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ALBERT MOLNAR v. ADMINISTRATOR, UNEMPLOYMENT COMPENSATION ACT

Connecticut Supreme Court1996-11-12No. 15449
239 Conn. 233

Summary

Holding. The court affirmed the trial court's judgment, upholding both that workers' compensation benefits do not qualify as "wages" for purposes of calculating unemployment compensation eligibility and that the twelve-quarter lookback requirement in the statute does not violate the equal protection clause.

Albert Molnar worked part-time for Domino's Pizza until he sustained a work-related leg injury in May 1988. He received workers' compensation temporary total benefits until June 1994, when he was cleared to return to work. When he applied for unemployment compensation benefits in July 1994, he was denied because he had no wages during the relevant base period used to calculate benefits for workers' compensation recipients.

Molnar challenged the denial on two grounds. First, he argued that workers' compensation benefits should count as "wages" under the unemployment compensation statute, which would have made him eligible. Second, he contended that the statute's requirement that a worker's most recent employment quarter fall within twelve calendar quarters of the benefit claim violated equal protection principles. The trial court rejected both arguments, finding that workers' compensation payments are distinct from wages and that the twelve-quarter limitation has a rational basis.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether workers' compensation benefits constitute "wages" under unemployment compensation law
  • Whether the base period calculation for workers' compensation recipients violates equal protection
  • Whether the twelve-calendar-quarter limitation on eligibility has a rational basis

Procedural posture

Molnar appealed from a Superior Court decision affirming the Employment Security Board of Review's determination that he was ineligible for unemployment compensation benefits.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

PER CURIAM.

The two issues presented by this appeal are whether the trial court properly determined that: (1) workers’ compensation benefits do not qualify as “wages” within the meaning of General Statutes § 31-222 (b) (l) and therefore could not be used to determine the base period of a benefit year under General Statutes § 31-230; and (2) so interpreted, § 31-230 does not violate the equal protection clause of the fourteenth amendment to the United States constitution. We affirm the judgment of the trial court.

The plaintiff, Albert Molnar, was a part-time employee of Domino’s Pizza in May, 1988, when he severely injured his leg in the course of his employment. He thereafter collected temporary total benefits from his employer’s workers’ compensation carrier until June, 1994, when he was declared eligible to return to work. The plaintiff subsequently applied for unemployment compensation benefits effective July 10,1994, and was found ineligible by an unemployment compensation examiner due to his lack of wages during the base period applicable to those individuals receiving workers’ compensation benefits. See General Statutes § 31-230. The plaintiff unsuccessfully appealed that decision within the agency, first to an appeals referee and later to the employment security board of review (board). He subsequently appealed to the Superior Court, which affirmed the board’s decision.

The trial court concluded that the board did not act arbitrarily in affirming the referee’s determination that workers’ compensation benefits received by an employee during a period of incapacity do not qualify as wages within the meaning of § 31-222 (b) (1).

The plaintiff also raised an equal protection claim to the trial court, arguing that no rational basis exists for the legislatures determination that only the recipient of workers’ compensation benefits whose “last most recently worked calendar quarter is no more than twelve calendar quarters prior to the date” of the individual’s initiating claim could subsequently receive unemployment compensation benefits once he or she was declared eligible to return to work. See General Statutes § 31-230. Finding that there was a rational basis for the twelve quarter cutoff, the trial court rejected that claim. The plaintiff appealed from the judgment of the trial court to the Appellate Court, and we transferred the appeal to this court pursuant to Practice Book § 4023 and General Statutes § 51-199 (c).

Our examination of the record and the briefs and arguments of the parties on appeal persuades us that the judgment of the trial court should be affirmed. The central issues relating to the proper interpretation of the relevant statutes and the constitutionality of the classification contained in § 31-230 were properly resolved in the trial court’s thoughtful and comprehensive memorandum of decision. Molnar v. Administrator, Unemployment Compensation Act, 44 Conn. Sup. 285, 685 A.2d 1157 (1996). It would serve no useful purpose for us to repeat the discussion contained therein. Cf. Val-Pak of Central Connecticut North, Inc. v. Commissioner of Revenue Services, 235 Conn. 737, 740, 669 A.2d 1211 (1996); Greater Bridgeport Transit District v. State Board of Labor Relations, 232 Conn. 57, 64, 653 A.2d 151 (1995).

The judgment is affirmed.

General Statutes § 31-222 (b) (1), which defines the wages to be used in determining unemployment compensation, provides: “ ‘Total wages’ means all remuneration for employment and dismissal payments, including the cash value of all remuneration paid in any medium other than cash except the cash value of any remuneration paid for agricultural labor or domestic service in any medium other than cash.”

General Statutes § 31-230 provides in relevant part: “The base period of a benefit, year shall be the first four of the five most recently completed calendar quarters prior to such benefit year . . . except that for any individual who is eligible to receive or is receiving workers’ compensation . . . the base period shall be the first four of the five most recently worked quarters prior to such benefit year, provided . . . the last most recently worked calendar quarter is no more than twelve calendar quarters prior to the date such individual makes his initiating claim.”