claimant could


reasonably have expected to work more than one day per week had she


made the attempt.  For this reason, it does not appear proper to


find that [Keller] is working all available hours."  The hearing


examiner went on to conclude that "the claimant is not fully able,


available, and actively seeking work" within the meaning of LE § 8-


903(a)(1), and therefore, she was denied unemployment benefits


"until such time as claimant meets the requirements of the law and


demonstrates that her attempts to work would be unavailing."  The


Board affirmed that decision, pursuant to COMAR 09.32.06.04.A ("The


Board may deny a petition for review if it agrees with the decision


of the hearing examiner.").


          We are unpersuaded by appellants' argument that the Board was


bound by the Keller decision, either factually or as precedent,16



          14 The term "Saturday/Holiday Employee" is defined in the Agreement as "an employee
who attained and continuously maintains Saturday/Holiday Seniority standing under Article 4[,]"
supra.

          15 The record does not reflect whether Keller sought other full-time work. 

          16 See COMAR 09.32.06.03.C., infra.


                                  -21-


as to render its decision in this case arbitrary and capricious.


Keller sought employment at the Laurel Park meet, but limited her


availability to Saturdays and holidays, the days for which she held


seniority status.  Babendreier, on the other hand, declined to work


the entire Pimlico meet.  Keller, as a "Saturday/Holiday Employee"


at Laurel Park, held a higher seniority status than Babendreier, a


"Days Worked" employee at Pimlico.  Consequently, Keller had a


greater guarantee of receiving a work assignment than had


Babendreier.


     Moreover, only "[d]ecisions of the Board of Appeals designated


as precedent by the Board constitute legal precedent for the


hearing examiner's decisions."  COMAR 09.32.06.03.C.  The Board's


decisions are somewhat analogous to our unreported opinions.


Maryland Rule 8-114(a) states that "[a]n unreported opinion of the


Court of Appeals or Court of Special Appeals is neither precedent


within the rule of stare decisis nor persuasive authority."


Therefore, the Board did not err by declining to treat Keller as


precedent.


     Appellants contend that the Keller decision was based on


Robinson v. Maryland Employment Sec. Board, 202 Md. 515, 97 A.2d


300 (1953), in which the Court of Appeals noted that


              [t]he purpose the [unemployment] law is
              designed to achieve, of protection against
              involuntary unemployment, is not frustrated by
              an interpretation that one who will work from
              11:00 A.M. to 3:00 P.M. only has restricted
              her utility and desirability in the labor


                               -22-


          market to a point where she cannot be held to
          be "available" as that word is used in the
          context of the statute.


Robinson, 202 Md. at 522.  The Court went on to hold that for an


individual to be found unavailable, he or she must place


restrictions on the days, time, place, or conditions of employment.


The Court concluded that a cafeteria operator, laid off by her


employer because of a reduction in staff, was unavailable for work


when she restricted the hours during which she was willing to work.


Here, Babendreier stated that she was available to work if


appellants contacted her, i.e., if work was available.  We do not


believe that her request for notice of available work was


equivalent to the general restriction Robinson placed on her


employment.


     In addition, in Maryland Employment Sec. Bd. v. Poorbaugh, 195


Md. 197, 72 A.2d 753 (1950), cited by the Board, the Court of


Appeals considered three separate unemployment benefits claims.  In


all three instances, the Court held that the Board's denial of


unemployment benefits was legally correct, basing its decision on


the respective parties' failure to look for work or accept an offer


to work.  The Court stated:


               A review of the testimony in the instant
          cases shows clearly that there was evidence to
          support the Board's findings.  Mrs. Poorbaugh
          received a maternity leave, and at the time
          she registered with the Employment Service was
          fully occupied in taking care of her child.
          There was no evidence that she had made any
          effort to procure work, other than to "watch


                                -23-


          the ads."  Mr. Feaster, whose employer
          contended that he had voluntarily quit his
          job, admitted that he [was] laid off because
          of the cold weather.  The employer sent him
          word that if he didn't report "for work
          tomorrow he wasn't going to have any more
          work", but he did not report until about four
          months later, a month after he filed his
          claim.  Mrs. Merbaugh was employed as a
          messenger.  She resigned her job to get
          married. Under a rule of the Company[,]
          married women were not employed as messengers.
          She applied for a transfer to another
          department, but there was no vacancy.  She
          admitted that since her marriage she had not
          applied for work elsewhere.
                 Since there was evidence to support the
          Board's findings and no suggestion of fraud,
          the court erred in attempting to substitute
          its judgment for that of the Board. 


Poorbaugh, 195 Md. at 199-200.  Again, we do not find these


circumstances analogous to the present case.  Here, the evidence


supports the finding that Babendreier was laid off when live racing


ended at Laurel Park, that she had not been offered a guaranteed


employment opportunity at Pimlico, and that she was actively


seeking work.


     Appellants direct us to GTE Products Corp. v. Unemployment


Compensation Bd. of Review, 141 Pa. Commw. 628, 596 A.2d 1172 (Pa.


Commw. Ct. 1991), in which a claimant for unemployment benefits


worked for an employer who ceased production for a summer shutdown,


lasting approximately one month.  GTE, 596 A.2d at 1172-73.  The


employer encouraged its employees to take their vacation time


during the shutdown period, but posted a sign-up sheet for


employees interested in working during the shutdown.  Id. at 1173.


                               -24-


If an employee was available for work during the shutdown period,


the employer would approve a request for vacation time during the


remaining portion of the year.  Id.  Unlike, Babendreier, however,


the claimant, who had previously used her vacation time, did not


make herself available for guaranteed work with her employer during


the shutdown period.


     In re Beatty, 286 N.C. 226, 210 S.E.2d 193 (1974), cited by


the Board, however, is instructive.  In Beatty, 126 longshoremen


were deemed ineligible for unemployment benefits based upon a


provision in their collective bargaining agreement, which required


the longshoremen to report to work between 6:00 a.m. and 7:30 a.m.,


and if no work was available by 8:15 a.m., they could go to a part-


time job.  That agreement also provided supplemental benefits to


those employees who were union members and sought employment, but


who were unable to obtain a part-time job.  The Supreme Court of


North Carolina affirmed the decision of the Employment Security


Commission that the claimants were not available for work because


the reporting requirement effectively took the claimants out of the


job market.


     In this case, Babendreier, like the longshoremen, would have


effectively removed herself from the labor market by reporting to


Pimlico each day.  What distinguishes Beatty from this case is that


the agreement entered into by the longshoreman required them to


report to work each day to be eligible for supplemental income


                               -25-


benefits available to union members who were unable to work part-


time jobs.  Babendreier, on the other hand, was not required by


contract to report daily to Pimlico, received no  compensation for


reporting to Pimlico, and was not guaranteed any work there.


     The Board affirmed its hearing examiner's finding that


Babendreier was laid off from her employment at Laurel Park because


of the nature of the employer's business and not because of


misconduct, and that she was "available for work" pursuant to LE §


8-903(a)(1)(ii), despite refusing to commute sixty miles to Pimlico


and await a non-guaranteed work assignment.  Had she spent many


hours commuting to and waiting at Pimlico for a non-guaranteed work


assignment, she would have been "unavailable" to other potential


employers.  We conclude that the Board's decision is supported by


substantial evidence and is not wrong as a matter of law.  We


therefore affirm the Board's decision granting Babendreier


unemployment benefits.


                              JUDGMENT AFFIRMED.


                              COST TO BE PAID BY APPELLANTS.