Williams v. Ohio Dep't of Job & Family Servs.
Annotate this CaseAfter appellee Mary Williams was hired as a full-time residential social worker at appellant Bridgeway, Inc., a community mental health center, Bridgeway offered Williams a promotion. The promotion was conditioned on the requirement that Williams obtain certification as a Licensed Independent Social Worker (LISW) within 15 months. Because Williams did not obtain her LISW certification within the time required, she was terminated. Williams' application for unemployment compensation was disallowed by the Ohio Department of Job and Family Services, which determined that Williams had been discharged with just cause. On appeal, the Unemployment Compensation Review Commission affirmed. The court of common pleas denied Williams's subsequent appeal. The court of appeals reversed, holding that Williams's requirement to obtain an LISW certification was not fairly applied to other program managers. Bridgeway appealed. The Supreme Court reversed the judgment of the appellate court, holding that when employment is expressly conditioned upon obtaining or maintaining a license or certification and an employee agrees to the condition and is afforded a reasonable opportunity to obtain or maintain the license or certification, an employee's failure to comply with that condition is just cause for termination for unemployment compensation purposes.
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