STATE OF OHIO ) IN THE COURT OF APPEALS
)ss: NINTH JUDICIAL DISTRICT
COUNTY OF LORAIN )
LORAIN COUNTY AUDITOR,
et al.
Appellees
v.
OHIO UNEMPLOYMENT
REVIEW COMMISSION, et al.
C. A. No. 05CA008679
APPEAL FROM JUDGMENT
ENTERED IN THE
COURT OF COMMON PLEAS
COUNTY OF LORAIN, OHIO
CASE No. 03CV136461
Appellants
DECISION AND JOURNAL ENTRY
Dated: November 2, 2005
This cause was heard upon the record in the trial court. Each error assigned
has been reviewed and the following disposition is made:
WHITMORE, Judge
{¶1} Appellant, the Director of the Ohio Department of Job and Family
Services has appealed the judgment of the Lorain County Court of Common Pleas
reversing the ruling of the Ohio Unemployment Compensation Review
Commission (“Review Commission”) granting benefits to claimant Kristie L.
Brinkman (“Brinkman”). This Court affirms.
{¶2} Brinkman, a registered nurse working for the Lorain County
Sheriff’s Department pursuant to an “intermittent employment contract,” filed for
unemployment benefits on November 1, 2002, after exhausting her contract
commitment of 1,000 hours. Subsequently, the Ohio Department of Job and
Family Services (“ODJFS”) determined that Brinkman was entitled to benefits.
Her employer, the Lorain County Auditor/Sheriff’s Department (Appellees)
requested reconsideration of the decision and ODJFS affirmed the initial
determination. Appellees appealed to the Review Commission and a hearing was
held on July 23, 2003.
{¶3} Upon hearing the evidence, the Review Commission awarded
Brinkman unemployment compensation benefits. Pursuant to R.C. § 4141.282(H),
Appellees appealed to the Lorain County Court of Common Pleas. The trial court
reversed the Review Commission’s ruling and vacated the award of benefits to
Brinkman. ODJFS has timely appealed the trial court’s decision, asserting one
assignment of error.
II
Assignment of Error Number One
“THE LORAIN COUNTY COMMON PLEAS COURT ERRED IN
REVERSING THE REVIEW COMMISSION’S FINDING THAT
CLAIMANT WAS DISCHARGED WITHOUT JUST CAUSE
AND THUS ELIGIBLE FOR UNEMPLOYMENT BENEFITS
WHERE SUCH FINDINGS WERE LAWFUL, REASONABLE
AND SUPPORTED BY CREDIBLE EVIDENCE IN THE
RECORD.”
{¶4} In his sole assignment of error, Appellant has argued that the trial
court erred in reversing the Review Commission’s decision because its findings
were lawful, reasonable and supported by the evidence. Specifically, Appellant
has argued that Brinkman was separated from her employment through no fault of
her own due to lack of work and therefore, the Review Commission’s award of
benefits was lawful. We disagree.
{¶5} It has been widely accepted that an “appellate court may only
reverse an unemployment compensation eligibility decision by the Review
Commission if the decision is unlawful, unreasonable, or against the manifest
weight of the evidence.” Markovich v. Employers Unity, Inc., 9th Dist. No. 21826,
2004-Ohio-4193, at ¶10, citing Tzangas v. Administrator, Ohio Bur. of Emp. Serv.
(1995), 73 Ohio St.3d 694, 696. In such cases, this Court is “required to focus on
the decision of the Review Commission, rather than that of the common pleas
court[.]” Id., citing Barilla v. Ohio Dept. of Job & Family Servs., 9th Dist. No.
02CA008012, 2002-Ohio-5425, at ¶ 6.
{¶6} In the case sub judice, the Review Commission based its grant of
unemployment benefits on the determination that Brinkman had been separated
from employment due to a lack of work. Appellant has echoed that argument in
his briefs. Appellees have countered that Brinkman voluntarily entered into a
fixed term contract for 1,000 hours per fiscal year. Therefore, Appellees argued,
pursuant to O.A.C. 123:1-47-01(44), Brinkman was classified as an intermittent
employee and simply not scheduled to work until the start of a new fiscal year.
Accordingly, Appellees have argued Brinkman should not be eligible for
unemployment benefits for the interim period.
{¶7} In Ohio, an individual must be involuntarily unemployed to be
eligible for unemployment compensation. R.C. 4141.29. Appellant has argued
that although Brinkman voluntarily entered into a fixed term contract, she was not
at fault for the term’s expiration and was therefore involuntarily unemployed. To
support his position, Appellant has relied on Lexington Township Trustees v.
Stewart (Mar. 17, 1986), 5th Dist. No. CA-6766, 1986 WL 3925. In Lexington
Township Trustees, the Fifth District Court of Appeals held that “[t]he fact that the
unemployment is the result of the expiration of a contract for employment is
irrelevant[.]” Id. at *2, citing Mathieu v. Dudley (1967), 10 Ohio App.2d 169,
174. Both the Seventh and Eighth Districts have adhered to this principle. See
Case W. Res. Univ. v. Ohio Unemp. Comp. Rev. Comm., 8th Dist. No. 81773,
2003-Ohio-2047, at ¶5.
{¶8} This Court rejects Appellant’s arguments and the rulings of the Fifth,
Seventh, and Eighth Districts. We cannot agree that parties who knowingly enter
into fixed term contracts become “involuntarily unemployed” at the expiration of
the fixed term. It is our opinion that as a matter of statutory interpretation and
public policy, such a conclusion runs contrary to the intent of the Unemployment
Compensation Act (“Act”).
{¶9} It has long been held in Ohio that the purpose of the Act is “to
enable unfortunate employees, who become and remain involuntarily unemployed
by adverse business and industrial conditions, to subsist on a reasonably decent
level and is in keeping with the humanitarian and enlightened concepts of this
modern day.” (Quotations omitted) Irvine v. Unemployment Comp. Bd. of Review
(1985), 19 Ohio St.3d 15, 17. Furthermore, the Act was intended to “‘provide
financial assistance to an individual who had worked, was able and willing to
work, but was temporarily without employment through no fault or agreement of
his own.’” Id., quoting Salzl v. Gibson Greeting Cards (1980), 61 Ohio St.2d 35,
39.
{¶10} First, we note that being without gainful employment at the
conclusion of a fixed term contract does not constitute involuntary unemployment
by adverse business conditions. See Irvine, 19 Ohio St.3d at 17. Rather, it is
simply a position that the claimant put themselves in by agreeing to the fixed term
contract, and a position that claimant was aware they would be in at the conclusion
of the contract. This Court disagrees with the proposition that just because an
individual reaches the extent of their fixed term contract, they necessarily must
have been separated because of lack of work. See Case Western Reserve, at ¶5
(stating “[i]n Ohio a presumption exists that the employee separated for lack of
work”).
{¶11} Secondly, we find the overarching policy of the Act is to protect
those workers who find themselves without employment through no fault or
agreement of their own, and to temporarily provide them with financial assistance
until they are able to find adequate employment. See Irvine, 19 Ohio St.3d at 17.
Such is not the case with regards to the expiration of fixed term contracts. In the
case of an employee who finds herself temporarily without work due to the
expiration of a fixed term contract voluntarily entered into, this Court declines to
say that such unemployment is through no agreement of her own. In fact, the
opposite is true; it is unemployment anticipated and agreed to by the employee,
and therefore, we cannot conclude that such an employee is entitled to
unemployment benefits.
{¶12} We find it illustrative that Appellant cites Tzangas, Plakas &
Mannos v. Ohio Bur. of Emp. Serv. (1995), 73 Ohio St.3d 694 for the proposition
that the Act “does not exist to protect employees from themselves, but to protect
them from economic forces over which they have no control.” Id. at 697. Here,
Brinkman had a measure of control over the terms of her employment. She
voluntarily entered into an agreement which limited her to 1,000 hours and she has
made no argument that she didn’t know or understand the terms. That said, she is
“no longer the victim of fortune’s whims, but is instead directly responsible for
[her] own predicament.” Id. at 698.
{¶13} Thirdly, we find that the rule adhered to by the Fifth, Seventh, and
Eighth Districts is against public policy in that it infringes upon businesses’
freedom to contract with a potential employee for fixed term employment.
Furthermore, it is foundational that businesses must be allowed to allocate their
resources in the way that best serves their business judgment. Granting
unemployment benefits to every worker who reaches the culmination of their fixed
term contract would eviscerate the purpose and benefit of employers using fixed
term contracts. This Court refuses to handcuff business in such a manner, and
therefore cannot support the position held by our sister districts.
{¶14} Finally, while it is crucial to the analysis to determine what the
purpose of the Act is, we find it equally compelling to determine what the purpose
of the Act is not. The Act is not legislation to “subsidize the vacation periods of
those who know well in advance that they may be laid off for certain specified
periods.” (Quotation omitted) Univ. of Toledo v. Heiny (1987), 30 Ohio St.3d 143,
146. In the instant matter, Brinkman was fully aware, pursuant to her contract,
that she was limited to 1,000 hours per year. Additionally, the contract made it
clear that Brinkman was required to complete a 2,000 hour probationary period.
That being the case, Brinkman must have been or should have been aware that
after completion of her first 1,000 hours, she would have a hiatus before being
called back to complete her second 1,000 hour period. Essentially, it appears that
Brinkman, through Appellant, is asking the State of Ohio to provide her with
supplemental income during a known hiatus period, simply because she chose to
enter into an agreement for such employment. See, generally, Id. This Court
cannot agree with such a proposition.
{¶15} Regardless of Appellant’s argument that the Court adopt the rulings
of the Fifth, Seventh and Eighth Districts, we find that the Review Commission’s
decision granting Brinkman unemployment benefits was unlawful and
unreasonable. There is competent and credible evidence in the record that
Brinkman was never terminated, nor separated, nor laid off. Additionally,
evidence exists that demonstrates that neither lack of work, nor lack of funds
precipitated Brinkman’s lull in scheduled hours.
{¶16} Captain John Reiber, administrative officer for the Lorain County
Sheriff’s Department, testified that the jail had sufficient work and sufficient funds
to pay registered nurses. Captain Reiber also testified that Brinkman was not
“fired” as a result of her reaching the 1,000 hour plateau, she was not separated or
terminated, and was not laid off in accordance with Ohio’s civil service laws.
Additionally, Captain Reiber testified that Brinkman was never removed from the
county payroll. Captain Reiber averred that the sole reason Brinkman was
removed from the work schedule was she had reached the maximum allowable
hours pursuant to her intermittent employment contract.
{¶17} Based on the foregoing, we find that the Review Commission’s
decision granting Brinkman unemployment benefits because her separation from
employment was due to lack of work, was unlawful, unreasonable and against the
manifest weight of the evidence. Accordingly, Appellant’s sole assignment of
error is without merit.
III
{¶18} Appellant’s sole assignment of error is overruled. The judgment of
the trial court is affirmed.
Judgment affirmed.