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Riekse v Grand Rapids Public Schools 5.04

Section 27(i)

DENIAL PERIOD, Past performance as a substitute, Reasonable assurance, Substitute teacher

CITE AS: Riekse v Grand Rapids Public Schools, 144 Mich App 790 (1985)

Appeal pending: No

Claimant: Nancy Riekse

Employer: Grand Rapids Public Schools

Docket No: B83 16325 93580W

COURT OF APPEALS HOLDING: If a teacher had a reasonable expectation of re-employment during the next academic year, unemployment compensation may be properly denied.

FACTS: Claimant had been a substitute teacher for the past seven years in the employer's school system. During the ending school year, claimant had taught 125 days. Claimant received a letter from the employer indicating that, "based upon the best financial data available and a comprehensive analysis of projected staffing needs," she could be reasonably assured that she would be offered a substitute teaching position during the incoming school year. Claimant returned an application for employment as a substitute and attended an in service meeting for teachers on September 6, 1983.

DECISION: Claimant is ineligible for unemployment benefits.

RATIONALE: Claimant had substantial and reasonable assurance that she would be re-employed. She had been employed as a substitute teacher for seven preceding years. The letter expressly stated claimant was reasonably assured of employment. Claimant had attended in service training. The term reasonable assurance does not require a formal written or oral agreement to rehire.


3, 11:NA

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