Briefs filed in Ronald Stagg, Respondent, vs. Vintage Place Inc., Respondent, Department of Employment and Economic Development, Appellant.

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Minnesota Appellate Court Issues in Briefs

Shown here are the statements of the issues presented for review by the appellate courts in the briefs filed for this case. The entire brief set can be found at the State Law Library and other libraries around the state. See Minnesota Appellate Court Briefs Collection for more information.

CASE NAME:  Ronald Stagg, Respondent, vs. Vintage Place Inc., Respondent, Department of Employment and Economic Development, Appellant.
        Read the opinion in this case at A09-949
        CITATION: 796 N.W.2d 312 (Minn. 2011)

Legal Issues in APPELLANT-DEPARTMENT'S BRIEF:
  • Issue 1: Individuals who are discharged for committing employment misconduct are ineligible for unemployment benefits. Since 1999, the statutory definition of "misconduct" has been exclusive, and there is no equitable or commonlaw entitlement to benefits. Minnesota courts have long maintained that an employee's misconduct is determined without regard to whether the employee was wrongfully terminated, and the governing statute does not give Unemployment Law Judges authority to consider whether an applicant was terminated for cause. But in Stagg v. Vintage Place, A09-949, filed June 1, 2010, the Court of Appeals revived and strengthened a contradictory line of cases holding that an employer's inconsistent application of progressive discipline steps laid out in its employment handbook is a breach of contract that can remove the employee's actions from the realm of misconduct. (Appendix to Department's Brief, A1-A8.) Did the Court of Appeals err in so doing?
  • Issue 2: Unemployment Law Judges have limited authority. In misconduct proceedings, they conduct non-adversarial, evidence-gathering hearings, in which no party has a burden of proof They decide whether, under a preponderance of the evidence standard, an applicant committed a serious violation of the standards of behavior the employer had the right to reasonably expect of him, or displayed a substantial lack of concern for his employment. Did the Court of Appeals expand the scope of the ULJs' authority and obligation when it held that ULJs must also gather evidence and make a finding as to whether an employer breached an employment contract when it terminated an employee? The Unemployment Law Judge ("ULJ") found that Ronald Stagg, who was frequently absent from his job at Vintage Place, a group home for troubled youth, was terminated for misconduct. The Court of Appeals reversed, finding that Stagg was wrongfully terminated, because Vintage Place breached an employment contract allowing for five warnings before termination, instead of the four that Stagg received. The Court of Appeals did not acknowledge that its decision cannot be reconciled with precedent holding that ULJs and courts are not concerned with whether an employee should have been terminated, nor did it acknowledge that its decision would alter and expand a ULJ's role in misconduct proceedings.
  • Legal Issues in Respondent Ronald J. Stagg's Response to the Department's Appeal of Decision of Court of Appeals:
  • I. May Appellant-Department raise a new legal theory not presented to the Court of Appeals or addressed by the Unemployment Law Judge as a basis for reversing the Court of Appeals' decision to reinstate Respondent Stagg's unemployment compensation benefits? List of Most Apposite Cases: Thiele v. Stich, 425 N.W.2d 580 (Minn. 1988).
  • II. Did the Court of Appeals err by following 26 years of precedent holding that, in cases where an employer provides a progressive disciplinary procedure for absenteeism or tardiness and there is no evidence that the employer gave notice to the employee that it intended to deviate from that policy, the employer must follow that procedure before an employee who is discharged can be properly denied unemployment compensation benefits? List of Most Apposite Cases: Hoemberg v. Watco Publishers, Inc., 343 N.W.2d 676 (Minn. Ct. App. 1984); Eyler v. Minneapolis Star & Tribune Co., 427 N.W.2d 758 (Minn. Ct. App. 1988); Neubert v. St. Ivfary's Hosp. & Nursing Ctr. ofDetroit Lakes, 365 N.W.2d 780 (Minn. Ct. App. 1985). List of Most Apposite Statutes: Minn. Stat. § 268.095, subd. 6(a) (2008).
  • III. Does occasional absenteeism or tardiness constitute statutory unemployment misconduct-a serious violation of the standards of behavior that the employer has a right to expect-where an employer routinely allows employees to be tardy with no consequences? List of Most Apposite Cases: Reddman v. Kokesch Trucking, Inc., 412 N.W.2d 828 (Minn. Ct. App. 1987). List of Most Apposite Statutes: Minn. Stat. § 268.095, subd. 6(a) (2008).
  • Also Filed: APPELLANT-DEPARTMENT'S REPLY BRIEF


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