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Trelleborg YSH, Inc. v. Board of Indiana Department of Workforce Development

Citations: 798 N.E.2d 484; 2003 Ind. App. LEXIS 2109; 2003 WL 22671579Docket: No. 93A02-0303-EX-185

Court: Indiana Court of Appeals; November 12, 2003; Indiana; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by Trelleborg YSH, Inc. against the Indiana Department of Workforce Development Review Board's decision, which affirmed that an employee, Lynn Corcoran, was eligible for unemployment benefits from November 23 to December 14, 2002. The dispute arose after Trelleborg announced layoffs due to a business downturn, allowing for optional layoffs based on seniority, as per the collective bargaining agreement (CBA). Corcoran, a senior employee, opted for layoff and filed for benefits. Her initial claim for unemployment benefits was denied, but an Administrative Law Judge (ALJ) later found that she actively sought work during the relevant period. Trelleborg contested the Board's confirmation of the ALJ's decision, arguing that Corcoran was voluntarily unemployed. The court, however, upheld the Board's findings, emphasizing that decisions are conclusive on factual matters unless legal errors are evident. The statute supports eligibility for individuals laid off under an inverse seniority clause, and such layoffs do not equate to voluntary unemployment. The court concluded that Trelleborg's interpretation of the CBA's seniority provisions was flawed, and dismissed the appeal, affirming Corcoran's entitlement to unemployment benefits.

Legal Issues Addressed

Inverse Seniority Clause in Collective Bargaining Agreement

Application: The court interpreted the CBA's inverse seniority provision to allow senior employees to opt for layoff, thus qualifying for unemployment benefits.

Reasoning: The statute supports eligibility for individuals laid off under an inverse seniority clause in a valid contract.

Judicial Review of Agency Decisions

Application: The court emphasized that factual findings by the Review Board are conclusive unless legal error is demonstrated.

Reasoning: The court emphasized that Review Board decisions are conclusive regarding factual questions and that challenges to these decisions must demonstrate legal error.

Unemployment Benefits Eligibility under Indiana Law

Application: The court affirmed that individuals laid off under an inverse seniority clause are entitled to unemployment benefits if they meet statutory eligibility criteria.

Reasoning: Under Indiana law, specifically Title 22, Article 4, Chapter 12, individuals who are unemployed and meet eligibility requirements are entitled to benefits.

Voluntary Unemployment and Disqualification from Benefits

Application: The court ruled that opting for layoff under an inverse seniority provision does not constitute voluntary unemployment disqualifying an individual from benefits.

Reasoning: It would be illogical to allow benefits for unemployment due to a layoff under an inverse seniority provision while simultaneously disqualifying the individual for exercising that provision.