Whether claimant was disqualified from benefits under MCL 421.29(1)(a) (whether she “voluntarily quit” her job); Interpretation of MCL 421.27(d); Unemployment Insurance Appeals Commission (the Commission); Administrative law judge (ALJ)

Agreeing with the circuit court’s analysis, the court affirmed the circuit court’s ruling affirming in part and reversing in part the Commission's order as to claimant-Martin’s entitlement to unemployment benefits. The case involved a dispute about the circumstances under which Martin quit her job as a cashier and bartender for respondent. The appellant-Agency contended that the trial court “exceeded its authority to review the Commission’s decision, and that the circuit court misinterpreted the applicable law when it held that Martin was eligible for 14 weeks of benefits.” The court noted that the “issue before the ALJ was whether Martin was disqualified from benefits under MCL 421.29(1)(a), i.e., whether Martin ‘voluntarily quit’ her job.” The Agency took “a remarkably cramped view of the circuit court’s authority in this case. In a hypertechnical sense, the Agency is correct: no reference was made to § 27(d) before the ALJ or the Commission. But as the circuit court noted, once the Commission made the determination that Martin was eligible for benefits, the plain language of § 27(d) mandated that she is eligible for ‘not more than 20 weeks of benefits or less than 14 weeks of benefits.’ The Commission found that Martin was not disqualified for benefits, but it determined that she was eligible for only two weeks of benefits, in direct contradiction to the statute. Thus, it made an error of law, which the circuit court had the authority to correct just as it did in setting the minimum period of eligibility for benefits at 14 weeks.” The court also rejected the Agency’s claim that the circuit court misinterpreted MCL 421.27(d).