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Rainbolt v. Everett
Citations: 6 Ark. App. 204; 639 S.W.2d 532; 1982 Ark. App. LEXIS 851Docket: E 82-99
Court: Court of Appeals of Arkansas; October 6, 1982; Arkansas; State Appellate Court
The case involves an appeal concerning unemployment benefits for the appellant, who had previously been found to have voluntarily quit her job to move with her spouse. In the first ruling, the court reversed the Board of Review's decision, establishing that the Employment Security Division could be estopped from denying the appellant's entry into the labor market based on representations from its agent. The case was remanded to allow the State to present evidence against the estoppel defense, marking the first application of this doctrine to a claimant seeking unemployment benefits. Upon remand, three issues remained: estoppel, registration and reporting requirements, and the appellant's efforts to secure employment. The Appeal Tribunal held a hearing, during which Mr. Keith Johnson provided testimony but could not recall details of his conversation with the appellant. The Board of Review concluded that the appellant had not left the job market, as her move was only 20-21 miles away, and determined she quit for personal reasons. The Board emphasized that the issue of her voluntary quit was already settled and not subject to review again, as established in the previous ruling. The doctrine of res judicata was upheld, asserting that administrative agencies can act in a quasi-judicial capacity, resolving disputes that have been adequately litigated. The law of the case doctrine applies to administrative proceedings involving quasi-judicial functions, establishing that decisions made or issues that could have been appealed are conclusively adjudicated and cannot be relitigated. In the referenced case, the Board is limited to addressing three specific issues on remand, particularly the issue of estoppel, using the existing record without further hearings or affidavits. The Board must certify its decision to the court within thirty days, ensuring that all parties, including those unrepresented by counsel, receive copies to facilitate a timely appeal. The decision is reversed and remanded, although the procedural due process implications of the Appeal Tribunal's actions remain subject to debate.