Rankin v. Director, Employment Security Department

Sam Bird, Judge.

On July 3, 2002, this court handed down Rankin v. Director, 78 Ark. App. 174, 79 S.W.3d 885 reh’g denied, review denied (2002) (Rankin I), in which we reversed and remanded the Board’s decision denying benefits to appellant pursuant to Ark. Code Ann. § 11-10-513 (Repl. 2002) because he had voluntarily left employment without good cause connected with the work. The rationale of our reversal was that because appellant, who was an inmate at the Arkansas Department of Correction (ADC) participating in a work-release program and assigned to Nucor Steel in Blytheville, was involuntarily transferred by ADC so as to render it impossible for him to continue in Nucor’s employment, his reason for leaving his employment was not voluntary. Thus, we held that the Board’s conclusion that appellant had voluntarily left his employment was not supported by substantial evidence. Our opinion concluded with the recitation that the matter was reversed and remanded to the Board “for further proceedings consistent with this opinion.”

Perhaps understandably, the Board took our recitation to mean that it was authorized to conduct further proceedings. After all, that is what our opinion said. On the other hand, it is not understandable how the Board could have reasonably interpreted our instruction to mean that it was authorized, sua sponte, to conduct a hearing for the purpose of determining if there was some other basis under Ark. Code Ann. § 11-10-513, aside from voluntarily leaving work, for denying benefits to the appellant. In the first place, such an interpretation is not consistent with our July 3, 2002, opinion. Secondly, although Ark. Code Ann. § 11-10-529(c)(2)(A) (Repl. 2002) authorizes this court to order that additional evidence be taken before the Board, we did not issue such a directive. Last, and perhaps most importantly, such an interpretation of our instruction contravenes the doctrine of the law of the case.

The doctrine of the law of the case provides that a decision of an appellate court establishes the law of the case for trial upon remand and for the appellate court itself upon subsequent review. Linder v. Linder, 348 Ark. 322, 72 S.W.3d 841 (2002). The doctrine prohibits a court from reconsidering issues of law and fact that were decided or issues that could have been raised on appeal, and provides that such issues are conclusively adjudicated and can no longer be litigated by the parties. Rainbolt v. Director, 6 Ark. App. 204, 639 S.W.2d 532 (1982). We have held that the doctrine is applicable to administrative agencies generally and, specifically, to the Board of Review. Id.

Almost exactly the same thing that has occurred here was prohibited in Rainbolt v. Director, 6 Ark. App. 204, 639 S.W.2d 532 (1982) (Rainbolt II) under the doctrine of the law of the case. In Rainbolt v. Director, 3 Ark. App. 48, 621 S.W.2d 877 (1981) (Rainbolt I), the claimant appealed from the Board of Review’s decision denying her unemployment benefits on the ground that she had voluntarily quit her job to accompany her spouse to a new place of residence but had not made an immediate entry and become available for suitable work in the new labor market. We reversed the Board’s decision, holding that “the Employment Security Division may be estopped to deny that appellant made an immediate entry into the labor market because of the apparent representations of its agent.” We also remanded the case to allow the State an opportunity to present evidence in rebuttal to the claimant’s estoppel defense.

We considered the remand appropriate in Rainbolt I because it was the first case in which the doctrine of estoppel had been applied to the State in a claim for unemployment benefits. However, upon remand, the Board, although receiving and considering the additional evidence that the State had presented on the issue of estoppel, concluded that the claimant was disqualified for benefits because she had quit her job for personal reasons, a basis of denial entirely different from the reason given for the denial originally. In reversing and remanding Rainbolt II, we said that our decision in Rainbolt I had become the law of the case and that issues other than estoppel were not open for consideration by the Board on remand because of the applicability of the doctrine of the law of the case. Rainbolt v. Director, 6 Ark. App. 204, 207, 639 S.W.2d 532, 534 (1982) (Rainbolt II).

Our holding in Rainbolt II is clearly controlling in the present case. Rankin I came to this court on the single issue of whether the appellant was disqualified for unemployment benefits because he had voluntarily left the employment without good cause connected with the work. We reversed, holding that there was no substantial evidence that appellant’s departure from his job at Nucor Steel was voluntary. However, on remand, instead of awarding benefits, the Board of Review conducted a hearing on an entirely different issue. From the evidence at that hearing the Board of Review concluded that claimant was disqualified for benefits because of misconduct connected with the work. This was contrary to the law of the case as established by Rankin I and was, therefore, erroneous as a matter of law.

The concurring opinion of Judge Griffen has accused the majority of remaining silent about what he calls “flagrantly injudicious conduct” on the part of the Board of Review. We do not share this characterization of our declination to discuss the manner in which the Board proceeded. Under Ark. Code Ann. § ll-10-529(c)(l), in the absence of fraud, our review of the decisions of the Board of Review is limited to a determination of whether the Board’s findings of fact are supported by the evidence and whether the Board has erred on questions of law. Our decision concludes that the Board’s action was erroneous as a matter of law, and it sets forth the bases for that conclusion. Therefore, no purpose within our jurisdiction is served by launching into an intensive examination of the actions of the Board that apparently led to its error.

We also note Judge Crabtree’s concurring opinion in which he agrees with our application of the doctrine of the law of the case to reverse the Board of Review, but he expresses his disagreement with Rankin I, decided by a three-judge panel of this court, that reversed the Board of Review’s decision denying benefits to Rankin. Whether we now agree or disagree with the decision of the three-judge panel in Rankin I is simply not pertinent to the application of the doctrine of the law of the case. Even if the Rankin I decision was wrong (and some of the majority may believe that it was), when our decision in Rankin I became final, its conclusion that the Board of Review had improperly denied benefits to Rankin on the sole ground that he had voluntarily left his employment without good cause connected with the work became the law of the case. While the holding in Rankin I can be overruled in a future case, the doctrine of the law of the case precludes the Employment Security Department, the Appeals Tribunal, the Board of Review, and this court from considering any other basis upon which benefits could be denied to Rankin in this case.

In accordance with our decision in Rainbolt II, the proceedings of the Appeal Tribunal and the Board of Review on remand were improper. Therefore, this case is again remanded to the Board of Review with instructions to enter an award requiring the Employment Security Department to pay unemployment benefits to the appellant. Also, as we did in Rainbolt II, we direct the Board to certify the record of its decision to this court within thirty days from the date thereof.

Reversed and remanded.

Vaught and Roaf, JJ., agree. Griffen and Crabtree, JJ., concur. Hart, J., concurs separately.