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September 05, 2024

Claimant's application for unemployment insurance benefits denied because claimant found to have voluntarily left her employment without good cause

Claimant applied for unemployment insurance benefits after she left her job claiming she had left due to "lack of work'.

The Department of Labor issued an initial determination disqualifying Claimant from benefits, finding, among other things, that she had been discharged for misconduct. Ultimately an Administrative Law Judge [ALJ] found that Claimant's testimony regarding her supervisor's behavior did not rise to the level of good cause to justify quitting her job and, thus, determined that claimant had voluntarily separated from her employment without good cause, disqualifying her from receiving benefits. Finding that Claimant had willfully misrepresented the circumstances under which she left her employment as lack of work when she had voluntarily quit without good cause, the ALJ imposed a reduced forfeiture penalty of four effective days.

The Unemployment Insurance Appeal Board affirmed the ALJ's findings that Claimant had voluntarily separated from her employment without good cause and had made willful misrepresentations in filing for unemployment insurance benefits. Claimant appealed the Board's decision.

The Appellate Division affirmed the Board's determination. The court explained, "Whether a claimant has good cause to leave employment is a factual issue for the Board to resolve and its determination will be upheld if supported by substantial evidence" and "Issues of witness credibility, the evaluation of evidence and the inferences to be drawn therefrom are within the exclusive province of the Board".

While Claimant testified that her supervisor had engaged in rude, disrespectful and unprofessional behaviors toward her, had yelled at her and caused unspecified "problems," creating conflict and making her uncomfortable, the ALJ, and the Board, found that, while the supervisor may have acted in a "disagreeable manner" when interacting with claimant, the supervisor never "stepped outside the bounds of propriety." 

Further, the Appellate Division's decision reports that "Despite specific questioning, the ALJ and the Board noted, Claimant "offered only vague and generic characterizations of her supervisor's behavior and failed to recount a single incident supporting her claim that her work conditions became unbearable and that she was forced to resign." The court also observed that "Inability to get along with a supervisor does not constitute good cause for leaving employment."

Finding that substantial evidence supported the Board's factual determination that Claimant made willful misrepresentations when she filed for benefits citing lack of work when, in fact, she left under disqualifying circumstances, including claimant's own testimony acknowledging that she left her employment due to her supervisor's behavior, the Appellate Division said it discerned no basis upon which to disturb the Board's determination.

Click HERE to access the Appellate Division's decision posted on the Internet.


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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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