Physicians Health Plan of Mid Michigan v. Chapman
Digest No. 12.149
Cite as: Physicians Health Plan v Chapman, unpublished opinion of the Ingham County Circuit Court, issued December 16, 2008 (Docket No. 08-628-AE).
Appeal pending: No
Claimant: Shanika Chapman
Employer: Physicians Health Plan of Mid Michigan
Date of decision: December 16, 2008
HOLDING: It is misconduct as a matter of law when an insurance company employee committs insurance fraud in violation of her employer’s human resources manual.
FACTS: Claimant worked in customer service for the employer insurance company; her job duties included assessing claims and administering customers’ financial obligations. Claimant was fired after she revealed to her employer that she committed criminal fraud by filing a false claim against her car insurance company.
At the ALJ hearing, the employer cited its H.R. policy manual as permitting employee firings for criminal activity, which could harm the employer’s public image. But, the ALJ decided Claimant was still not disqualified from receiving benefits for misconduct. The Board of Review affirmed, citing the mandate to interpret the meaning of misconduct narrowly to avoid disqualification.
DECISION: Reversed. The Circuit Court determined that claimant’s conduct constituted misconduct connected with her work, disqualifying her from benefits.
RATIONALE: The Circuit Court surveyed various cases regarding whether off-duty conduct may be sufficiently connected to a claimant’s work to constitute misconduct. Ultimately, it concluded that, as a matter of law, the filing of a false insurance claim constituted a wanton disregard of the employer’s interests and standards of behavior. This behavior clouded Claimant’s ability to fulfill her job duties, particularly given her unique financial responsibilities; sufficiently involved the employer’s interests; and adversely affected the employer’s behavioral expectations of employees.
Digest author: Austin L. Webbert, Michigan Law, Class of 2017
Digest updated: 10-31-2017