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J. Snak v. UCBR

Citation: Not availableDocket: 1034 C.D. 2021

Court: Commonwealth Court of Pennsylvania; August 5, 2022; Pennsylvania; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

The case involves a claimant seeking review of an Unemployment Compensation Board of Review decision that denied his unemployment benefits for the week ending February 6, 2021, under his second application. Initially, the claimant was deemed eligible for benefits under his first application, with a benefit year from February 16, 2020, to February 13, 2021, at a weekly rate of $572. A subsequent application resulted in a new benefit year starting February 14, 2021, with a weekly rate of $583. However, a system error led to benefits being paid for the week ending February 6, 2021, under the second application, which was outside its effective date. The claimant appealed after the Scranton UC Service Center and a referee upheld the denial, with the referee clarifying the inapplicability of the second application for that week. The Board affirmed the referee’s decision, modifying it to address an $11 non-fault overpayment due to the error, subject to recoupment. Represented by counsel, the claimant contested the ruling, asserting no fault in filing and seeking the overpayment's removal. The court reviewed for constitutional and procedural errors, confirming the Board's decision, emphasizing the non-fault nature of the overpayment and proper application under the first benefit year.

Legal Issues Addressed

Application Validity Under Unemployment Compensation Law

Application: The claimant's application for the week ending February 6, 2021, was considered valid under the first benefit year application, as there was no evidence of improper filing or fault by the claimant.

Reasoning: Claimant's application for Unemployment Compensation (UC) benefits for the week ending February 6, 2021, was deemed valid, as there was no evidence of improper filing or fault on his part.

Eligibility for Unemployment Compensation Benefits

Application: The court affirmed the Board's decision that the claimant's application for benefits for the week ending February 6, 2021, was invalid under the second benefit year application as it fell within the previous benefit year.

Reasoning: The Board determined that this week fell within Claimant's previous benefit year, rendering his application for that week invalid under Section 401(c) of the Law.

Non-Fault Overpayment and Recoupment

Application: The Board identified a non-fault overpayment of $11, which was subject to recoupment from future benefits due to a system error, rather than immediate repayment by the claimant.

Reasoning: The Board determined that Snak had received a non-fault overpayment of $11 due to a system error and that this amount was subject to recoupment.

Review Standards for Unemployment Compensation Decisions

Application: The court reviewed the Board's decision for constitutional violations, procedural errors, and substantial evidence, ultimately affirming the Board's decision.

Reasoning: The Court reviews such orders for constitutional violations, procedural errors, and substantial evidence supporting the decision.