DeBoer Transportation, Inc. v. Swenson

DYKMAN, EJ.

¶ 21. (dissenting). The majority opinion starts off well, explaining that this is an administrative review dependent on the meaning of Wis. Stat. *497§ 102.35(3) (2007-08).1 It quotes the statute. But the train runs off the track at ¶ 13, when the majority uses deBoer's uniform and long-standing practice to interpret "reasonable cause" under the statute. It is not surprising then that, having used an incorrect analysis, the majority reaches the wrong conclusion.

¶ 22. The correct analysis focuses on the plain language of the statute. Wisconsin Stat. § 102.35(3) reads:

Any employer who without reasonable cause refuses to rehire an employee who is injured in the course of employment, where suitable employment is available within the employee's physical and mental limitations, upon order of the department and in addition to other benefits, has exclusive liability to pay to the employee the wages lost during the period of such refusal, not exceeding one year's wages. In determining the availability of suitable employment the continuance in business of the employer shall be considered and any written rules promulgated by the employer with respect to seniority or the provisions of any collective bargaining agreement with respect to seniority shall govern.

The statute says nothing about long-standing and uniform practices. It says nothing about what an employee must say or do to be rehired. Instead, § 102.35(3) focuses only on an employer's duty to rehire an injured employee.

¶ 23. We are not interpreting this statute for the first time. The supreme court explained what Wis. Stat. § 102.35(3) was all about in West Allis School District v. DILHR, 116 Wis. 2d 410, 422-23, 342 N.W.2d 415 (1984):

*498Hence, in accord with long accepted traditional approaches to workers compensation statutes, sec. 102.35(3) must be liberally construed to afford the aggrieved worker additional compensation.
Also, as stated above, sec. 102.35(3), Stats., as a part of the workers compensation act, must be liberally construed to effect as fully as possible the beneficent objectives of the workers compensation act. It was well settled at the time of the enactment of sec. 102.35(3) that the compensatory aspects of ch. 102 were to be liberally construed.
It is clear from the plain words of the statute that its purpose is to prevent discrimination against employees who have previously sustained injuries and to see to it, if there are positions available and the injured employee can do the work, that the injured person goes back to work with his former employer. This fundamental purpose, and the objective of worker protection explicit in the workers compensation act, makes the construction urged by the school district inappropriate .... [I]t would defeat the clear legislative purpose of providing compensation to the employee of not more than a year's wages should the refusal to rehire be found unreasonable.

¶ 24. We have explained that Wis. Stat. § 102.35(3) puts the burden of showing a reasonable refusal to rehire on the employer. Dielectric Corp. v. LIRC, 111 Wis. 2d 270, 278, 330 N.W.2d 606 (Ct. App. 1983).

¶ 25. I am not sure why the majority has concluded that LIRC's conclusion was unreasonable, but I am sure what it has not done: it has not interpreted *499Wis. Stat. § 102.35(3) in the way the supreme court and the court of appeals have told us we must. The statute is short, unambiguous, and to the point. It nowhere suggests that extraneous matters that the majority considers important, such as a long-standing and uniformly enforced rule, an ailing father or woodworking and dance classes are relevant to whether an employer's test for rehire is reasonable. These factors are important only to the majority. It is apparent to me that before refusing to rehire an injured employee, the employer must determine only whether it has reasonable cause to refuse to rehire. Or, put in terms of standard of review, we examine whether LIRC properly found that the employer's decision not to rehire was or was not reasonable. That is the beginning and the end.

¶ 26. The majority writes that "[t]he commission seemingly accepted deBoer's assertion that the purpose of the check-ride was to ensure that it employed safe drivers and that the policy was reasonable on its face." Majority, ¶ 6. Where does that come from? What LIRC really wrote was that deBoer

did not credibly explain how the applicant's fitness to resume over-the-road driving could only have been evaluated by an overnight road trip. If it was the night driving the employer was concerned about, it could have required the applicant to have gone out with an observer on a night driving trip, with a return home the following morning. This would have been precisely the type of route the applicant had driven in his pre-injury employment. The employer's unyielding insistence that there be an extended overnight trip was unexplained and unreasonable.

LIRC Decision, ¶ 1.

¶ 27. The second paragraph of LIRC's decision, and the Administrative Law Judge's lengthy decision, *500which LIRC adopted, can be reduced to this: "DeBoer unreasonably refused to accommodate Swenson's reasonable request for an alternative test ride which would allow him to attend to his ailing father." While I agree with this conclusion, it is not necessary to go there. Wisconsin Stat. § 102.35(3) says nothing about accommodating an injured employee's request for accommodation. Adding accommodation to a clear statutory mandate complicates and confuses the real issue. The majority's focus on this will o' the wisp is a classic example of an analysis led astray by a red herring.

¶ 28. The only relevant question is whether LIRC erred in finding that deBoer did not have reasonable cause to refuse to rehire Swenson because Swenson did not perform a several-day road trip. LIRC found that this was unnecessary to establish his fitness to perform the type of employment he held before his injury.

¶ 29. We do not review LIRC's answer to this question de novo. We recently said that we afford LIRC great weight deference in interpreting worker's compensation statutes "[bjased on the [cjommission's duty to administer the worker's compensation statutes, its longstanding interpretation of these statutes, its expertise, and the benefit of consistent decisions." McRae v. Porta Painting, Inc., 2009 WI App 89, ¶ 7, 320 Wis. 2d 178, 769 N.W.2d 74. We also explained that "[ujnder the great weight deference standard of review we will uphold the [cjommission's interpretation and application of the statute to the facts found unless the interpretation is unreasonable," and that "[ajn unreasonable interpretation of a statute is one that directly contravenes the words of the statute, is clearly contrary to legislative intent, or is otherwise without rational basis." Id., ¶ 21 (citation omitted). The majority appears *501to choose Number 3, but fails to explain why the part of LIRC's decision I have quoted is irrational.2

¶ 30. The majority concludes that because the employer's "check-ride" policy was of long standing and uniformly enforced, and had some relation to safety, the application of this policy to Swenson must be reasonable.3 There is nothing magical about a long-standing but arbitrary policy. A uniformly enforced capricious policy does not somehow become reasonable. Suggest*502ing that some uniformly enforced, long-standing governmental and commercial policies about race, gender and ethnicity must be reasonable because they were or are long standing and uniformly enforced is easily recognized as bogus.

¶ 31. So that leaves us with safety. Facially, who could disagree that upholding safety requirements for truck drivers is reasonable? But even safety involves a cost-benefit analysis. Cloverleaf intersections are not required for every intersection of every road. That is where reasonableness enters the picture. LIRC makes decisions about reasonableness every time it hears a case under Wis. Stat. § 102.35(3). That is always a legal conclusion intertwined with facts. It is probably no coincidence that this is also the definition of the "great weight" or highest standard of deference we use when reviewing administrative decisions. See Clean Wisconsin, Inc. v. PSC, 2005 WI 93, ¶ 41, 282 Wis. 2d 250, 700 N.W.2d 768. So, for me, the question is whether I should defer to LIRC's conclusion intertwined with facts that the employer's refusal to rehire Swenson was not reasonable. I do not believe that whether an employer's policy is long standing or uniformly enforced should have anything to do with the majority's or my decision.

¶ 32. The majority concedes that if the first paragraph of LIRC's decision is considered without considering LIRC's paragraph two and the ALJ's decision, Swenson might prevail because LIRC found deBoer's check-ride policy unreasonable as to Swenson. Majority, ¶ 11 n.3. By turning LIRC's two paragraphs into one, the majority avoids a necessary inquiry. What would the majority do if all LIRC wrote was the first paragraph of its decision? The majority isn't saying. I conclude that had LIRC done so, the court of appeals would have issued a per curiam decision or summary order affirm*503ing the trial court and LIRC. Thus, the majority is really telling us that LIRC's second paragraph and the ALJ's decision are poison pills which doom anything else LIRC has found or concluded. I conclude that the second paragraph of LIRC's decision together with the ALJ's decision are unnecessary to our analysis, under whatever standard of review we might use.4 I am not willing to accept that we are to scour administrative *504decisions for any error we can find, and having found one, blow up the whole decision even though we would affirm the agency based on the balance of its decision. I cannot agree with this new concept.

¶ 33. We grant trial courts far more deference than the majority gives LIRC under situations similar to this one. Administrative agencies and trial courts both exercise discretion. "[I]f the trial court's exercise of discretion demonstrates consideration of improper facts or a mistaken view of the law, the reviewing court need not reverse if it can conclude ab initio that facts of record applied to the proper legal standard support the trial court's conclusion." State v. Pittman, 174 Wis. 2d 255, 268-69, 496 N.W.2d 74 (1993). Why cannot we do the same for LIRC's determination that deBoer's reason for not re-hiring Swenson was unreasonable? If LIRC's comments about Swenson's ailing father show that it considered improper facts or that it held a mistaken view that the statute permitted or required consideration of Swenson's father's illness, why cannot we do as we do for trial courts: ignore the improper facts and apply the relevant facts found by LIRC to the statute? We can, and if we do, we would affirm.5 The majority has turned standard of review on its head. Instead of *505searching for reasons to affirm LIRC, the majority has searched for reasons to reverse.

¶ 34. I will give great weight to LIRC's decision. While safety is important for truck drivers, there is a disconnect between requiring Swenson to spend several days of overnight over-the-road driving when all that Swenson had done and would do if rehired would be day trips with single overnight stays. Swenson did a day trip for his employer, apparently with no problems. LIRC was entitled to believe that no useful purpose would be served by requiring Swenson to take an extended overnight trip when his future employment would have nothing to do with that type of driving and therefore deBoer's insistence on a multi-day, overnight check-ride as a condition of employment was unreasonable. I have explained why I do not join in the majority's decision. Therefore, the best I can do is respectfully dissent.

All references to the Wisconsin Statutes are to the 2007-08 version unless otherwise noted.

Even looking at this case without the guidance of West Allis School District v. DILHR, 116 Wis. 2d 410, 342 N.W.2d 415 (1984), and McRae v. Porta Painting, Inc., 2009 WI App 89, 320 Wis. 2d 178, 769 N.W.2d 74, the majority's conclusion that LIRC's decision is unreasonable is tenuous. "Reasonableness" has a history. We do not review a court's decision as to the reasonableness of some act de novo. Wassenaar v. Panos, 111 Wis. 2d 518, 525, 331 N.W.2d 357 (1983), identified reasonableness as a question of law, though, because that conclusion was intertwined with factual findings supporting the conclusion, stated that an appellate court should give weight to the trial court's decision. The Wassenaar standard has been imported into administrative reviews. West Bend Education Ass’n v. WERC, 121 Wis. 2d 1, 12, 357 N.W.2d 534 (1984), reads: "Where a legal question is intertwined with factual determinations or... where the agency's interpretation and application of the law is of long standing, a court should defer to the agency which has primary responsibility for determination of fact and policy." (Footnote omitted.)

DeBoer might also have a long-standing and uniformly enforced policy requiring its janitors to take a check-ride or to attend three supreme court oral arguments as a condition of re-employment after an injury. But that would not require LIRC to find that these long-standing and uniformly enforced requirements were reasonable. The focus of our review should be on the rationality of LIRC's reasoning as to the reasonableness of the conditions for re-employment as applied to each returning employee. We should defer to LIRC's decisions on this issue.

Paragraph two of LIRC's decision reads:

The simple accommodation the applicant requested for the testing process was reasonable, and it would not have jeopardized any of the employer's safety concerns. The applicant merely asked for an alternative schedule so that he could care for his terminally ill father, but the employer gave no explanation for failing to even consider this request. As noted by the administrative law judge, the employer had the burden of demonstrating reasonable cause for discharging the applicant, but failed to carry that burden. The employer's safety director refused to discuss any possible accommodation with the applicant, resulting in what constituted a discharge. The courts have regularly held that the statute must be liberally construed to effectuate its beneficent purpose of preventing discrimination against injured employees. The employer's actions evinced an unreasonable disregard for the applicant's circumstances, leading to the credible inference that the work injury did play a part in the discharge. The employer violated both the spirit and the letter of the law set forth in Wis. Stat. § 102.35(3).

While I have concluded that paragraph two of LIRC's decision is unnecessary, I do not agree with the majority's decision even if I consider paragraph two. The ultimate question is whether deBoer's refusal to rehire Swenson was unreasonable. Reasonableness is a large enough umbrella to cover deBoer's response to Swenson's request for accommodation. The majority tells us that any non-work, non-injury request for accommodation to an employer's long-standing and uniformly enforced rehire policy makes an employer's decision to refuse to rehire the employee reasonable. That conclusion ignores the plain meaning of Wis. Stat. § 102.35(3).

LIRC has not had the opportunity to consider this dispute between LIRC and Swenson under the interpretation the majority gives to Wis. Stat. § 102.35(3). That interpretation makes significant changes in the analysis parties and LIRC have used to determine eligibility in refusal to rehire cases. At the very least, we should reverse and remand with instructions to remand to LIRC for consideration of deBoer's liability under the majority's new analysis. A reviewing court would then know whether LIRC would come to a different conclusion under the interpretation of § 102.35(3) that the majority has promulgated today.