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Hilton Hotels Corp. v. District of Columbia Department of Employment Services

Citations: 531 A.2d 999; 1987 D.C. App. LEXIS 453Docket: No. 86-1136

Court: District of Columbia Court of Appeals; October 6, 1987; District Of Columbia; State Supreme Court

Narrative Opinion Summary

This case involves a dispute over unemployment benefits following the termination of an assistant manager by a hotel chain for alleged misconduct. The employee, terminated for photocopying confidential documents during a pending lawsuit on gender-based pay discrimination, was initially granted unemployment benefits by a claims examiner. However, upon Hilton's appeal, an Appeals Examiner ruled the termination was due to misconduct, disqualifying her from benefits. The employee contested this decision, and the Office of Appeals and Review reversed, deeming her eligible. Hilton further appealed, arguing procedural errors, particularly the inability to respond to additional evidence submitted by the employee during the appeal. The court found merit in this argument, citing the District of Columbia Administrative Procedure Act, which mandates decisions be based solely on the original hearing record and allows for rebuttal evidence. Consequently, the court reversed the OAR's decision and remanded the case for a de novo hearing, ensuring adherence to procedural standards.

Legal Issues Addressed

Admissibility of Evidence in Administrative Proceedings

Application: The court considers whether the admission of evidence not presented at the original hearing violates procedural rules under the APA.

Reasoning: The court referenced the District of Columbia Administrative Procedure Act (APA), affirming that parties have the right to submit rebuttal evidence and that the OAR must base its decision solely on the record from the appeals examiner's hearing without accepting additional evidence.

Procedural Fairness in Administrative Appeals

Application: The court evaluates whether the failure to allow a party to respond to new evidence submitted during an appeal constitutes a procedural error.

Reasoning: The court agreed with Hilton on the second contention regarding the lack of opportunity to respond and did not address the other arguments.

Termination for Misconduct and Eligibility for Unemployment Benefits

Application: The court examines whether the termination of an employee for misconduct disqualifies them from receiving unemployment benefits.

Reasoning: The Appeals Examiner subsequently ruled that Sachko was discharged for misconduct, rendering her ineligible for benefits.