Summary
The Supreme Judicial Court of Maine held that an employee's voluntary resignation from reasonable post-injury employment, without good and reasonable cause, constitutes a refusal of a bona fide offer of employment under 39-A M.R.S.A. § 214(1)(A). The court further held that the statute applies even when workers' compensation benefits had not yet begun, vacated the hearing officer's decision awarding partial incapacity benefits, and remanded for further proceedings.
Topics
Practice areas
Questions Presented
- Whether 39-A M.R.S.A. § 214(1)(A) applies when the employer has not yet commenced payment of incapacity benefits.
- Whether an employee's voluntary resignation from reasonable post-injury employment constitutes a refusal of a bona fide offer of reasonable employment under § 214(1)(A).
Holdings
- Section 214(1)(A) applies whether or not the employer has commenced payment of benefits when the employee refuses a bona fide offer of reasonable employment.
- An employee's voluntary resignation from reasonable post-injury employment constitutes a refusal of a bona fide offer of reasonable employment under § 214(1)(A), absent good and reasonable cause.
Key quotations
“Because Holt's voluntary resignation of reasonable post-injury employment without good and reasonable cause constituted a refusal of an offer of bona fide employment pursuant to 39-A M.R.S.A. § 214(1)(A) (2001), we vacate the decision of the Hearing Officer.” (782 A.2d at 780)
“Because section 214(1)(A) addresses an employee's entitlement to benefits, it applies whether or not the employer has commenced payment of benefits at the time of the refusal.” (782 A.2d at 781)
“An existing employment relationship, however, implicitly constitutes an ongoing "offer" of employment, thereby obviating the need for an employer to make a formal, affirmative "offer" of employment.” (782 A.2d at 782)
Factual background
Stephanie Holt sustained a compensable right-knee injury on June 2, 1994, after teaching at Bonny Eagle High School for eighteen years, including sixteen years as head of the English Department. She continued working for SAD 6, which modified the workplace to accommodate her restrictions. Holt later began paid administrative leave for reasons unrelated to her injury and voluntarily resigned in October 1996; the Hearing Officer found that the resignation was not compelled by the injury or any other good and reasonable cause.
Procedural history
Holt suffered a compensable knee injury while employed by SAD 6, continued working with accommodations, later took paid administrative leave, and voluntarily resigned. She petitioned the Workers' Compensation Board for benefits, and the Hearing Officer awarded partial incapacity benefits. After the Hearing Officer rejected the employer's argument that Holt's resignation constituted refusal of bona fide employment, the Supreme Judicial Court granted appellate review and vacated the decision, remanding for further proceedings.
Remand instructions
Remanded to the Workers' Compensation Board for further proceedings consistent with the decision.