Procito v. Unemployment Compensation Board of Review

DISSENTING OPINION BY

Judge FRIEDMAN.

I respectfully dissent. The majority holds that: (1) the Unemployment Compensation Board of Review (UCBR) did not err in refusing to remand this case for additional evidence relating to the circumstances under which Joan Procito’s (Claimant) domestic partner left her employment and moved to Florida because the “following spouse doctrine” does not apply to unmarried same-sex couples;1 (2) assuming that the “following spouse doctrine” does apply, Claimant would be ineligible for benefits because Claimant failed to prove that her domestic partner’s decision to leave her employment and move to Florida was caused by circumstances beyond her control; and (3) because Claimant did not meet that burden, it is not necessary to determine whether the UCBR’s failure to apply the “following spouse doctrine” to Claimant’s same-sex family violated Claimant’s equal protection rights. (Majority op. at 260.) For the following reasons, I cannot agree.

I.Refusal to Remand

In this case, the UCBR, which adopted the determination of the referee, made only four findings of fact.

1. The claimant worked from July 11, 2005 through July 31, 2006, as a full-time Financial Manager for Cushman & Wakefield of Pennsylvania, Inc. The claimant earned $66.00 an hour.
2. The claimant voluntarily resigned her position to follow her domestic partner to Florida.
3. The claimant’s domestic partner relocated to Florida in order to be near her son, who has a learning disability.
4. The claimant resigned her position and relocated to Florida because she was not financially able to maintain two separate households in two states.

(Findings of Fact, Nos. 1-4.) Based on these four findings, the UCBR then determined that Claimant was ineligible for benefits under section 402(b) of the Unemployment Compensation Law (Law)2 because, “unfortunately,”3 unless Claimant is legally married to her domestic partner, she cannot prove a necessitous and compelling reason for leaving her employment. (Referee’s op. at 2); see Kurtz v. Unemployment Compensation Board of Review, 101 Pa.Cmwlth. 299, 516 A.2d 410 (1986) (holding that the “following spouse doc*271trine” does not apply to an unmarried heterosexual couple because, until there is a marriage, there is no family unit), appeal denied, 516 Pa. 644, 533 A.2d 715 (1987); see also Nimitz v. Unemployment Compensation Board of Review, 699 A.2d 822 (Pa.Cmwlth.1997) (relying on Kurtz to hold that the “following spouse doctrine” does not apply to an unmarried heterosexual couple with children).

The majority agrees that the “following spouse doctrine” does not apply to unmarried couples, but, in order to avoid addressing the constitutional question raised by Claimant on appeal, the majority actually applies the doctrine in this case.4 The majority’s conclusion is that Claimant failed to prove that her domestic partner left her job and moved to Florida due to circumstances beyond her control. However, Claimant attempted to present evidence on that very issue, but the referee would not allow it, believing that the “following spouse doctrine” did not apply and that the circumstances of her partner’s separation were irrelevant.5 It is a clear violation of Claimant’s due process rights for the majority to apply the “following spouse doctrine” on appeal when the referee would not allow Claimant a full and fair opportunity to be heard on the matter.

Moreover, the majority’s conclusion, i.e., that Claimant failed to meet her burden of proving that her domestic partner quit due to circumstances beyond her control, is based on testimony that the UCBR never used to formulate a finding of fact.6 Within this court’s limited scope of review, this court may examine testimony to determine whether findings of fact are supported by substantial evidence, but this court may not examine testimony for the purpose of making findings of fact. See Platz v. Unemployment Compensation Board of Review, 709 A.2d 450 (Pa.Cmwlth.) (stating that the exclusive role of fact-finder belongs to the UCBR), appeal denied, 556 Pa. 699, 727 A.2d 1125 (1998); section 704 of the Administrative Agency Law, 2 Pa. C.S. § 704. Thus, in my view, the majority cannot avoid the constitutional issues by applying the “following spouse doctrine.”

II. Necessitous and Compelling Cause

A cause of necessitous and compelling nature exists where real and substantial circumstances force a claimant to terminate her employment and would compel a reasonable person to act in the same man*272ner. Beachem v. Unemployment Compensation Board of Review, 760 A.2d 68 (Pa.Cmwlth.2000). If a claimant leaves employment when compelled to do so by family obligations, the claimant is entitled to benefits. Id.

A. “Following Spouse Doctrine”

Where a claimant leaves work to accompany a spouse to a new locality, the following spouse is entitled to benefits if he or she shows that: (1) there was an economic hardship in maintaining two residences or that the move caused an insurmountable commuting problem; and (2) the spouse’s relocation was caused by circumstances beyond the control of the spouse and was not brought about by purely personal preference. Wheeler v. Unemployment Compensation Board of Review, 69 Pa.Cmwlth. 201, 450 A.2d 775 (1982).

The “following spouse doctrine” does not apply to unmarried heterosexual couples because there can be no family unit absent a marriage, even where a child is involved. Kurtz; Nimitz. In other words, the only type of heterosexual family unit recognized by this court for purposes of the “following spouse doctrine” is one within the bounds of marriage.7 To be clear, this court believes that unmarried heterosexual couples with children, who live together and support one another like families, are not really “families.” Thus, whenever this court discusses preservation of the family unit in “following spouse doctrine” cases, this court really is talking about preservation of the marriage.

While preservation of the family unit [i.e., marriage,] does not, in and of itself, give rise to necessitous and compelling reason ... we are not indifferent to its social desirability. Moreover, in the absence of statutory language mandating such application, we are disinclined to interpret the Law in a way which tends to be disruptive to family [i.e., marital,] unity.

Stevens v. Unemployment Compensation Board of Review, 81 Pa.Cmwlth. 239, 473 A.2d 254, 257 (1984) (citation omitted) (awarding benefits because, although the marriage ultimately failed, the claimant made a good faith effort to keep the family/marriage together).

Clearly, then, heterosexuals who have chosen to raise a family outside the bounds of marriage are not entitled to benefits under the “following spouse doctrine.” Nimitz. However, this case is not about a heterosexual couple that made such a choice. This case is about a same-sex couple who would choose to raise a family within the bounds of marriage but may not legally do so. Whether this court should apply the “following spouse doctrine” to same-sex families, where marriage is not an option, is a question of first impression.

B. No Specific Exclusion

In 1953, section 402(b) of the Law specifically excluded necessitous and compelling cause claims based on marital, filial and domestic circumstances; however, that exclusion was repealed in 1955. See Pittsburgh Pipe and Coupling Company v. Unemployment Compensation Board of Review, 401 Pa. 501, 165 A.2d 374 (1960). Recognizing the repeal of the statutory exclusion, our supreme court stated:

In determining whether ... facts exist [of a necessitous and compelling reason for leaving employment based on mari*273tal, filial or domestic circumstances], the test is not whether the claimant has taken himself out of the scope of the [Law], but whether the [Law] specifically excludes him from its provisions. That is what is meant by a liberal and broad construction.

Id. at 509, 165 A.2d at 378 (emphasis added). In other words, if the legislature intended to exclude a specific necessitous and compelling cause claim, the legislature knew how to place the exclusion in the Law.

Section 402(b) of the Law no longer specifically excludes necessitous and compelling cause claims based on marital, filial or domestic circumstances. Thus, any type of necessitous and compelling cause claim based on domestic circumstances is permitted, even a claim based on the domestic circumstances of same-sex families. The “following spouse doctrine” is a type of necessitous and compelling cause claim based on marital and/or domestic circumstances. Because the statute does not limit such claims, the courts cannot limit such claims. Id.

C. In Loco Parentis

Our supreme court has stated that the rights and liabilities arising out of an in loco parentis relationship are exactly the same as between parent and child. T.B. v. L.R.M., 567 Pa. 222, 786 A.2d 913 (2001). The phrase in loco parentis refers to a person who puts himself or herself in the situation of a lawful parent by assuming the obligations incident to the parental relationship without going through the formality of a legal adoption.8 Id. In Pennsylvania, a same-sex domestic partner may seek partial custody of a child based on the doctrine of in loco parentis. Id. This is based on the fact that a child may establish strong psychological bonds with an individual who, although not a biological parent, has lived with the child and provided care, nurture and affection to the child, assuming in the child’s eyes a stature like that of a parent. Id. Thus, in every case, the paramount consideration is the best interests of the child. Id.

Inasmuch as our supreme court has recognized the bonds that unite same-sex families, even without the benefit of legal marriage, it would be absurd to suggest that same-sex families do not experience the same real and substantial pressure that traditional families experience when one parent must relocate due to circumstances beyond his or her control. Here, Claimant presented evidence indicating that her domestic partner has “sons,” not just the special needs son attending college, and that Claimant has been “an integral part of the raising of [those] sons.”9 (O.R., Item No. 5, ex. 3.) Thus, although Claimant cannot be legally married to her domestic partner, I would consider Claimant’s family to be a real family and apply the “following spouse doctrine” in this case.10

*274III. Equal Protection

In my view, the UCBR’s failure to apply the “following spouse doctrine” because Claimant is not married to her domestic partner violates Claimant’s equal protection rights. The essence of equal protection under the law is that like persons in like circumstances will be treated similarly. Curtis v. Kline, 542 Pa. 249, 666 A.2d 265 (1995). Of course, the right to equal protection does not absolutely prohibit the classification of individuals for the purpose of receiving different treatment, provided that the classification is reasonable rather than arbitrary, i.e., the classification must rest upon some ground of difference that justifies the classification. Id.

In Wallace v. Unemployment Compensation Board of Review, 38 Pa.Cmwlth. 342, 393 A.2d 43 (1978), this court held that the exclusion of necessitous and compelling cause claims based on marital, filial or domestic, i.e., family, circumstances violates equal protection rights. Likewise, here, the exclusion of a necessitous and compelling cause claim under the “following spouse doctrine” based on Claimant’s marital status violates her equal protection rights.

The UCBR contends that, although section 402(b) of the Law does not classify claimants based on their marital status for purposes of a necessitous and compelling cause claim, courts may do so under the “following spouse doctrine” in order to protect the limited assets of the unemployment compensation fund. (See majority op. at 7.) However, in Wallace, this court rejected the same argument as patently arbitrary. See Wallace. To reiterate, the pressures that create necessitous and compelling cause under the “following spouse doctrine” are real and substantial whether the claimant is married or not. There is simply no difference that would justify dissimilar treatment.

Accordingly, I would vacate and remand for further proceedings and, ultimately, application of the “following spouse doctrine.”

.Under the "following spouse doctrine,” where a claimant leaves work to accompany a spouse to a new locality, the following spouse must show an economic hardship in maintaining two residences or that the move has caused an insurmountable commuting problem. Wheeler v. Unemployment Compensation Board of Review, 69 Pa.Cmwlth. 201, 450 A.2d 775 (1982). The following spouse also must show that the spouse's relocation was caused by circumstances beyond the control of the spouse and was not brought about by purely personal preference. Id.

. Act of December 5, 1936, Second Ex.Sess., P.L. (1937) 2897, as amended, 43 P.S. § 802(b). Section 402(b) of the Law provides that a claimant is ineligible for benefits for any week in which her unemployment is due to leaving work without a necessitous and compelling cause. 43 P.S. § 802(b).

. It is apparent that the UCBR believed that, if Claimant had been legally married, she would have met her burden of proving necessitous and compelling cause under the "following spouse doctrine.”

. On the one hand, the majority states that evidence to prove the “following spouse doctrine” is completely irrelevant; on the other hand, the majority concludes that Claimant did not present sufficient evidence to prove the elements of the "following spouse doctrine.” This places Claimant in a "Catch-22” situation, giving her a burden that is impossible to meet.

. A referee must give a pro se claimant every assistance that is compatible with the impartial discharge of official duties. 34 Pa.Code § 101.21(a). This means that a referee must help a pro se claimant adequately develop the facts necessary for a decision. Lewis v. Unemployment Compensation Board of Review, 814 A.2d 829 (Pa.Cmwlth.2003). The majority states that Claimant failed to prove that her domestic partner’s son needed her in Florida. (Majority op. at 266.) However, because the referee believed it was irrelevant, the referee made no inquiries about the son’s special needs or how the presence of Claimant’s domestic partner in Florida would alleviate them.

.For example, the majority relies on a portion of Claimant’s testimony to find that the domestic partner's main reason for leaving her job was stress. (Majority op. at 266.) While giving credence and weight to that testimony, the majority gives no credence or weight to Claimant's testimony that job stress had an adverse effect on her domestic partner’s health. (N.T. at 10.) Of course, only the UCBR can determine the credibility and weight of evidence.

. This court recognizes unmarried, heterosexual, single-parent families for other purposes in determining necessitous and compelling cause. See Beachem (holding that a single father who relocated to care for an eleven-year-old son with emotional and behavioral problems had a necessitous and compelling reason for leaving his employment).

. I note that an individual may legally adopt the child of her same-sex partner where it would be in the best interests of the child. In Re: Adoption of R.B.F., 569 Pa. 269, 803 A.2d 1195 (2002).

. The mere fact that the domestic partner’s son is an adult child with special needs does not preclude an inquiry, on remand, into whether it is in the best interests of that child for his birth mother to leave her employment, i.e., whether the best interests of the child create necessitous and compelling cause to leave employment. The age of the child is irrelevant; indeed, the person with special needs could be an elderly parent or sibling. Moreover, should the UCBR find that Claimant is in loco parentis with her domestic partner’s son, so that the Claimant stands in the shoes of a parent, I submit it would be appropriate to apply the “following spouse doctrine.”

. The majority fails to consider the ‘‘best interests of the child” doctrine, which motivates and controls family law. If Claimant were to prove that she has provided care, shelter, nurture and affection to the children of her domestic partner, then Claimant and her partner have a real family, and, in a real family, the best interests of a child can create necessitous and compelling cause for leaving employment.