Wood v. Louisiana Dept. of Employment Security

Roy Wood (plaintiff) worked for the New Orleans Police Department (the police department) as a commissioned officer. Wood also worked part-time at an apartment community that only used commissioned police officers as security personnel. The police department implemented changes that negatively affected Wood’s working hours. Therefore, Wood reluctantly resigned his commission with the police department. When Wood resigned his commission, his supervisor at the police department told him that, consequently, he would no longer be able to work at the apartment community. Wood applied for unemployment compensation. Although Wood never indicated that he quit working at the apartment community, the Louisiana Department of Employment Security (the department) (defendant) handled Wood’s claim as though he had quit the part-time position voluntarily, and his claim for benefits was disqualified. Section 23:1601(1)(a) of Louisiana’s unemployment compensation statute provided that disqualification for benefits occurred if an employee left his job without good cause attributed to a significant change in employment caused by the employer. On the other hand, § 23:1601(2)(a) provided that if an employee had been discharged, disqualification only occurred for misconduct by the employee. An administrative-law judge also found Wood’s claim to be disqualified under § 23:1601(1)(a), finding that Wood left employment without good cause that was attributed to a significant change in employment caused by his employer. A review board upheld the decision of the administrative-law judge. In reviewing the case, a district court also affirmed Wood’s disqualification despite acknowledging that Wood’s separation from employment was more akin to a termination at the employer’s direction or a constructive discharge related to an employee’s lack of an essential qualification. The district court also relied on § 23:1601(1)(a), finding that the apartment community had not caused a significant change in Wood’s employment that caused separation. The district court reasoned that an employer was permitted to enforce job qualifications that were reasonable and that if an employee was not able to satisfy those qualifications, the employer was permitted to discharge the employee, and the employee would be disqualified from receiving unemployment compensation. Wood appealed.