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Hadley v. DIR. OF DEPT. OF INDUS. RELATIONS
Citation: 473 So. 2d 519Docket: Civ. 4656
Court: Court of Civil Appeals of Alabama; June 19, 1985; Alabama; State Appellate Court
In the case of Margaret Hadley v. Director of the Department of Industrial Relations and Mannor Slacks, Inc., the Court of Civil Appeals of Alabama addressed an unemployment compensation claim. Hadley, a seamstress employed for five years on a piece rate basis, quit her job after being informed of an increase in the minimum production requirements, believing her weekly earnings would decrease from $210 to $180. Despite being aware of the contract provisions between the employer and the local union, which allowed for re-engineering of piece rates and established grievance procedures, Hadley did not pursue any formal request for re-engineering or file a grievance. The trial court ruled that Hadley was not entitled to unemployment compensation because she did not follow the contractual procedures prior to quitting. The court emphasized that an employee must demonstrate good cause related to their work to qualify for benefits, and Hadley's immediate resignation without seeking resolution was deemed unreasonable. Consequently, the court upheld the trial court's decision, confirming that Hadley's voluntary departure disqualified her from receiving unemployment benefits. The re-engineering provision and grievance procedures were deemed reasonable. An employee's failure to adhere to a reasonable employment rule does not equate to non-compliance with the unemployment compensation act unless no valid excuse for the non-compliance is presented, which could indicate willful disregard for consequences. In the present case, the employee acknowledged not following reasonable rules and procedures. The trial court inferred her indifference to her employment status due to her failure to demonstrate that pursuing re-engineering through a written grievance was futile, particularly as she resigned the day after learning of new production quotas. The opinion was authored by Retired Circuit Judge Edward N. Scruggs and adopted by the court, affirming the decision and overruling the application for rehearing, with all judges concurring.