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City of Milwaukee v. Department of Industry, Labor & Human Relations

Citations: 316 N.W.2d 367; 106 Wis. 2d 254; 1982 Wisc. LEXIS 2517Docket: 80-1558

Court: Wisconsin Supreme Court; March 2, 1982; Wisconsin; State Supreme Court

Narrative Opinion Summary

The Supreme Court of Wisconsin reviewed the eligibility of school crossing guards for unemployment benefits during summer recess in a case involving the City of Milwaukee and the Department of Industry, Labor, and Human Relations (DILHR). The crossing guards, employed by the City but serving public schools, were laid off during summer with assurances of rehire in the fall. Initially granted benefits by DILHR, the court of appeals reversed this decision, interpreting sec. 108.04 (17. b. Stats. 1977) to exclude such benefits for individuals with reasonable reemployment assurances. The Supreme Court found the statute ambiguous, needing clarification on whether it solely pertained to employees of educational institutions. Emphasizing legislative intent and federal compliance, the court concluded that only those directly employed by educational institutions should be denied benefits. The ruling underscored the significance of statutory interpretation and legislative history, reversing the court of appeals' decision and affirming DILHR's interpretation. This case highlights the complexity of unemployment compensation law and the interplay between state statutes and federal mandates.

Legal Issues Addressed

Clarification of Legislative Intent

Application: The Supreme Court of Wisconsin concluded that the legislative intent was to exclude only employees directly employed by educational institutions from unemployment benefits during school breaks.

Reasoning: The conclusion drawn is that the legislature intended the exemption to apply only to individuals directly employed by the educational institution, despite potential incongruities regarding the petitioners—City-hired crossing guards assigned solely to school duties, who were paid by the City.

Conformity with Federal Unemployment Law

Application: Wisconsin's statute was amended to conform with federal standards, which deny benefits to school employees during breaks if they are assured of reemployment.

Reasoning: The bill, unanimously recommended by the Council on Unemployment Compensation, aimed to align state laws with federal requirements, particularly concerning denial of benefits for school workers during recesses and vacations.

Interpretation of Unemployment Benefits Statute

Application: The case addressed whether school crossing guards employed by the City, but performing services for public educational institutions, are eligible for unemployment benefits during summer recess.

Reasoning: The statute in question is deemed ambiguous regarding whether it applies solely to employees of educational institutions or includes employees from other employers performing services for schools.

Weight of Administrative Interpretation

Application: The court gave considerable weight to the Department of Industry, Labor and Human Relations' interpretation, which supported the exclusion of crossing guards from unemployment benefits.

Reasoning: The interpretation from the Department of Industry, Labor and Human Relations (DILHR) is given considerable weight, supporting the conclusion that crossing guards are excluded from unemployment benefits during school vacations.