Michigan Tool Co. v. Employment Security Commission, 346 Mich. 673

Summary

The Michigan Supreme Court considered whether employees were disqualified from unemployment benefits because their unemployment resulted from a work stoppage caused by a labor dispute. The court upheld the appeal board’s finding that the employer failed to prove that an alleged production slowdown caused the plant closure, and held that the employer bore the burden of producing competent evidence of the slowdown. The court reversed the circuit court and remanded for reinstatement of the appeal board’s order.

Holdings

1. Section 29(1)(b) disqualifies an individual only when the unemployment is due to a stoppage of work existing because of a labor dispute. The existence of disputes between the employer and union did not establish that the plant closure and resulting unemployment were caused by those disputes.
2. The appeal board's finding that the employer failed to prove a slowdown was not contrary to the great weight of the evidence and therefore could not be reversed.
3. Although claimants generally bear the burden of establishing eligibility for benefits, the employer bore the burden of producing competent and convincing evidence of the alleged slowdown because the relevant facts were peculiarly within the employer's knowledge and control.

Questions Presented

1. Whether the claimants' unemployment was due to a stoppage of work existing because of a labor dispute, so as to disqualify them from benefits under section 29(1)(b) of the Michigan Employment Security Act.
2. Whether the employment-security appeal board's finding that the asserted slowdown was not proved was contrary to the great weight of the evidence.
3. Whether the employer, rather than the claimants, bore the burden of producing competent and convincing evidence of the alleged slowdown when the relevant facts were peculiarly within the employer's knowledge and control.

Disposition

reversed_and_remanded