Heatherly v. Carter

Citations: 485 So. 2d 769; 1986 Ala. Civ. App. LEXIS 1243Docket: Civ. 5043

Court: Court of Civil Appeals of Alabama; February 4, 1986; Alabama; State Appellate Court

Lead Opinion SummaryLead Opinion Original

EnglishEspañolSimplified EnglishEspañol Fácil

The case involves an appeal by the State Department of Industrial Relations regarding a judgment that granted Peggy Carter extended trade readjustment allowance (TRA) benefits under the Federal Trade Act of 1974. Carter lost her job at Siluria Textiles, which ceased operations due to foreign competition in 1979. She initially received fifty-two weeks of basic TRA benefits, after which she was informed she could qualify for an additional twenty-six weeks of extended TRA benefits if she enrolled in an approved training program. Carter enrolled in an LPN training program but discontinued her studies after four months. Consequently, the Department disqualified her from receiving the extended benefits, asserting that she dropped out of the approved program. After her disqualification was upheld by a departmental appeals referee and the Board of Appeals, Carter appealed to the circuit court, which reversed the Board's decision, finding she had good cause to discontinue her training. The court ruled in favor of Carter, awarding her the remaining weeks of extended TRA benefits. The Department subsequently appealed this decision. The Federal Trade Act aims to promote economic growth and assist workers affected by international trade changes, providing TRA benefits to workers who have lost jobs due to import competition, with provisions for both basic and extended benefits based on training program participation.

The Department disqualified Carter from receiving extended Trade Readjustment Allowances (TRA), asserting that these benefits apply only during periods when an individual is actively engaged in training. Carter argues she is entitled to benefits for the remaining unpaid weeks within the twenty-six-week period, citing that she left the training program with good cause. Under 19 U.S.C. § 2296(c), workers who cease training with good cause retain eligibility for TRA benefits. The circuit court interpreted this section to confirm that eligibility persists even after a worker exits training for justified reasons. The Department disagrees, contending that without reentry into a training program, Carter cannot receive extended benefits, referencing definitions in the Code of Federal Regulations that categorize a trainee as someone currently undergoing instruction.

While the Department's argument is compelling, it overlooks Congress's intent in enacting § 2296(c), which distinguishes between workers who leave training with and without good cause. This distinction suggests that those who leave with good cause can continue to receive remaining basic TRA benefits during the fifty-two-week period and that § 2296(c) applies to additional payments under the twenty-six-week period as well. Precedents affirm that workers who unjustifiably refuse training lose eligibility for supplemental benefits. Consequently, the conclusion is that a worker who withdraws from training with good cause remains eligible for extended TRA benefits. The next step is to assess whether Carter's reasons for leaving the program qualify as good cause, defined in the regulations as reasons justifying an individual's actions based on reasonable expectations in similar situations.

Good cause is defined as a reasonable, material, and substantial reason based on specific facts, as established in *Department of Industrial Relations v. Mann*. In this case, Carter sought to enroll in cosmetology or welding but was directed to the LPN program by the program administrators. She attended LPN classes for one quarter and began clinical training in the second quarter, during which she experienced significant anxiety related to patient care, rendering her unable to perform essential tasks such as administering injections or taking blood pressure. After requesting a transfer to a different training program and being denied, Carter withdrew from the LPN program after only two weeks of clinical training.

The legal precedent for determining good cause in employment cessation under Alabama law was applied to Carter's situation, drawing parallels to cases where employees left jobs due to stress or health issues. The circuit court reviewed the appeal from the Board of Appeals under a de novo standard, meaning it assessed the case independently rather than simply affirming or reversing the Board's decision. The court found the evidence undisputed, noted that Carter's clinical training caused her emotional distress, and concluded that it was reasonable for her to withdraw from the program.

Ultimately, the circuit court determined that Carter had good cause for her withdrawal from the training program, which allowed her to remain eligible for TRA benefits. The court's order was affirmed, with concurrence from other judges.