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Storey v Meijer, Inc 16.23

Section 11(b)

APPEALS, Collateral estoppel

CITE AS: Storey v Meijer, Inc, 431 Mich 368 (1988).

Appeal pending: No

Claimant: William F. Storey

Employer: Meijer, Inc.

Docket No: NA

SUPREME COURT HOLDING: MESC determinations are not to be used to collaterally estop the litigation of issues in a subsequent civil suit but are limited to the purpose of determining a claimant's eligibility for benefits.

FACTS: Claimant was denied benefits by the MESC because of theft connected with his work. The Referee concluded there was neither theft nor discharge, but that finding was reversed by the Board of Review. While that appeal was pending at the Board, claimant filed a wrongful discharge action in circuit court. Employer moved for summary disposition on the basis the Board's factual findings regarding claimants disqualification collaterally estopped him from relitigating those issues. The circuit court granted summary disposition and the court of appeals affirmed.

DECISION: The circuit court's summary disposition in favor of the employer is reversed. Remanded for further proceedings.

RATIONALE: "We find that Section 11(b)(1) clearly and unambiguously prohibits the use of MESC information and determinations in subsequent civil proceedings unless the MESC is a party or complainant in the action.

Furthermore, our decision in this case advances the legislative purpose of the unemployment compensation system and is supported by considerations of public policy that underly the exceptions to the application of collateral estoppel. ...

Due to the full range of remedies available in a civil action, the parties have a greater incentive to fully litigate the civil claim than the claim for unemployment benefits. If collateral estoppel is applied to determinations of the MESC, both claimants and employers will be forced to fully litigate the administrative claim, potentially delaying the determination of benefit rights and burdening the unemployment compensation system."



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