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July 11, 2011

Determining the creditability of a witness


Determining the creditability of a witness
Sarmiento v Newsday, 287 A.D.2d 851

Newsday dismissed Marta Sarmiento from her position after she allegedly uttered a racial epithet in Spanish to a fellow employee in violation of Newsday's rules governing its employees’ conduct. When Sarmiento applied for unemployment insurance, her application was denied on the ground that she had lost her employment due to her misconduct.

Sarmiento appealed and ultimately the Unemployment Insurance Appeals Board, affirming the decision of its Administrative Law Judge [ALJ], ruled that Sarmiento was entitled to benefits. The ALJ had found Sarmiento's “testimony to be the more credible and lacking any disinterested witnesses to the incident in question.” Newsday appealed.

The Appellate Division, Third Department, affirmed the Board's determination, holding that while “[o]ffensive conduct in the workplace, including the use of abusive language, can be found to constitute disqualifying misconduct,” here the only direct evidence that Sarmiento uttered a racial slur was given by the alleged victim thereof who had admittedly been at odds with claimant for some time. Accordingly, the Board's decision was based on it view as to the credibility of the testimony of the witnesses.

The issue of credibility is one for the Board to resolve and as there is substantial evidence to support the Board's decision finding claimant entitled to receive unemployment insurance benefits, the court declined to overturn its ruling.

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NYPPL Blogger Harvey Randall served as Principal Attorney, New York State Department of Civil Service; Director of Personnel, SUNY Central Administration; Director of Research, Governor’s Office of Employee Relations; and Staff Judge Advocate General, New York Guard. Consistent with the Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers and Associations, the material posted to this blog is presented with the understanding that neither the publisher nor NYPPL and, or, its staff and contributors are providing legal advice to the reader and in the event legal or other expert assistance is needed, the reader is urged to seek such advice from a knowledgeable professional.
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