ROBERT BANZULY
Attorney for Employees

Offices in Chicago and Skokie, IL   
312-953-4268   

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In five words I can sum up everything I've learned about litigation —  Avoid it if you can!

 

Some of What Every Claimant Should Know

About Unemployment Insurance Benefits Act  

by
Alvin D. Meyers, Attorney at Law
General Practitioner and
Part-time Hearing Referee for the Illinois Department of Employment Security


To receive benefits while out of work you must look for and be able to work.

Applying for benefits

Filing an appeal

What if I was fired?

What if I quit my job?

What if I'm too sick to work?

What if I'm a temporary employee between assignments?

What is an appeal before a Hearings Referee?

How does the Appeal work?

Advice to the claimant: Think before you act; be prepared.

 

To receive benefits while out of work you must look for and be able to work

Merely being out of work or being unable to work does not entitle you to unemployment insurance benefits under the Illinois Unemployment Insurance Act (the Act).  Generally, benefits are only payable to those who are unemployed, temporarily laid-off or who were forced to quit work through no fault of their own and who are available, able to and actively seeking work.  Benefits will not be paid to those who do not want to work, who do not seek work, who are too sick to work, who have been discharged from work for misconduct or who have voluntarily left work through no fault of their employer.  1

 

 

Applying for benefits

 

You usually apply for unemployment insurance benefits (benefits) at your Local Office of the Illinois Department of Employment Security (IDES).  That office decides whether you (the "claimant") are entitled to benefits.  That decision is made by the person handling your claim, who is called the Claims Adjudicator (the "Adjudicator").  The Adjudicator decides whether benefits should be paid.  The Adjudicator makes an investigation and makes a decision based on what you and your former employer may say. 

You should be very careful the first time you speak to the Adjudicator about your case to tell the adjudicator all the important facts the first time, so no important facts are left out that have to be added later.  The idea is to be consistent and not make contradictory statements.  If you give inconsistent or contradictory statements or if you add important facts in later statements, when those statements are reviewed later they may lead the Adjudicator to believe that you have not been truthful and cause your claim to be denied.  Thus, even if the employer never objects to your claim for benefits, or even if the employer agrees that you should be paid benefits, you can, just by what you yourself say, cause your own claim to be denied.  Therefore, to be consistent think about what you will say before you say it.  Get it right the first time.

 

 

Filing an appeal.

The actual decision of the Local Office to allow or deny benefits is made in a written document, called a "Determination."  It is mailed to you and the employer.  The Determination gives a brief explanation of the reasons for the decision and says how and when an appeal from it may be made to a Hearings Referee (Referee), who is an attorney authorized to hear and decide appeals.  Only the losing party may file an appeal.  If the losing party fails to file an appeal as required by the Act, the Determination will become final and it cannot be appealed later.

The appeal must be filed within thirty (30) days of the date the Local Office makes its Determination.  That date is called the "appeal due date;" it appears on the copy of the Determination mailed to the losing party.  As an example, if you are allowed benefits, only the Determination sent to your employer (if it protested the claim) will give an appeal due date.  On the other-hand, if the Determination denies benefits, the copy of the Determination sent to you, not the one sent to your employer, will include an appeal due date.  If that date falls on a weekend or holiday, an appeal will be timely if it is filed on the next business day.  The appeal may be filed in person, by mail or by facsimile sent to the Local Office.  The instructions are on the Determination.  If you mail the appeal the date of mailing controls timeliness.  Though your appeal need only say you are appealing because the Determination is wrong, you may also give your reasons why you feel the Determination is wrong.  Except in rare cases, a Referee is without authority to hear an appeal that is filed late.  A late appeal will be dismissed. 

You should be aware that the employer has to take an additional step, besides filing the appeal on time, in order to validly appeal.  Not only must the employer file its appeal by the appeal due date, as you must do, but the employer must also file, within ten days of receiving notice of your claim for benefits, a protest or objection to the claim for benefits.  Unless both a timely, sufficient protest and a timely appeal are filed by the employer, the employer's appeal will be dismissed by the Referee.  On the other-hand, your appeal will be valid as long as it is filed on time.  The claimant has to meet only one requirement to appeal: File the appeal on or before the appeal due date. 

The most common cases appealed to Referees (but far from the only ones), involve: 1) Whether or not the claimant was discharged for misconduct under Section 602A of the Act; 2) whether or not the claimant who voluntarily left work was forced to leave by the employer under Section 601A of the Act; and 3) whether or not the claimant is available, able and actively seeking work under Section 500C of the Act. 

 

What if I was fired?

What does "misconduct" under Section 602A of the Act mean?  It means a willful and deliberate violation of an employer's known and reasonable rule or policy or of an earlier warning to an employee that harms the employer.  A few examples include tardiness, absenteeism, intoxication, the use of illegal drugs and insubordination.  Thus, besides being a violation of a known and reasonable rule, policy or a prior warning, in order to be considered misconduct under Section 602A the employee's conduct must be more than accidental or negligent.  It must be intentional, willful, or deliberate.  However, certain conduct, if proven, is considered misconduct whether or not a written rule or prior warning forbids it: If the employee's conduct is generally considered improper, it will be considered misconduct in every workplace.  Some examples are fighting, drunkenness and stealing. 

As mentioned already, since Section 602A requires an intentional, willful or deliberate violation of a reasonable rule or prior warning, not all conduct that leads to a discharge will disqualify you from receiving benefits.  This is especially true where the employer has rules that require an employee's discharge based solely on points given for certain infractions, such as for absences or tardiness.  That is sometimes referred to as a "no-fault" policy or system.  Under that policy, the employee is discharged whenever the required points are reached, regardless of why the points were given.  If the claimant can show his or her points were accumulated as a result of absences or tardiness caused by sickness, accident or medical emergencies over which the claimant had no control, the claimant may still be entitled to benefits under Section 602A of the Act.  Although a claimant may be properly discharged under a point system, unless the claimant acted deliberately, willfully, or intentionally when accumulating those points his or her right to benefits may not be affected. 

 

What if I quit my job?

The issue under Section 601A of the Act is whether an employee who voluntarily left his or her job was forced to leave by the employer.  Generally, benefits are not available to an employee who voluntarily leaves a job when work is still available.  If an employee voluntarily resigns, moves or relocates to another area the employee may not receive benefits.  Examples of when you may be entitled to benefits under Section 601A even if you leave voluntarily are: 1) The employer moves to a new location that is very difficult or almost impossible for you to get to; 2) the employer suddenly changes your shift or hours without giving you a reasonable time to get needed child-care or to arrange transportation; or 3) the employer significantly reduces your pay or hours. 

Section 601B of the Act provides some exceptions to Section 601A.  It exempts from disqualification certain situations that would otherwise cause the employee to lose benefits under Section 601A.  The exemptions under Section 601B(1) are the ones that are used most often.  Under 601B(1), if an employee voluntarily leaves work because he or she has been told to do so by a doctor either due to the employee's own health or to care for the employee's sick child, spouse or parent and, before leaving, the employee tells the employer that is why he or she is leaving, the employee will not be disqualified from receiving benefits.  Although Section 601B(1) of the Act does not specifically require it, it is a good idea for the employee to give the employer a written statement from the doctor giving both the medical reasons and the need for the employee to leave work.  You should also keep extra copies of that statement in case it is needed as proof in the future.  In most cases, if a claimant qualifies for an exemption under any subpart of Section 601B of the Act, any benefits paid to the claimant under that exemption after the claimant is able to return to work are not chargeable to the employer. 

 

What if I'm too sick to work?

The majority of appeals under Section 500C of the Act deal with whether or not, since being unemployed or for any period while being unemployed or laid off from work, a claimant: 1) Was able to work; 2) made a reasonable and realistic search for work; 3) has records to show he or she made a reasonable and realistic search for work (called a work search); and 4) is willing to accept suitable work.  To be eligible for benefits, the claimant, in all events, must be able to work.  Even if Section 601B of the Act applies to exempt a voluntary separation from disqualification under Section 601A, or even if a discharged claimant is found not to be disqualified under Section 602A, a claimant who is unable to work due to his or her health or for most any other reason will not be eligible to receive benefits under Section 500C of the Act.  You have to keep in mind, regardless of all else, that the Act only allows benefits to people who are able to and who are seeking work. 

 

What if I'm a temporary employee between assignments?

You must be actively looking for work to be eligible to get or to continue to get benefits while you are unemployed.  To comply with Section 500C of the Act, if you are applying for benefits while between assignments when working for a temporary help firm (an employer that assigns people to temporarily work at its client's locations) you should regularly contact the employer for new assignments.  Otherwise, the employer may say it could not reach you to give you a new assignment, or it had an assignment but it did not hear from you, or you were not around to take an assignment, so you were not actively looking for work.  Even if the employer says it will call you, you should regularly contact the employer so the employer will not be able to say you failed to contact it.  For that reason, when you call or contact the employer you should keep a record of each contact and the name of the person you spoke with.  Keep contacting the employer even if you are also contacting others for work.  Also, when you complete your work search for the Local Office do not forget to include, in addition to all other contacts and information, your contacts with the employer, as proof that you made those contacts. 

 

What is an appeal before a Hearings Referee?

Every claimant should have an understanding of the Referee's appeal hearing and how it is conducted.  It is not an interview.  It is not a conversation.  It is not a conference.  It is not a meeting.  It is a hearing, or, in other words, it is similar to a trial in a regular court.  It is presided over and conducted by a lawyer who is called a Hearings Referee. The Referee acts as the judge.  Most hearings are by telephone.  A special conference telephone is used so everyone can hear what each person says. It is an adversarial hearing, which means each side does whatever it legitimately can to prove its case.  Usually, no punches are pulled.

 

How does the Appeal work?

After a party files an appeal of a Determination, a written notice setting the date and time for the appeal hearing is mailed to the employer and the claimant by the IDES.  Continuances are rare and given only for special circumstances, such as a death in the immediate family, a medical emergency, a job interview or a failure to receive a timely notice of the hearing.  Each side has an opportunity to present its proof and contest the proof of the other side through sworn testimony and the presentation of documents. 

The Referee is required to make his or her decision based on reliable testimony and documents admitted into evidence at the hearing.  The Referee will not consider facts, testimony, or documents not presented or given at the time of the hearing.  To do otherwise would prevent the other side from contesting them or arguing against their admissibility.  Therefore, the Referee cannot discuss the facts of a case separately with either party before the hearing.  To do so might give the other side an advantage.  Before the hearing, the Referee may only discuss procedural questions with one side.  Procedural questions include a request for a continuance, a request to review the file, a request to appear in person or to give the Referee the names and telephone numbers of witnesses to be called for the hearing.  You should not be upset if the Referee refuses to discuss non-procedural matters with you when the other side is not on the telephone.  You should understand that when the Referee says he or she cannot discuss certain matters with you that the Referee is trying to keep the hearing as fair as possible. 

Both sides, the claimant and the employer, are entitled to have an attorney or other representative assist them in the hearing.  A representative need not be an attorney.  Employers frequently use what are called "Service Companies," companies that specialize in unemployment matters, to assist them to respond to claims, to deal with the Local Office and to handle appeals.  A Service Company may also contact the employer's witnesses, arrange for their testimony and help present the employer's evidence and arguments to the Referee.

The Referee will open the hearing by briefly explaining how the proceedings will be conducted.  It is tape-recorded by the Referee; no one else may record the hearing.  What is said in the hearing is strictly confidential and may only be used for that hearing and in appeals of that hearing.  Testimony given at the hearing cannot be used in any other case, trial or proceeding and will not be made available for use in any other case, trial or proceeding.  After all the witnesses are sworn to tell the truth, the Referee will ask each witness questions and then the witness may add additional facts.  Next, the other side, if it wishes, may cross-examine the witness to test the witness' truthfulness and memory.  Cross-examination means asking the witness questions, not making statements of your own.  After cross-examination, the witness is given a chance to explain his or her answers that were given while under cross-examination.  Each witness for each side will testify in turn so each side has a chance to present its case. 

One problem claimants face that employers usually do not have is that claimants usually have no witnesses to support their position.  That should not be surprising since most factual witnesses are still working for the employer when the appeal is heard.  Witnesses who are still working for the employer will not want to testify against their employer.  They fear they will be fired.  As a practical matter, it usually is not done.  Before you can count on the testimony of any witness who is still working for the employer you should talk to that person to determine whether he or she will actually testify against the employer and, if so, what the witness will say.  You should not put on any witness who will not help your case.  Additionally, although the Referee may in certain cases issue a subpoena to compel a witness to testify, a witness who is forced to testify against his or her own employer will usually not be helpful.  You should also be aware that the one who causes the subpoena to be issued must also serve it on the witness. The Referee will not serve it. 

During the initial or direct testimony of a witness the other side may not interrupt or speak except to make an objection.  Objections are mainly evidentiary.  They usually only go to the nature of the question.  As examples, objections may be made to questions that require conclusions, that attempt to or do elicit hearsay or that lack a proper foundation.  You cannot object to a question or an answer merely because you disagree with it if it is otherwise proper.  Even if a witness says you made a particular statement that you know you did not make, you may still not object to that statement.  An objection that goes only to whether the answer is true or false is not proper.

The rules of evidence used at regular trials determine, under the court's direction, what testimony and records may be properly presented during the trial.  Though very similar to the rules used in regular trials, less rigorous rules of evidence and procedure apply before Referees.  For example, hearsay evidence is allowed at the hearing although not allowed at a regular trial.  However, though allowed, hearsay is not treated the same as evidence that is not hearsay.  Simply put, hearsay evidence is the statement of one person about what another person said.  An affidavit, even if notarized, from a person who does not appear and testify under oath at the hearing may be hearsay also.  Direct, sworn testimony of a firsthand witness who is available for cross-examination by the other side is the strongest evidence.  The witness who testifies at the hearing does so under oath and is subject to cross-examination. 

Cross-examination of a witness is a fundamental and important right.  The right to cross-examine a witness is the right to ask a witness, after the completion of his or her direct testimony, questions about what he or she just said.  It can have several purposes.  It may show that the witness lacks firsthand knowledge about the facts, that the witness made contradictory statements at other times or that the witness is not credible so his or her testimony should not be believed.  Cross-examination is not the time for the examiner to make a statement, to offer contradictory facts or to argue with the witness.  (Contradictory testimony or evidence should be presented when you put on your own case before the Referee.)  Although the cross-examiner may not like the answers a witness may give, the examiner may still not make a direct response to them during cross-examination.  An unfavorable or unexpected answer to a question you ask is the price you may pay for asking the question.  Unless you know what the answer will be, you must always consider whether to ask the question and risk getting a bad answer. 

After all the testimony is presented at the hearing, each side is given a chance to make a closing argument.  Through a closing argument you may summarize the facts already in evidence and argue how those facts support your position.  New facts may not be presented in a closing argument.  If you fail to present relevant facts during the hearing, you may not present them for the first time in your closing argument.  Closing arguments are not evidence, they are not required and they may be waived. 

 

Advice to the claimant: Think before you act; be prepared.

You should keep the following suggestions in mind at all times.  To avoid appearing untruthful, you must always do what you promise to do.  Thus, if you told the Local Office you will bring in a medical statement or any other item and you fail to do so, your truthfulness or credibility will be affected.  Furthermore, any papers or records that you want to use at the hearing that are not already in the file should be produced before the hearing to the Referee and the other side or they cannot be used in the hearing. The Rules and the Notice for Hearing state that.  Additionally, do not assume that any of the documents you previously gave the employer that might help you in your claim for benefits, such as your doctor's statement or hospital bill, will be automatically included in submissions the employer makes to the Local Office or the Referee.  Because the proceeding is adversarial, the employer usually will not submit anything that is helpful to you.  To make sure that the Local Office or the Referee gets the documents you want them to have, you should submit them yourself.  Finally, you should not wait until the telephone hearing has begun to first start thinking about the case, what documents to use in the hearing or how and when to get them to the Referee and the other side.  Your statements during the telephone hearing such as: "I have the bill in front of me;" "I'll have to look for it;" "I gave my only copy of it to the employer;" "my doctor has it;" "I lost it;" or, "I can get it if I had time," will not help you.  In fact, they may hurt you.  They show either that the documents do not exist or, if they do exist, they would not help you.  It is the duty of both parties to be prepared to proceed when the hearing begins.  You cannot wait until the Referee calls to begin thinking about the case. If you do, it will be too late.


1 The Illinois Department of Employment Security has contracted with certain law firms to provide limited free legal services to qualified claimants and small employers.  A claimant may contact one of these firms to see if he or she qualifies for free legal services or, even if not qualified, to discuss their case with an attorney.  Claimants may call the following numbers: In Illinois, 1-800-884-6591; out of state, 1-618-235-6008; TDD, 1-800-884-6597.


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