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Tarr v. Florida Unemployment Appeals Commission

Citations: 651 So. 2d 1246; 1995 Fla. App. LEXIS 2385; 1995 WL 96820Docket: No. 94-01679

Court: District Court of Appeal of Florida; March 9, 1995; Florida; State Appellate Court

Narrative Opinion Summary

The case concerns an appeal by an individual against a Florida Unemployment Appeals Commission (UAC) order that reversed a decision by an appeals referee granting him unemployment benefits. The appellant had resigned from his position at Elreha Photogene Corporation, citing a lack of necessary training and support for his role as an Environmental Protection Agency (EPA) liaison, which led to fears of personal liability for potential EPA violations. The appeals referee initially found the resignation to be for good cause attributable to the employer. However, the UAC disagreed, arguing that the decision was unsupported by substantial evidence. The court, referencing relevant precedents, found that the referee’s decision was indeed supported by substantial evidence and that the UAC had improperly overturned it. The court ruled that the resignation constituted a good cause, reversed the UAC's order, and remanded the case with instructions to approve the appellant's unemployment compensation application, subject to other qualifications. The decision was rendered unanimously by the judges.

Legal Issues Addressed

Factual Determination in Voluntary Resignation Cases

Application: The determination of whether an employee's resignation is voluntary involves a factual analysis, and the court found that the UAC improperly overturned the appeals referee's decision based on substantial evidence.

Reasoning: The court emphasized that the determination of voluntary resignation is a factual question, and the UAC improperly overturned the referee's decision, which was backed by substantial evidence.

Good Cause for Resignation under Unemployment Compensation Law

Application: The court found that an employee's resignation due to the employer's failure to provide promised training and support, resulting in fear of personal liability, constitutes good cause attributable to the employer.

Reasoning: The appeals referee determined that Tarr had resigned for good cause attributable to his employer, Elreha Photogene Corporation (Elreha), after expressing concerns about his responsibilities as an Environmental Protection Agency (EPA) liaison without proper training or support.

Substantial Evidence in Administrative Decisions

Application: The court held that the Unemployment Appeals Commission erred in reversing the appeals referee's decision, as it was supported by substantial evidence regarding the employee's resignation circumstances.

Reasoning: The UAC found the referee's decision unsupported by substantial evidence, but the court disagreed, citing precedents that support claims when an employee leaves due to unmet training promises or fears of liability.