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Barno v. Dir., Ohio Dept. of Job & Family Servs.

Ohio Ct. App.March 29, 2018No. 105933Cited 2 times
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Case Details

Judge(s)
Blackmon, Boyle, Keough
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
appeal

Related Laws

No specific laws identified for this ruling.

Claim Types

Wage TheftWrongful Termination

Outcome

The appellate court reversed the trial court's decision upholding the denial of unemployment benefits and remanded the case, finding the UCRC's decision was against the manifest weight of the evidence regarding whether Barno quit for just cause.

Excerpt

Unemployment compensation just cause to quit failure to pay as promised. UCRC's decision finding no just cause to quit and disallowing employee's unemployment compensation benefits was against the manifest weight of the evidence. Hearing officer's decision improperly found that employee's failure to quit "immediately" and failure to notify anyone other than his immediate supervisor of workplace issues did not amount to just cause to quit. Furthermore, hearing officer improperly concluded that the employer's failure to address the employee's concerns was reasonable just cause to quit, under unemployment compensation law, focuses on the conduct of the employee, not the employer.

What This Ruling Means

# Barno v. Ohio Department of Job & Family Services ## What Happened Barno worked for Great Lakes Water Treatment, Inc. and quit his job because the company failed to pay him what was promised. He applied for unemployment benefits, but the state denied his claim, saying he didn't have a valid reason to quit. The state argued he should have complained to someone other than his supervisor and should have quit immediately rather than waiting. ## The Court's Decision An appellate court disagreed with the state's decision and sent the case back for reconsideration. The court found that Barno did have just cause to quit because his employer failed to pay him as promised. The court ruled the hearing officer was wrong to require Barno to complain through multiple channels or quit instantly. ## Why This Matters for Workers This ruling clarifies that employees can quit and still qualify for unemployment benefits when employers don't pay them correctly. You don't have to follow a perfect complaint procedure or resign on the spot to have a legitimate reason for leaving. If an employer breaks pay promises, quitting can be justified.

This summary was generated to explain the ruling in plain English and is not legal advice.

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