Aldana-Chiles v. Florida Unemployment Appeals Comm'n

Citations: 930 So. 2d 808; 2006 Fla. App. LEXIS 8533; 2006 WL 1479598Docket: No. 3D05-1441

Court: District Court of Appeal of Florida; May 31, 2006; Florida; State Appellate Court

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Juliette Aldana-Chiles appeals the Unemployment Appeals Commission's (UAC) May 19, 2005 order disqualifying her from unemployment benefits. The court reverses this decision. Chiles worked for Behavioral Science Research Corporation (BSRC) from 1989 until October 29, 2004, with varying responsibilities and hours based on her needs and the company's ability to employ her. She started as an hourly employee, became a full-time employee in 1995, and was promoted to Director of Field Services in 1996, later assuming office manager duties. After finding the dual roles overwhelming, she negotiated a reduction in responsibilities and took medical leave in 2001 due to stress. Chiles returned to full-time work in October 2001, requested part-time status in August 2003 due to workload and pay issues, and took a vacation in September 2003. Upon her return, she resumed full-time work. Following the unexpected death of the office manager in August 2004, Chiles again struggled with dual roles and requested to scale back her responsibilities. After notifying her supervisor, Robert Ladner, of her desire to work part-time starting January 2005, Chiles returned from a scheduled vacation on October 29, 2004, only to be handed a letter accepting her resignation and instructing her to leave immediately. Ladner agreed to pay her until December 31, 2004, which he claimed was her resignation date. Chiles applied for unemployment benefits on January 2, 2005, but a claims examiner initially denied her application, asserting she had quit without good cause. Chiles appealed, and during the hearing, the appeals referee concluded she was discharged for reasons unrelated to work misconduct, making her eligible for benefits under Florida law.

The UAC reversed the referee’s decision regarding Chiles’ employment status, prompting Chiles to seek redress. Under Section 120.57(1)(Z) of the Florida Statutes, an agency must provide specific reasons for rejecting or modifying a conclusion of law or interpretation of an administrative rule, and must demonstrate that its new conclusion is as or more reasonable than the one modified. The agency cannot reject findings of fact unless it determines they are not based on competent substantial evidence. The excerpt emphasizes that the UAC failed to meet the particularity requirement in its review and decision-making process.

Chiles consistently communicated her desire to transition from full-time to part-time work, asserting she never indicated a resignation. Testimonies indicated she would remain in her position until the end of 2004 while expressing a willingness to work part-time thereafter. The UAC, however, made findings that contradicted the referee’s conclusions, claiming Chiles announced her resignation and intent to work part-time only after resigning. 

The referee found Chiles’ testimony more credible than Ladner’s and ultimately concluded that Chiles was not resigning but was instead requesting to shift to part-time work. The UAC’s order, which simply stated that the referee's decision was unsupported by the record, was deemed insufficient. In light of the evidence presented, the court reversed the UAC's order and remanded the case for the reinstatement of the referee's decision, affirming that Chiles' actions did not constitute a resignation but rather a request for part-time employment.