Justia Public Benefits Opinion Summaries

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