----ooOoo---- 
EAGALA, Inc., 
Petitioner, 
v. 
Department of Workforce 
Services, Workforce Appeals 
Board; and Gregory W. Kersten, 
Respondents. 


¶1 Petitioner the Equine Assisted Growth and Learning 
Association, Inc. (EAGALA) seeks judicial review of Respondent 
Workforce Appeals Board's (the Board's) final order ruling that 
EAGALA did not have just cause to terminate Respondent Gregory W. 
Kersten. See Utah Code Ann. § 35A-4-405(2)(a) (2005). We 
affirm. 

BACKGROUND 

¶2 Kersten and Lynn Thomas founded EAGALA in 1999 as a 
nonprofit corporation promoting equine assisted therapy. Kersten 
was the chairman of the company's board of trustees. Kersten and 
Thomas both resigned from the board in 2005 because they were 
collecting salaries. Kersten then became the company's president 
and chief executive officer. 

¶3 On November 16, 2005, Kersten was notified that the board of 
directors had voted unanimously to terminate his employment. 
EAGALA claimed that Kersten misused corporate funds when, among 
other things, he charged EAGALA for the repair of his tractor,
for veterinary care of his horses, for payments on his house and 
barn, and for renting office space in his home even after most of 
EAGALA's offices had moved to a different location. EAGALA also 
contended that Kersten verbally abused board members and failed 
to comply with the directives of the board by not submitting a 
strategic plan for the company. 

¶4 After receiving notification that he had been terminated, 
Kersten applied for benefits under the Employment Security Act. 
The Department of Workforce Services initially denied Kersten's 
claim, finding that he was discharged from his job for an act 
constituting a crime that he admitted or of which he had been 
convicted. Kersten appealed that decision and sought a hearing 
before an administrative law judge (ALJ). 

¶5 Around 8 a.m. on the morning of the hearing, EAGALA faxed 
documentary evidence to the ALJ and emailed copies of the 
documents to Kersten. During the 3 p.m. telephonic hearing, 
Kersten told the ALJ that he had not checked his email that day 
and therefore had not received the documents. The ALJ then 
determined that the documents would not be received as evidence. 

¶6 After the hearing, the ALJ ruled that EAGALA failed to prove 
that it had just cause to terminate Kersten because EAGALA did 
not show that Kersten was culpable for his conduct or that he had 
knowledge that it was wrong. Therefore, EAGALA was found to be 
liable for a share of the unemployment benefit costs paid to 
Kersten. EAGALA appealed the ALJ's decision to the Board, 
arguing that just cause was demonstrated and that the documentary 
evidence should have been admitted. The Board adopted the ALJ's 
findings of fact and affirmed the ALJ's decision, concluding that 
EAGALA did not unequivocally disallow Kersten's expenditures. 
The Board's decision did not make any reference to the excluded 
documentary evidence. EAGALA seeks review of the Board's 
decision by this court. 

ISSUES AND STANDARDS OF REVIEW 

¶7 EAGALA first argues that the Board did not "decide[] all of 
the issues requiring resolution," Utah Code Ann. § 63-46b- 
16(4)(c) (2004), because it failed to rule on the ALJ's decision 
to exclude the documentary evidence faxed the morning of the 
hearing. Issues raised under Utah Code section 63-46b-16(4)(c) 
are questions of law to which we apply a correction of error 
standard. See SEMECO Indus., Inc. v. State Tax Comm'n , 849 P.2d 
1167, 1171 (Utah 1993). 

¶8 EAGALA also challenges the Board's factual findings 
supporting its conclusion that EAGALA did not have just cause to 
terminate Kersten. See Utah Code Ann. § 63-46b-16(4)(g). 
[T]his court grants great deference to an 
agency's findings, and will uphold them if 
they are supported by substantial evidence 
when viewed in light of the whole record 
before the court. Substantial evidence has 
been defined as such relevant evidence as a 
reasonable mind might accept as adequate to 
support a conclusion. . . . It is the 
petitioner's duty to properly present the 
record, by marshaling all of the evidence 
supporting the findings and showing that, 
despite that evidence and all reasonable 
inferences that can be drawn therefrom, the 
findings are not supported by substantial 
evidence. 

¶9 Finally, EAGALA contends that the Board erred when it 
concluded that EAGALA did not have just cause to terminate 
Kersten. See Utah Code Ann. § 63-46b-16(4)(d). "When we review 
an agency's application of the law to a particular set of facts, 
we give a degree of deference to the agency." Autoliv ASP, Inc. 
v. Department of Workforce Servs., 2001 UT App 198,¶16, 29 P.3d 7 
(quotations and citations omitted). Application of the 
Employment Security Act "requires little highly specialized or 
technical knowledge . . . uniquely within the [Board's] 
expertise"; therefore, we grant "moderate deference" to the 
Board's decision. Id. (alteration in original) (quotations and 
citations omitted). "Thus, we will uphold the [Board's] decision 
so long as it is within the realm of reasonableness and 
rationality." Id. (alteration in original) (quotations and 
citations omitted). 

ANALYSIS 

I. Exclusion of Documentary Evidence 
¶10 EAGALA first argues that the Board erred by failing to 
address the ALJ's refusal to admit documentary evidence EAGALA 
faxed to the ALJ and emailed to Kersten the morning of the 
hearing. According to EAGALA, the Board failed to "decide[] all 
of the issues requiring resolution," Utah Code Ann. § 63-46b- 
16(4)(c), and instead of excluding the documents, the ALJ should 
have followed the relevant administrative rule, which provides: 

Parties may introduce relevant documents 
into evidence. Parties must mail, fax, or 
deliver copies of those documents to the ALJ 
assigned to hear the case and all other 
interested parties so that the documents are 
received prior to the hearing. Failure to 
prefile documents may result in a delay of 
the proceedings. If a party has good cause 
for not submitting the documents prior to the 
hearing or if a party does not receive the 
documents sent by the Appeals Unit or another 
party prior to the hearing, the documents 
will be admitted after provisions are made to 
insure due process is satisfied. At his or 
her discretion, the ALJ can either: 

(a) reschedule the hearing to another 
time;
(b) allow the parties time to review the 
documents at an in-person hearing; 
(c) request that the documents be faxed 
during the hearing, if possible, or read the 
material into the record in case of telephone 
hearing; or 
(d) leave the record of the hearing 
open, send the documents to the party or 
parties who did not receive them, and give 
the party or parties an opportunity to submit 
additional evidence after they are received 
and reviewed. 

Utah Admin. Code Ann. R994-508-109(11) (2006). Kersten claimed 
that he had not checked his email the morning of the hearing and 
thus had not received the documents. After learning this, the 
ALJ stated that he would not address the documents or admit them 
into the record. The ALJ also stated, however, that he would not 
"prevent any discussion or verbal testimony regarding anything 
that might be contained in those documents." 

¶11 Under the plain language of the rule, the proper course 
would have been to order one of the enumerated options, such as 
rescheduling the hearing, reading the documents into the record, 
or resending the documents to Kersten. However, we need not 
determine whether the Board erred by failing to address this 
issue because, even assuming the documents should have been 
admitted, EAGALA was not prejudiced. 

¶12 EAGALA asserts that the excluded documents were crucial 
because they included checks written by Kersten to pay for both 
his horse's veterinary expenses and the construction of his barn. 
The documents also included corporate credit card statements 
showing charges for vehicle maintenance, fuel, and dry cleaning. 

¶13 We disagree that the introduction of these documents was 
critical because the ALJ allowed extensive questioning and 
discussion on all of the contested expenditures. The ALJ asked 
Kersten whether he had a corporate credit card, whether he was 
given any instructions on what the card could be used for, and 
whether he used the card for his dry cleaning bills. The ALJ 
further questioned Kersten about the veterinary bills and the 
vehicle costs. 

¶14 EAGALA's witnesses were also asked about these expenditures. 
Thomas told the ALJ that Kersten "purchased a barn for his 
personal property," "used EAGALA funds to support his personal 
horses," and "purchased items--tools [and] fencing materials that 
benefitted his personal property." EAGALA's counsel specifically 
asked Thomas whether Kersten "would . . . make out checks for 
personal use." Thus, because these expenditures were repeatedly 
discussed, EAGALA was not harmed by the exclusion of the 
documents. Cf. State v. Stephens, 667 P.2d 586, 588 (Utah 1983) 
("Where evidence is excluded by the trial court, any error which 
may have resulted from such exclusion is cured where the 
substance of the evidence is later admitted through some other 
means.").1 

II. The Board's Factual Findings 

¶15 EAGALA next contends that the Board's decision is not 
supported by substantial evidence. We disagree. Although EAGALA 
has marshaled the evidence in support of the Board's decision, it 
has not demonstrated "that despite the supporting facts, . . . 
the findings are not supported by substantial evidence." Grace 
Drilling Co. v. Board of Review of the Indus. Comm'n , 776 P.2d 
63, 68 (Utah Ct. App. 1989). 

¶16 We review the whole record before the court to determine 
whether the Board's findings are supported by substantial 
evidence. See Utah Code Ann. § 63-46b-16(g). It is not this
court's place to "substitute its judgment as between two 
reasonably conflicting views, even though we may have come to a 
different conclusion had the case come before us for de novo 
review." Grace Drilling Co., 776 P.2d at 68. Similarly, "[i]t 
is the province of the Board, not appellate courts, to resolve 
conflicting evidence, and where inconsistent inferences can be 
drawn from the same evidence, it is for the Board to draw the 
inferences." Id. 

¶17 The Board found that because EAGALA did not make a clear 
showing that Kersten knew his expenses were improper, EAGALA 
failed to show that just cause existed. After reviewing the 
record, we conclude that this finding is supported by substantial 
evidence. This evidence includes Kersten's testimony that, to 
his knowledge, he did not use corporate funds improperly and 
believed he was authorized to charge EAGALA for dry cleaning his 
uniform; for the maintenance of his vehicle that he used for 
company events; and for repair of his tractor that was used for 
EAGALA purposes. He further testified that he did not charge 
EAGALA for the care of his personal horses. Further, there is no 
dispute in the record that Kersten never received a negative job 
performance review. And, Kersten stated that none of the Board 
members ever complained to him about his expenditures or 
behavior. 

¶18 The contrary evidence includes the testimony of Thomas and 
Amy Blossom, EAGALA board members, that Kersten did not have 
permission to use company funds for his dry cleaning, vehicle, 
tractor, and veterinary expenses. Thomas also testified that she 
confronted Kersten about his continued withdrawal of $1000 per 
month for rent even after most of the EAGALA offices had moved 
out of Kersten's home. Thomas further testified that Kersten 
used corporate money to start a tack and saddle business and to 
build a barn, improper expenditures that the Board only 
discovered recently. Thomas also testified about incidents where 
Kersten verbally abused EAGALA board members. 

¶19 Thus, many of the facts surrounding Kersten's expenditures 
and termination are disputed, with each side offering its own 
version of events. However, as stated, it is not our duty to 
resolve these conflicts, see id.; rather, it is the province of 
the ALJ to determine which party is more credible where divergent 
testimony is given. As noted by the Board in adopting the ALJ's 
findings, the ALJ in this case "[wa]s in the unique position of 
being an active participant in the hearing, interacting with the 
parties and also questioning the witnesses" and, in so doing, 
"found that the claimant was credible" because he "was able to 
provide an explanation as to why the expenses should have been 
paid by the corporation." See Albertsons, Inc. v. Department of 
Employment Sec., 854 P.2d 570, 574-75 (Utah Ct. App. 1993)
(noting that testimony of parties diverged as to whether claimant 
intentionally damaged forklift, but court was not in position "to 
second guess the detailed findings of the ALJ"). We therefore 
decline to disturb the ALJ's and Board's factual findings because 
they are supported by substantial evidence. 

III. The "Just Cause" Determination 

¶20 Finally, EAGALA asserts that the Board erroneously concluded 
that no just cause existed to terminate Kersten. An employee 
will not be awarded unemployment benefits if the Department of 
Workforce Services concludes that the employee was discharged for 
just cause. See Utah Code Ann. § 35A-4-405(2)(a); see also 
Autoliv ASP, Inc. v. Department of Workforce Servs. , 2001 UT App 
198,¶17, 29 P.3d 7; Bhatia v. Department of Employment Sec. , 834 
P.2d 574, 577 (Utah Ct. App. 1992). "To establish 'just cause,' 
three elements must be present: culpability, knowledge, and 
control." Autoliv ASP, 2001 UT App 198 at ¶17; see also Utah 
Admin. Code Ann. R994-405-202 (2006). "The employer must 
establish each of the three elements . . . for the 
[administrative agency] to deny benefits." Gibson v. Department 
of Employment Sec., 840 P.2d 780, 783 (Utah Ct. App. 1992). 
Because we affirm the ALJ and the Board's finding that Kersten 
did not have knowledge that his conduct was inappropriate, we 
need not examine the culpability and control prongs of the just 
cause inquiry. 

¶21 To establish just cause, 
[t]he worker must have had knowledge of 
the conduct the employer expected. There 
does not need to be evidence of a deliberate 
intent to harm the employer; however, it must 
be shown that the worker should have been 
able to anticipate the negative effect of the 
conduct. Generally, knowledge may not be 
established unless the employer gave a clear 
explanation of the expected behavior or had a 
written policy, except in the case of a 
violation of a universal standard of conduct. 
A specific warning is one way to show the 
worker had knowledge of the expected conduct. 
After a warning the worker should have been 
given an opportunity to correct the 
objectionable conduct. 

Utah Admin. Code Ann. R994-405-202(2) (emphasis added). Thus, 
our inquiry focuses on whether EAGALA's board of directors gave 
Kersten a clear explanation regarding his use of corporate funds
or whether Kersten violated a universal standard of conduct. See 
Autoliv ASP, 2001 UT App 198 at ¶18. 

¶22 Kersten asserts that he never knew that his expenditures 
were inappropriate because EAGALA did not provide him with any 
warnings or written notice. EAGALA responds by contending that 
the trustees did not know about the misuse of funds, and even if 
Thomas knew about Kersten's expenditures, Thomas was Kersten's 
underling and was therefore powerless to do anything about it. 
Alternatively, EAGALA contends that Kersten violated a universal 
standard of conduct by engaging in self-dealing. 

¶23 We disagree with both of EAGALA's contentions. First, it 
was "within the realm of reasonableness and rationality," id. at 

¶16, for the Board and ALJ to conclude that knowledge was not 
established. EAGALA neither warned Kersten to stop his spending 
practices2 nor took any other action to block Kersten's use of 
his corporate credit card or his access to the company bank 
account. The Board and ALJ also concluded that EAGALA did not 
take any steps to stop Kersten's monthly withdrawal of $1000 for 
rent payments after EAGALA moved its offices out of Kersten's 
home. EAGALA repeatedly asserts that Kersten should have sought 
permission from the board of trustees before making his 
expenditures. This may well have been the more prudent course of 
action, but, under the rule quoted above and the specific facts 
of this case, it was the employer's duty to provide a clear 
explanation of expected conduct. See Utah Admin. Code Ann. R994- 
405-202(2). Kersten was a founder of EAGALA and served as 
chairman of the board of trustees for six years when he became 
president and chief executive officer. The business was 
conducted from offices located in the basement of Kersten's home, 
company horses were sometimes stabled in Kersten's barn, and 
Kersten used his personal equipment to keep the offices 
accessible during the winter and for other EAGALA-related 
purposes. By the time the structure of the organization changed 
in 2006, the lines between personal and business expenditures had 
been blurred by practice. EAGALA made no attempt to notify 
Kersten that those past practices would no longer be tolerated. 
Under the unique circumstances of this case, we cannot say that 
the Board's conclusion is outside the bounds of reasonableness 
and rationality. 

¶24 The Board also reasonably concluded that Kersten did not 
violate a universal standard of conduct by engaging in self
dealing because Kersten "gave credible testimony as to why he was 
authorized to charge [his] expenses to the corporation." We 
likewise do not believe that Kersten's behavior reached a level 
where it violated a universal standard of conduct. See, e.g., 
Autoliv ASP, 2001 UT App 198 at ¶27 (concluding that emailing 
sexually explicit jokes, pictures, and videos in the workplace 
"constitutes a flagrant violation of a universal standard of 
behavior"); Bhatia v. Department of Employment Sec. , 834 P.2d 
574, 580 (Utah Ct. App. 1992) (concluding that "angrily walking 
off the job in the middle of a busy shift at a crucial time for 
the employer's business, leaving others to assume . . . 
responsibilities, and us[ing] vulgarity within the hearing of 
customers" constituted a violation of a universal standard of 
behavior). Here, the lines between corporate and personal 
activities and expenditures were blurred by historic operations. 
Kersten provided office space for the company in his home and 
stabled company horses in his barn. Unlike more traditional 
commercial enterprises, these practices created confusion about 
the appropriate use of corporate funds. Under the facts of this 
case, we affirm the Board's determination that Kersten did not 
violate a universal standard of conduct. 

CONCLUSION 

¶25 EAGALA was not prejudiced by the exclusion of the 
documentary evidence because EAGALA was free to use the 
information contained in those documents at the hearing and 
Kersten admitted the expenditures reflected by the documents. 
The ALJ and Board's decisions are supported by substantial 
evidence. Finally, the ALJ and Board did not exceed the bounds 
of reasonableness and rationality in determining that EAGALA did 
not have just cause to terminate Kersten. 

¶26 We affirm. 
______________________________ 
Carolyn B. McHugh, Judge 
----- 

¶27 WE CONCUR: 
______________________________ 
Russell W. Bench, 
Presiding Judge

20060340-CA 10 
______________________________ 
William A. Thorne Jr., Judge





notes:

1 EAGALA further contends that it was harmed because it could 
not use the documents to impeach Kersten's testimony. We 
disagree. For the most part, Kersten admitted to using corporate 
funds for the expenses shown in the documents, but he explained 
why he believed it was proper to do so. Thus, the documents 
would not have shown Kersten to be untruthful. Moreover, and 
importantly, the ALJ's ruling did not prevent EAGALA from making 
specific reference to the documents or even reading portions of 
the documents into the record during its examination of Kersten. 

2 At most, the record shows that Thomas told Kersten that his 
expenditures blurred the lines between company use and personal 
use but did not specify what expenditures in particular were 
problematic.