Justia Public Benefits Opinion Summaries

Dominique Robison, a bus operator for the Washington Metropolitan Area Transit Authority (WMATA), was suspended from her job after bringing her own bottle of urine to a scheduled drug test, which was deemed an automatic failure under WMATA’s policy. She was suspended without pay for 180 days and subsequently filed for unemployment benefits, which were initially granted by the claims examiner due to WMATA's failure to provide evidence of misconduct.WMATA appealed to the Office of Administrative Hearings (OAH), where an administrative law judge (ALJ) found that Robison had committed simple misconduct, not gross misconduct, and was disqualified from benefits for the first eight weeks of her unemployment. The ALJ reasoned that Robison’s violation was her first drug-related offense and that WMATA’s decision to suspend rather than terminate her undercut the severity of the offense. The ALJ did not consider WMATA’s argument that Robison was ineligible for benefits because she was merely suspended, not terminated.WMATA then appealed to the District of Columbia Court of Appeals. The court reviewed whether the ALJ made findings of fact on each materially contested issue, whether substantial evidence supported each finding, and whether the ALJ’s conclusions flowed rationally from its findings. The court concluded that Robison’s actions did not rise to the level of gross misconduct, as there was no direct evidence of drug use or impairment, no demonstrable impact on passenger safety or WMATA’s operations, and it was her first offense. The court also determined that Robison was "unemployed" within the meaning of the statute because she was suspended without pay and did not work during the suspension period.The District of Columbia Court of Appeals affirmed the ALJ’s decision. View "WMATA v. Robison" on Justia Law

Five individuals experienced significant delays in receiving food assistance (SNAP or P-EBT), TANF, or Medicaid benefits. Each requested a hearing before an Administrative Law Judge (ALJ) at the Office of Administrative Hearings (OAH). The ALJs directed the District of Columbia Department of Human Services (DHS) to provide the correct benefits to the claimants, which was eventually done. However, the ALJs also issued orders requiring DHS to correct an "unlawful policy" related to delays caused by internal computer errors or faulty programs.The ALJs' orders were based on the assumption that the delays were due to a systemic issue with DHS's computer systems. DHS representatives mentioned various reasons for the delays, including confusion, human error, and the need for IT tickets to resolve specific issues. In some cases, the delays were attributed to problems with external agencies, such as the Office of the State Superintendent of Education (OSSE). Despite these explanations, the ALJs issued broad orders for DHS to correct its policies.The District of Columbia Court of Appeals reviewed the case and found that the records did not support the conclusion that the delays were due to a DHS policy or systemic computer errors. The court noted that the ALJs did not hold evidentiary hearings or gather substantial evidence to support their findings. The court also found that the ALJs overstepped their authority by issuing broad injunctive relief without a demonstrated need for such measures.The court vacated the challenged orders, concluding that there was no substantial evidence of a DHS policy causing the delays and that the ALJs had not followed proper procedures in issuing their orders. The court emphasized the need for ALJs to base their decisions on substantial evidence and to consider whether broad injunctive relief is necessary. View "District of Columbia Dep't of Human Services v. Butler" on Justia Law

Travon Celey, a former employee of Children’s National Medical Center, was terminated on March 1, 2022, for accumulating six instances of tardiness within a twelve-month period. Celey subsequently applied for unemployment benefits, but a claims examiner from the District of Columbia Department of Employment Services (DOES) disqualified him, citing gross misconduct due to repeated tardiness following warnings.Celey appealed the decision to the Office of Administrative Hearings (OAH). Despite filing the appeal well beyond the fifteen-day deadline, OAH extended the deadline due to good cause and excusable neglect. During the hearing, the Hospital presented evidence and testimony showing that Celey had been warned and suspended for his tardiness, referencing both the independent Attendance Policy and the collective bargaining agreement (CBA) policy. The CBA policy mandated termination after the sixth instance of tardiness, while the independent Attendance Policy allowed for termination only after the eighth instance.The OAH administrative law judge (ALJ) found that the Hospital had issued inconsistent rules, failing to clearly notify Celey of the specific policy that applied to him. The ALJ concluded that Celey did not willfully violate the Hospital’s expectations and was therefore qualified to receive unemployment benefits.The District of Columbia Court of Appeals reviewed the case and affirmed the OAH decision. The court held that substantial evidence supported the ALJ’s finding that Celey was not adequately informed about the CBA policy, which was crucial for determining his eligibility for unemployment benefits. The court emphasized that the issue was whether Celey was on notice that his conduct could lead to termination, not whether the Hospital was justified in terminating him. View "Children's National Medical Center v. Celey" on Justia Law

The petitioner, Lin Luo, sought review of a final order from the Office of Administrative Hearings (OAH) that determined her ineligible for unemployment benefits from April 5, 2023, to June 28, 2023. Luo was terminated from her position at the American Chemical Society (ACS) and received post-termination payments under an Agreement and General Release. The OAH administrative law judge (ALJ) classified these payments as severance pay, which disqualified her from receiving unemployment benefits. Luo argued that the payments were settlement payments for sexual harassment claims, not severance pay.The Department of Employment Services (DOES) initially found Luo ineligible for benefits for a slightly different period. Luo appealed to OAH, where the ALJ held a hearing and excluded Luo's evidence of her harassment claims, citing the parol evidence rule. The ALJ concluded that the Agreement's language unambiguously indicated the payments were severance pay, based on Luo's years of service and lack of advance notice of termination. The ALJ also noted that the Agreement included a release of claims against ACS and found that Luo signed the Agreement without fraud, duress, or mutual mistake.The District of Columbia Court of Appeals reviewed the case and found that the ALJ erred in not considering parol evidence regarding the nature of the payments. The court noted that the parol evidence rule does not preclude evidence showing that factual recitals in an agreement are untrue. The court concluded that the ALJ should have considered Luo's testimony and evidence about her harassment claims to determine the parties' intent regarding the payments. The court vacated the OAH orders and remanded the case for further proceedings to consider this evidence. View "Luo v. District of Columbia Department of Employment Services" on Justia Law