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Langer v. Employment Division

Citations: 111 Or. App. 154; 826 P.2d 6; 1992 Ore. App. LEXIS 341Docket: 90-AB-516; CA A64721

Court: Court of Appeals of Oregon; February 11, 1992; Oregon; State Appellate Court

Narrative Opinion Summary

This case involves an appeal from a claimant who was denied unemployment benefits following his termination from a position as an assistant district attorney. The Employment Appeals Board (EAB) upheld the denial, citing misconduct related to the claimant's refusal to undergo a mandatory psychiatric evaluation as directed by the district attorney. The claimant's employment history included unauthorized absences and erratic behavior, prompting the employer to suspect a manic-depressive illness. Though the claimant argued that the evaluation order was retaliatory and violated his privacy, the EAB found the order reasonable and necessary to assess his capability to perform duties. The claimant also contended that the chosen psychologist was biased, but the EAB upheld the selection as justified. Concerns about the privacy of the evaluation report were noted, but the EAB determined the focus was solely on job performance. Ultimately, the EAB concluded that the claimant's refusal to comply with the examination and his policy violations constituted deliberate insubordination, affirming the termination decision as non-retaliatory and supporting the denial of benefits.

Legal Issues Addressed

Evaluation of Employer's Orders

Application: EAB concluded that the district attorney's order for a psychiatric evaluation was reasonable given the claimant's behavior and absences, rejecting the claimant's argument of bias against the chosen psychologist.

Reasoning: Claimant argued the order was unreasonable, yet did not challenge the district attorney's authority to issue it. EAB justified the order based on claimant's erratic behavior and stress-related absences, concluding it was reasonable.

Insubordination as Grounds for Termination

Application: Claimant's refusal to comply with orders and violation of office policies were deemed a deliberate breach of standards, constituting insubordination.

Reasoning: While disobeying an order alone does not necessarily lead to a negative conclusion, EAB found that the claimant's refusal to comply with the examination and his violation of district attorney office policies indicated a pattern of insubordination.

Misconduct under ORS 657.176(2)(a)

Application: The Employment Appeals Board determined that the claimant's refusal to comply with the psychiatric examination constituted misconduct related to his employment, justifying denial of unemployment benefits.

Reasoning: The Employment Appeals Board (EAB) noted claimant’s significant absences due to depression earlier that year and subsequent erratic behavior, leading the district attorney to suspect a manic-depressive illness. The examination was justified as it aimed to assess his capability to perform his duties.

Privacy Concerns in Employment Evaluations

Application: The claimant's concerns about privacy regarding a psychiatric evaluation report were acknowledged, but EAB found the examination necessary for assessing job performance.

Reasoning: The claimant refused to undergo a psychiatric examination due to concerns about privacy, specifically regarding the potential dissemination of intimate details from his personnel file to the district attorney and others.

Retaliatory Discharge

Application: The claimant alleged that his termination was retaliatory for a complaint made to the Oregon State Bar Association, but the EAB found substantial evidence to the contrary.

Reasoning: Claimant alleges that his termination was retaliatory in response to a complaint made to the Oregon State Bar Association regarding the district attorney's handling of media access to case files. However, the Employment Appeals Board (EAB) found substantial evidence supporting the conclusion that claimant did not establish his discharge was retaliatory.