KATHRYN L. ROHAN, APPELLANT,
v.
TRAKKER MAPS, INC. AND FLORIDA UNEMPLOYMENT APPEALS COMMISSION, APPELLEES
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Kathryn Rohan appealed the denial of her Florida unemployment compensation benefits claim. The court reversed, holding that collateral estoppel from a prior federal Disaster Unemployment Assistance (DUA) denial could not be applied to bar her from a hearing on the merits of her separate state unemployment claim.
Collateral estoppel does not apply to bar a hearing on the merits of the Florida unemployment claim. Although Rohan received a full and fair hearing in the DUA proceeding, the issues adjudicated in that federal claim (whether unemployment was a direct result of the major disaster) are not the same as the issues in the state claim (whether she left work without good cause attributable to her employer), and therefore collateral estoppel cannot prevent relitigation of the state claim.
[1] The doctrine of collateral estoppel prevents relitigation of issues actually adjudicated in a prior suit.
[2] A prior determination that unemployment was not a direct result of a major disaster does not preclude a subsequent determination on whether the claimant left work without…
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Join FLexlaw to unlock all legal intelligence“The application of collateral estoppel prevents the parties in a second suit from litigating those points in question which were actually adjudicated in the first suit.”
Statement of the general legal principle governing collateral estoppel.
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Join FLexlaw to unlock all legal intelligenceAfter Hurricane Andrew in 1992, Rohan filed both a federal DUA claim and a state Florida unemployment compensation claim. She had left her job after h…
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NESBITT, Judge.
Claimant, Kathryn L. Rohan, appeals an order denying her claim for Florida unemployment compensation benefits. We reverse.
Shortly after the natural disaster commonly known as “Hurricane Andrew,” the claimant filed two claims for unemployment benefits. The first was a Disaster Unemployment Assistance (DUA) claim, filed under a federal disaster relief law. The second was a regular claim for Florida unemployment compensation benefits.
The claimant stopped working for the employer on approximately September 9, 1992. She stopped working for the employer because the general manager wanted her to work more hours than she was willing to work.
After several postponements and continuances, Rohan’s appeal from an earlier adverse determination on her Florida unemployment compensation claim was then heard. Section 443.101(l)(a), Florida Statutes (1991) provides an individual shall be disqualified for benefits “[f]or the week in which he has voluntarily left his work without good cause attributable to his employing unit....”
At the evidentiary hearing for this appeal, the referee reviewing the claim, received into evidence a copy of the DUA decision and concluded:
Since the record reflects that the claimant attended a full and fair hearing relative to the claimant’s job separation, the doctrine of collateral estoppel will apply, therefore, the appeals referee is bound by the referee’s finding of facts in Docket No. 92-43917DUA and the facts will not be disturbed.
Relying on the DUA’s order, the referee concluded that the claimant had stopped working “because the general manager wanted her to work more hours than she was willing to work” and denied Rohan’s claim. The referee’s decision was affirmed by the Florida Unemployment Appeals Commission.
The application of collateral estoppel prevents the parties in a second suit from litigating those points in question which were actually adjudicated in the first suit. United States Fidelity & Guaranty Co. v. Odoms, 444 So. 2d 78, 80 (Fla. 5th DCA 1984). The evidence from the earlier DUA hearing, although arguably broad enough to embrace the present claim was not dispositive of the claim. The denial of unemployment benefits on the basis that they had not been a result of a major disaster does not embrace the question of whether the claimant left work without any cause attributable to the employer. The claimant therefore was improperly denied a hearing on the merits of her Florida claim.
For this reason, the order of the Florida Unemployment Appeals Commission is reversed and the cause remanded.
Reversed.
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Brown v. R.J. Reynolds Tobacco Co., 611 F.3d 1324 (11th Cir. 2010)…t”); State Dep’t of Revenue v. Ferguson, 673 So. 2d 920, 922 (Fla. 2d DCA 1996) (“The doctrine of collateral estoppel prevents identical parties from relitigating issues that have previously been decided between them.”); Rohan v. Trakker Maps, Inc., 633 So. 2d 1176, 1177 (Fla. 3d DCA 1994) (“The application of collateral estoppel prevents the parties in a second suit from litigating those points in question which were actually adjudicated in the first suit.”); Liberty Mut. Ins. Co. v. Jozwick, 204 So. 2d 216,…
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Graham v. R.J. Reynolds Tobacco Co., 857 F.3d 1169 (11th Cir. 2017)…tween the parties in an earlier lawsuit.” Id. at 1332 (citations omitted). Like the District Court before us, we recognized that Florida’s doctrine of issue preclusion carried an actually decided requirement. Id. (citing Rohan v. Trakker Maps, Inc., 633 So. 2d 1176, 1177 (Fla. Dist. Ct. App. 1994)). Unlike the District Court, however, we did not take any position as to whether that requirement was required under the U.S. Constitution, “because,” we assumed, “under Florida law the findings could not be used” “t…
Authorities Cited
- United States Fid. & Guar. Co. v. Odoms, 444 So. 2d 78 (Fla. 5th DCA 1984)