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Tuff v. Knitcraft Corp.

Supreme Court of Minnesota
Jan 6, 1995
526 N.W.2d 50 (Minn. 1995)

Summary

holding that appellate court will uphold findings by commissioner's representative if reasonably supported by the evidence

Summary of this case from Christensen v. Visual Edge

Opinion

No. C8-94-564.

January 6, 1995.

Appeal from the Court of Appeals, Harvey A. Holtan, Acting, J.

Kent E. Todd, Dept. of Economic Security, St. Paul, for relator.

Ernest Tuff, pro se.

Considered and decided by the court en banc without oral argument.


OPINION


In this claim for unemployment compensation benefits, the referee authorized Ernest Tuff to receive benefits; she found that Tuff had requested a medical leave of absence and thought he had been granted that leave, and that his employer discharged Tuff because of a miscommunication as to the allowable time off. The commissioner's representative reversed the referee and concluded that Tuff had committed disqualifying misconduct by taking an extended leave of absence without notifying his employer. The court of appeals reversed, holding that the commissioner's representative was required to specify the reasons for rejecting the referee's findings of fact. We granted the commissioner's petition for further review for the sole purpose of clarifying the standard of review on certiorari to the court of appeals. We reverse.

The court of appeals, citing Semanko v. Department of Employment Servs., 309 Minn. 425, 428, 244 N.W.2d 663, 665 (1976), acknowledged that its task on appeal is to review the findings of the commissioner or the commissioner's representative, not those of the referee, even though those findings might involve witness credibility. Nevertheless, it then imposed a burden on the commissioner's representative to demonstrate the basis for rejecting the referee's credibility determination. In addition, the court required the commissioner's representative on remand to address the applicability of the serious illness exception contained in Minn.Stat. § 268.09, subd. 1(c)(2) (Supp. 1993) — an exception held applicable by the referee and rejected without explanation by the commissioner's representative. Tuff v. Knitcraft Corp., 520 N.W.2d 483 (Minn.App. 1994).

Minn.Stat. § 268.10, subd. 5 (1992) authorizes the commissioner or the commissioner's representative to "affirm, modify or set aside any finding of fact or decision, or both, of the referee on the basis of the evidence previously submitted * * *." Specifically, the commissioner is statutorily authorized to:

[D]isregard the findings of fact of the referee and examine the testimony taken and make any findings of fact as the evidence taken before the referee may, in the judgment of the commissioner, require, and make any decision as the facts found by the commissioner require.

Minn.Stat. § 268.12, subd. 13(3) (1992). This court has long accorded particular deference to the commissioner rather than to the referee. In Chellson v. Division of Employment and Sec., 214 Minn. 332, 8 N.W.2d 42 (1943), we held that the applicable standard of review is "whether there is reasonable support in the evidence to sustain the decision of the director [now commissioner] rather than the decision of the appeal tribunal [now referee]." 214 Minn. at 335, 8 N.W.2d at 44; White v. Metropolitan Medical Ctr., 332 N.W.2d 25 (Minn. 1983).

Because the decision of the court of appeals imposes a burden inconsistent with the statute and with our previous decisions, we reverse. We reinstate the decision of the commissioner's representative that relator Tuff was discharged from his employment for misconduct and that he is accordingly disqualified from the receipt of unemployment benefits. Minn.Stat. § 268.09, subd. 1(b) (1992). Tilseth v. Midwest Lumber Co., 295 Minn. 372, 204 N.W.2d 644 (1973).

Reversed.


Summaries of

Tuff v. Knitcraft Corp.

Supreme Court of Minnesota
Jan 6, 1995
526 N.W.2d 50 (Minn. 1995)

holding that appellate court will uphold findings by commissioner's representative if reasonably supported by the evidence

Summary of this case from Christensen v. Visual Edge

holding that the courts will accord deference to the commissioner rather than to the referee and that the commissioner may make independent factual determinations and decisions

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holding court defers to representative's findings even when findings involve witness credibility

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concluding that we will not disturb the commissioner's representative's decision if it is has reasonable support in the record

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concluding court gives deference to findings of commissioner's representative even though findings may involve witness credibility

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addressing earlier version of applicable statute

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applying predecessor statute to decision by "representative of the commissioner," now referred to as "senior unemployment review judge"

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reviewing decision of commissioner's representative

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noting that when witness credibility and conflicting evidence are at issue, this court defers to the ability of the commissioner's representative to weigh evidence and make credibility determinations

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identifying review standard as whether evidence reasonably supports commissioner's decision

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reaffirming that appellate courts review findings of the commissioner's representative, not the unemployment law judge

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In Tuff, the Minnesota Supreme Court ruled that the commissioner's representative need not give any weight to an unemployment law judge's credibility determinations.

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reaffirming that appellate courts review findings of commissioner or commissioner's representative, not unemployment law judge

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noting that the appellate court refers to the commissioner's representative's findings of credibility, not the unemployment law judge

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In Tuff v. Knitcraft Corp., 526 N.W.2d 50, 51-52 (Minn. 1995), an employee's failure to return from medical leave resulted in a discharge for misconduct. The facts of this case call for a similar result.

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In Tuff v. Knitcraft, 526 N.W.2d 50, 51-52 (Minn. 1995), the Minnesota Supreme Court reaffirmed that the commissioner's representative is free to weigh the evidence independently of the reemployment insurance judge.

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reiterating that the task of this court is to review the findings of the Commissioner or its representative, not those of the referee, even though those findings might involve witness credibility

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Case details for

Tuff v. Knitcraft Corp.

Case Details

Full title:Ernest TUFF, Respondent, v. KNITCRAFT CORP., Respondent, Commissioner of…

Court:Supreme Court of Minnesota

Date published: Jan 6, 1995

Citations

526 N.W.2d 50 (Minn. 1995)

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Akopi v. Commr. of Economic Security

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