STATE OF OHIO ) IN THE COURT OF APPEALS
)ss: NINTH JUDICIAL DISTRICT
COUNTY OF SUMMIT )
AUTOZONE, INC.
Appellee
v.
STEVEN J. HERRING, et al.
Appellants
C. A. No. 22824
APPEAL FROM JUDGMENT
ENTERED IN THE
COURT OF COMMON PLEAS
COUNTY OF SUMMIT, OHIO
CASE No. CV 05 01 0268
DECISION AND JOURNAL ENTRY
Dated: March 8, 2006
This cause was heard upon the record in the trial court. Each error assigned
has been reviewed and the following disposition is made:
WHITMORE, Presiding Judge.
I
{¶1} Defendant-Appellant Steven J. Herring has appealed from the
judgment of the Summit County Court of Common Pleas that reversed the ruling
of the Unemployment Compensation Review Commission (“Review
Commission”) which had found that he had been terminated without just cause
from his employment with Plaintiff-Appellee Autozone, Inc. This Court reverses.
{¶2} Defendant-Appellant Steven J. Herring filed a claim for
unemployment benefits for the week ending January 24, 2004. Initially, the
Director of the Ohio Department of Job and Family Services found that Appellant
was discharged by his employer, Autozone, for just cause. Accordingly,
Appellant’s claim for benefits for the week ending January 24, 2004 was rejected.
Appellant then filed an appeal of the initial determination. On March 15, 2004,
the Director affirmed the original determination.
{¶3} Appellant appealed the re-determination and the Director transferred
jurisdiction to the Review Commission. A hearing was held before a hearing
officer on September 17, 2004. The hearing officer reversed the Director’s redetermination
and found that Appellant was terminated without just cause. On
January 13, 2005, Autozone appealed to the Summit County Court of Common
Pleas.
{¶4} On July 8, 2005, the trial court issued its final appealable order. The
trial court found that the hearing officer failed to consider all the undisputed facts
on the record and as a result the hearing officer’s decision was arbitrary,
unreasonable and against the manifest weight of the evidence. Accordingly, the
trial court determined that the Appellant was terminated for just cause and
reversed the Review Commission’s decision.
{¶5} Appellant has timely appealed, asserting one assignment of error.
II
Assignment of Error
“THE TRIAL COURT ERRED IN REVERSING THE DECISION
OF THE UNEMPLOYMENT COMPENSATION REVIEW
COMMISSION WHERE THAT DECISION WAS NOT
UNLAWFUL, UNREASONABLE, OR AGAINST THE
MANIFEST WEIGHT OF THE EVIDENCE.”
{¶6} In his sole assignment of error, Appellant has argued that the trial
court erred in reversing the Review Commission’s decision because it was
supported by competent, credible evidence and therefore was not against the
manifest weight of the evidence. Further, Appellant has argued that the trial court
violated the standard of review, disregarded its limited function in reviewing the
Review Commission’s decision, and substituted its own judgment for that of the
Review Commission. We agree.
{¶7} We begin with a discussion of the applicable standard of review.
This 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.” (Quotations omitted). Markovich v.
Employers Unity, Inc., 9th Dist. No. 21826, 2004-Ohio-4193, at ¶10. When an
appellate court reviews the common pleas court’s review, it applies the same
standard. Tzangas, Plakas & Mannos v. Ohio Bur. of Emp. Serv. (1995), 73 Ohio
St.3d 694, 696-97. In such cases, this Court is “required to focus on the decision
of the Review Commission, rather than that of the common pleas court[.]”
Markovich at ¶10, citing Barilla v. Ohio Dept. of Job & Family Serv., 9th Dist.
No. 02CA008012, 2002-Ohio-5425, at ¶6.
{¶8} Under an appellate court’s limited scope of review of Review
Commission decisions, we cannot make factual findings or determine the
credibility of witnesses. Lorain Cty Auditor v. Unemployment Comp. Rev. Comm.,
9th Dist. No. 03CA008412, 2004-Ohio-5175, at ¶8, citing Tzangas, 73 Ohio St.3d
at 696. However, we do “have a duty to determine whether the Review
Commission’s decision is supported by the evidence in the record.” Id. If the
decision is supported by evidence in the record, this Court cannot substitute its
judgment for that of the Review Commission. Id. Furthermore, “‘[e]very
reasonable presumption must be made in favor of the [decision] and the findings
of facts [of the Review Commission].’” Upton v. Rapid Mailing Serv., 9th Dist.
No. 21714, 2004-Ohio-966, at ¶11, quoting Karches v. Cincinnati (1988), 38 Ohio
St.3d 12, 19.
{¶9} A party is entitled to unemployment benefits if he or she quits with
just cause or is terminated without just cause. R.C. 4141.29(D)(2)(a); Upton at
¶13. Traditionally, in the statutory sense, “just cause” has been defined as “that
which, to an ordinarily intelligent person, is a justifiable reason for doing or not
doing a particular act.” (Quotations omitted). Irvine v. Unemployment Comp. Bd.
of Review (1985), 19 Ohio St.3d 15, 17. The determination of whether an
employer had just cause to terminate an employee is a factual question primarily
within the province of the Review Commission, and one which reviewing courts
are precluded from inquiring into during these administrative appeals. Roberts v.
Hayes, 9th Dist. No. 21550, 2003-Ohio-5903, at ¶20, citing Durgan v. Ohio Bur.
of Emp. Serv. (1996), 110 Ohio App.3d 545, 551.
{¶10} The hearing officer made the following findings of fact. Appellant
was discharged from employment as a direct result of an incident occurring on
January 2, 2004. On this date, a regular customer left a large bag of apples and
oranges for Autozone employees. The bag was left in the store break room.
Lynette Brown, an assistant manager, stated that she was taking the fruit home and
placed a majority of the fruit (approximately ten pounds) into another bag.
Appellant attempted to reach for a piece of fruit from the bag, whereupon Ms.
Brown grabbed Appellant’s hand and stabbed it repeatedly with a ballpoint pen.
After the altercation, Appellant and Ms. Brown continued to work the remainder
of their shift. During this time, the two again exchanged words concerning the
altercation.
{¶11} The hearing officer found that while Appellant’s actions were
imprudent, they in no way justified Ms. Brown’s violent response. The hearing
officer also found that despite Appellant’s talk concerning his utility knife, he
never directly threatened Ms. Brown and that his statement regarding using the
knife if Ms. Brown attacked him again did not indicate a present intent to commit
harm. The hearing officer reasoned that Appellant’s justifiable anger towards Ms.
Brown due to the attack mitigated the statements made subsequent to the
altercation. Furthermore, the hearing officer reasoned that Appellant worked the
remainder of his shift without any attempt to retaliate or injure Ms. Brown.
{¶12} We begin our analysis by reiterating that under our standard of
review, we are to focus on the Review Commission’s decision, not the decision of
the trial court. Accordingly, we must first turn our attention to the hearing
officer’s reasoning and determination that no just cause existed for Appellant’s
termination by Autozone.
{¶13} While we cannot make our own determination concerning the
existence of just cause, we can review the hearing officer’s reasoning. In the
instant matter, we find that the hearing officer employed improper reasoning as a
matter of law in his just cause determination. From the record, it is apparent that
the hearing officer based his decision on a standard of comparative fault. The
hearing officer stated in his reasoning:
“While [Appellant’s] attempt at self-help to obtain a portion of the
fruit was imprudent, [Appellant’s] actions in no way justified Ms.
Brown’s response. *** While the employer concluded that both
employees were guilty of misconduct, it is apparent that Ms.
Brown’s actions were far more egregious than [Appellant’s]. The
fact that he had been injured by Ms. Brown’s unjustified attack
somewhat mitigates [Appellant’s] statements made following the
incident.”
It is clear that the hearing officer believed that Appellant was justified in his
actions and that while not blameless, Appellant’s conduct was far less egregious
than Ms. Brown’s. This analysis was improper because under the Unemployment
Compensation Act, just cause is predicated on the individual employee’s fault –
not the employee’s fault as compared to another employee’s fault. See Markovich,
at ¶7.
{¶14} This court has held that “[t]he determination of what constitutes ‘just
cause’ within the context of unemployment compensation *** involves a
concurrent analysis of the legislative purpose of the Unemployment Compensation
Act[.]” Roberts at ¶17, citing Irvine, 19 Ohio St.3d at 17. The purpose of the Act
is 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.” (Quotations omitted). Irvine, 19 Ohio St.3d at 17.
Consistent with the purpose of the Act, “a discharge is considered for just cause
where an employee’s conduct demonstrates some degree of fault[.]” Markovich at
¶8. See also Tzangas, 73 Ohio St.3d at paragraph two of the syllabus (holding that
fault on behalf of the employee is an essential component of a just cause
termination). Furthermore, we have agreed with other Ohio courts that fault
includes behavior that displays a disregard for the best interests of the employer.
Markovich at ¶8.
{¶15} Ohio precedent is clear on the matter: a just cause determination
requires an analysis of the employee’s fault in the situation leading to his
termination. Nowhere in our precedent or that of the Ohio Supreme Court is it
indicated that an employee is unjustly terminated simply because his misconduct
is less egregious than another employee’s. The standard is just the opposite. The
Ohio Supreme Court has clearly explained the standard:
“When an employee is at fault, he is no longer the victim of
fortune’s whims, but is instead directly responsible for his own
predicament. Fault on the employee’s part separates him from the
Act’s intent and the Act’s protection. Thus, fault is essential to the
unique chemistry of a just cause termination.” (Emphasis added).
Tzangas, 73 Ohio St.3d at 697-698.
{¶16} Nowhere in its decision did the Review Commission find that
Appellant was blameless regarding the altercation at Autozone. Instead, the
hearing officer based his decision on the reasoning that Appellant’s behavior was
imprudent and that his misconduct was less egregious than Ms. Brown’s. This
comparative fault analysis flies in the face of traditional just cause determination
and is therefore improper.
{¶17} We repeat we are not making any findings of fact nor making a just
cause determination. We are precluded from doing so by the applicable standard
of review. We are simply stating that the Review Commission decided that no just
cause existed for Appellant’s termination based on the comparative fault of the
two participants in the altercation when Ohio precedent clearly states that an
employee’s individual fault is the essential component of a just cause
determination. See Markovich at ¶9 (holding an “employee must provide evidence
his discharge was without just cause by demonstrating he was without fault in the
incident resulting in his termination to show he is entitled to unemployment
compensation.”).
{¶18} With regard to the trial court’s reversal of the Review Commission’s
decision, we find that trial court did overstep its boundaries as a reviewing court.1
We find that the trial court’s conclusions that the hearing officer did not take into
account all of the facts and did not consider whether Appellant’s conduct was still
detrimental to Autozone were presumptuous. Additionally, we agree with
Appellant that the trial court improperly made inferences and findings of fact
when it decided that Appellant’s conduct was indeed detrimental to Autozone.
Most importantly, however, we find that the trial court erred when it determined
that Appellant was terminated for just cause. As discussed supra, neither this
Court, nor the trial court may make a just cause determination on administrative
appeal. See Roberts and Durgan, supra.
{¶19} Based on the foregoing, Appellant’s sole assignment of error has
merit.
III
{¶20} The judgment of the trial court is reversed and the cause remanded.
The trial court is instructed to remand the matter to the Review Commission for
rehearing consistent with this opinion.
Judgment reversed
and cause remanded.