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Eaton v. Arch Telecom, Inc.

Supreme Court of Delaware

April 24, 2018

CHAVEZ EATON, Appellant Below, Appellant,

          Submitted: March 9, 2018

          Court Below-Superior Court of the State of Delaware C.A. No. K17A-02-002

          Before STRINE, Chief Justice, VALIHURA, and VAUGHN, Justices.



         This 24th day of April 2018 upon consideration of the appellant's opening brief and the record below, [1] it appears to the Court that:

         (1) The appellant, Chavez Eaton, filed this appeal from the Superior Court's November 14, 2017 order affirming the February 2, 2017 decision of the UIAB.[2] We find no merit to the appeal. Accordingly, we affirm.

         (2) Eaton worked as a sales associate for ArchTelecom from July 9, 2015 to October 26, 2016. He received multiple write-ups for various workplace issues, including violation of the dress code and failure to follow company policies. On October 10, 2016, ArchTelecom issued Eaton a final warning. The final warning identified multiple issues with Eaton's work performance, including cash handling errors, unauthorized breaks, failure to meet key performance metrics, and dress code violations. Eaton was warned that he would be terminated in the event of any similar infractions. He was also informed that his metrics and performance would be monitored.

         (3) On October 22, 2016, Eaton was suspended. On October 26, 2016, Eaton was terminated. The termination notice stated that Eaton had continued to take unauthorized breaks, harassed a co-worker after he was told to stop, and failed to meet the requirements of the performance improvement plan in the final warning.

         (4) Eaton filed a claim for unemployment benefits with the Division of Unemployment Insurance. On November 14, 2016, a claims deputy concluded that Eaton was disqualified from receiving unemployment benefits because he was discharged for willful or wanton misconduct. Eaton timely filed a notice of appeal.

         (5) On December 12, 2016, there was a hearing before an appeals referee. The appeals referee heard testimony from Eaton and an ArchTelecom representative. On December 12, 2016, the appeals referee issued her decision affirming the decision of the claims deputy. The appeals referee found that ArchTelecom warned Eaton further infractions would result in termination, there were further infractions by Eaton, and Eaton was terminated for just cause. Eaton timely appealed the decision of the appeals referee.

         (6) The UIAB heard Eaton's appeal on January 11, 2017. Eaton and an ArchTelecom representative testified at the hearing. On February 2, 2017, the UIAB issued its decision affirming the decision of the appeals referee. The UIAB concluded that ArchTelecom gave Eaton a final warning that certain conduct, including the taking of unauthorized breaks, would result in termination, Eaton subsequently took unauthorized breaks and was found to have harassed a co-worker by repeatedly asking her if she had reported his unauthorized breaks to management, and Eaton was discharged for just cause. Eaton timely appealed the UIAB's decision to the Superior Court.

         (7) On appeal to the Superior Court, Eaton argued that the final warning could not be unambiguous because it identified six different issues with his performance. He also argued that his metrics and performance were not monitored as provided for in the final warning. The Superior Court found that the final warning was unambiguous and that there was substantial evidence supporting the UIAB's determination that Eaton received adequate notice, his neglect of his duties was willful and wanton, and he was terminated for just cause.[3] The Superior Court affirmed the UIAB's decision.[4] This appeal followed.

         (8) This Court's review of an appeal from the UIAB to the Superior Court is limited to a determination of whether there is substantial evidence in the record to support the UIAB's findings and whether such findings are free from legal error.[5]Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.[6] Like the Superior Court, this Court considers the record in the light most favorable to the party prevailing on the UIAB appeal.[7] We do not weigh the evidence, determine questions or credibility, or make our own factual findings.[8]

         (9) An employee who is discharged for just cause is disqualified from receiving unemployment benefits.[9] Generally, there is just cause if an employee commits a "willful or wanton act or pattern of conduct in violation of the employer's interest, the employee's duties, or the employee's expected standard of conduct."[10]"If an employer consistently tolerates willful or wanton misconduct, however, the employer may not be justified in firing employees without first warning them that their conduct no longer is acceptable."[11] ...

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