Hodge v. U.S. Security Associates, Inc.

Carnice Hodge brought an action to appeal the Unemployment Insurance Agency’s determination that she was disqualified from receiving unemployment benefits under a section under the Michigan Employment Security Act (MESA) that disallows benefits for individuals discharged for work-related misconduct, after respondent U.S. Security Associates, Inc., terminated her employment as a security guard at Detroit Metropolitan Wayne County Airport. Hodge was fired for accessing publicly available flight departure information on a computer near her post at the request of a traveler in violation of respondent’s policy regarding the unauthorized use of client equipment. An administrative law judge affirmed the denial of benefits, as did the Michigan Compensation Appellate Commission (MCAC), but the Wayne Circuit Court reversed. The Court of Appeals granted the employer's application for leave to appeal and affirmed, holding that the circuit court had not erred by concluding as a matter of law that claimant’s behavior was a good-faith error in judgment rather than misconduct. After review, the Supreme Court reversed, finding that the circuit and appellate courts applied an incorrect standard of review by substituting their own assessment of the seriousness of Hodge's conduct for the assessment of the MCAC. Accordingly, the Supreme Court reversed the Court of Appeals and reinstated the MCAC's judgment. View "Hodge v. U.S. Security Associates, Inc." on Justia Law