Boyd-Davis v. Macomber Law, PLLC
Annotate this CaseClaimant-appellant Terri Boyd-Davis filed for unemployment compensation on January 27, 2013, and began receiving benefits. IDOL claims to have mailed an "online review letter" to Boyd-Davis' listed address on March 6, 2013. The Online Review Letter indicated that Boyd-Davis had been selected to provide additional information concerning her unemployment insurance claim for the week of March 2, 2013. The Online Review Letter instructed Boyd-Davis that she would need to complete work search documentation online. The letter also indicated that failure to complete the online eligibility review by 5:00 p.m. on March 15, 2013, would result in the denial of her benefits. Boyd-Davis claimed she did not receive the Online Review Letter. When Boyd-Davis had not provided the requested information by the deadline, IDOL issued an Eligibility Determination on March 19, 2013, indicating that Boyd-Davis had failed to complete the online eligibility review and as a result was ineligible for benefits effective March 10, 2013. Boyd-Davis filed a protest. A telephonic hearing was scheduled for April 18, 2013. On April 1, 2013, Boyd-Davis provided the information IDOL had requested in the Online Review Letter. As soon as the requested information was provided, Boyd-Davis' benefits were reinstated for the week beginning March 31, 2013. However, benefits were not reinstated for the period of March 10 through March 30, 2013. Boyd-Davis proceeded with the April 18, 2013, hearing seeking restoration of her benefits for the period of March 10 through March 30, 2013. Following the hearing, an IDOL Appeals Examiner affirmed the original eligibility determination and concluded that Boyd-Davis' benefits had been properly denied. After review, the Supreme Court reversed and remanded the case for further proceedings, finding that Boyd-Davis presented evidence that "would permit reasonable minds to conclude that the Online Review Letter was not received." The Court concluded that the Commission erred in its application of the presumption of delivery articulated in Idaho Code section 72-1368(5) of the online letter. Furthermore, the Commission abused its discretion in determining that Boyd-Davis was ineligible for unemployment benefits for the period from March 10, 2013, through March 30, 2013.
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